Owner and Data Controller 

Sportlytics SRL 

Owner contact email: info@sportlyticsapp.com

Types of Data collected 

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address; first name; last name; phone number; Usage Data; Trackers; payment info; device information; purchase history; Data communicated while using the service; Social media accounts permission; Camera permission; Photo Library permission; Health Data read permission; IP address; various types of Data; password; diagnostics; search 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. 

Users are responsible for any third-party Personal Data obtained, published or shared through this Application. 

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. 

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. 

 

Retention time 

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 

 

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: Registration and authentication, Contacting the User, Building and running this Application, Hosting and backend infrastructure, Displaying content from external platforms, Handling payments, Handling activities related to productivity, Interaction with external social networks and platforms, Device permissions for Personal Data access, Collection of privacy-related preferences, Platform services and hosting, Data transfer outside of the UK, Access to third-party accounts and Beta Testing. 

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”. 

 

Device permissions for Personal Data access 

Depending on the User’s specific device, this Application may request certain permissions that allow it to access the User’s device Data as described below. 

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document. 
The exact procedure for controlling app permissions may be dependent on the User’s device and software. 

Please note that the revoking of such permissions might impact the proper functioning of this Application. 

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application. 

 

Camera permission 

Used for accessing the camera or capturing images and video from the device. 

 

Health Data read permission 

Allows reading the User’s health Data. 

 

Photo Library permission 

Allows access to the User’s Photo Library. 

 

Social media accounts permission 

Used for accessing the User’s social media account profiles, such as Facebook and Twitter. 

 

Detailed information on the processing of Personal Data 

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

 

• Access to third-party accounts

  This type of service allows this Application to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User.

  Partner dati sportivi e API 

  Sportlytics gestisce la sessione di autenticazione con dati personali (nome, cognome, mail e password dell’utente) e il trattamento di dati sportivi personali raccolti da terze parti tramite API a cui l’utente dà autorizzazione di trattamento accettando la presente policy 

  This processing constitutes:

• • a Sale in the United States 

• • a Sharing in California 

• • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana 

 

• Beta Testing

  This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application. The service provider may automatically collect data related to crashes and statistics related to the User’s use of this Application in a personally identifiable form. 

  TestFlight (Apple Inc.) 

  TestFlight is a beta testing service provided by Apple Inc. 

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

  Place of processing: United States – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. 

  This processing constitutes: 

• • a Sale in the United States 

• • a Sharing in California 

• • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana 

 

• Building and running this Application

  Key components of this Application are built and run directly by the Owner by making use of the software listed below. 

  WordPress (self-hosted) (this Application) 

  This Application is built and run by the Owner via a CMS software (Content Management System) called WordPress. 

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

  Category of Personal Information collected according to the CCPA: identifiers. 

   

• Collection of privacy-related preferences

  This type of service allows this Application to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation. 

  iubenda Privacy Controls and Cookie Solution (iubenda srl) 

  The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on this Application. 

  Personal Data processed: IP address; Trackers. 

  Place of processing: Italy – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

   

• Contacting the User

  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. 

   

• Device permissions for Personal Data access

  This Application requests certain permissions from Users that allow it to access the User’s device Data as described below. 

  Device permissions for Personal Data access (this Application) 

  This Application requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document. 

  Personal Data processed: Camera permission; Health Data read permission; Photo Library permission; Social media accounts permission. 

  6Category of Personal Information collected according to the CCPA: biometric information; internet or other electronic network activity information. 

   

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it. 

  Instagram widget 

  Instagram is an image visualization service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages. 

  Personal Data processed: Trackers; Usage Data. 

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

   

• Handling activities related to productivity

  This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question. These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity. 

  Gmail (Google Ireland Limited) 

  Gmail is a service that manages email communication provided by Google Ireland Limited. Such email communication is not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside this service for advertising purposes in any other way. 

  Personal Data processed: Data communicated while using the service; Trackers. 

  Place of processing: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  Google Workspace (Google Ireland Limited) 

  Google Workspace is an integrated suite of cloud-based productivity, collaboration and storage services provided by Google Ireland Limited. Gmail or other G Suite services are not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside these services for advertising purposes in any other way. 

  Personal Data processed: Data communicated while using the service; Trackers. 

  Place of processing: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

   

• Handling payments

  Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed. 

  Payments processed via the Apple App Store (Apple Inc.) 

  This Application uses a payment service provided by Apple Inc. 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 Apple, as described in the privacy policy for the App Store. 

  Personal Data processed: device information; email address; first name; last name; payment info; phone number; Trackers. 

  Place of processing: United States – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity 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; email address; first name; last name; payment info; purchase history; Trackers. 

  Place of processing: United States – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity 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 services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored. 

  Firebase Cloud Firestore (Google LLC) 

  Firebase Cloud Firestore is a hosting and backend service provided by Google LLC. 

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

  Place of processing: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. 

  Firebase Cloud Functions (Google LLC) 

  Firebase Cloud Functions is a hosting and backend service provided by Google LLC. 

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

  Place of processing: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity 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. 

  LinkedIn button and social widgets (LinkedIn Corporation) 

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation. 

  Personal Data processed: Trackers; Usage Data. 

  Place of processing: United States – Privacy Policy – Opt Out. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  X Post button and social widgets (X Corp.) 

  The X Post button and social widgets are services allowing interaction with the X social network provided by X Corp. 

  Personal Data processed: Trackers; Usage Data. 

  Place of processing: United States – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  YouTube button and social widgets (Google Ireland Limited) 

  The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Ireland Limited. 

  Personal Data processed: Usage Data. 

  Place of processing: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  Facebook Like button and social widgets (Meta Platforms Ireland Limited) 
  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms Ireland Limited. 

  Personal Data processed: Trackers; Usage Data. 

  Place of processing: Ireland – Privacy Policy – Opt out. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  This processing constitutes: 

• • a Sale in the United States 

• • a Sharing in California 

• • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana 

 

• 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. 

  Hostinger (Hostinger UK Limited) 

  Hostinger is a hosting service provided by Hostinger UK Limited. 

  Personal Data processed: Data communicated while using the service. 

  Place of processing: United Kingdom – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  Google Play Store (Google Ireland Limited) 

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

  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: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  This processing constitutes: 

• • a Sale in the United States 

• • a Sharing in California 

• • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana 

• App Store Connect (Apple Inc.)

  This Application is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc. 

  App Store Connect enables the Owner to manage this Application on Apple’s App Store. Depending on the configuration, App Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure the performance of this Application. App Store Connect only collects such data from Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device settings here. 

  Personal Data processed: diagnostics; search history; Trackers; Usage Data. 

  Place of processing: United States – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. 

  This processing constitutes: 

• • a Sale in the United States 

• • a Sharing in California 

• • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana 

 

• 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. 

  Sign in with Apple (Apple Inc.) 

  Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account – therefore shielding their actual email address from the Owner. 

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

  Place of processing: United States – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers. 

  Direct registration and profiling (this Application) 

  By registering or authenticating directly through this Application, Users allow this Application to identify them and give them access to dedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profiling purposes; to find out more, Users can contact the Owner using the contact details provided in this document. 

  Personal Data processed: various types of Data. 

  Category of Personal Information collected according to the CCPA: identifiers. 

  Firebase Authentication (Google LLC) 

  Firebase Authentication is a registration and authentication service provided by Google LLC. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform. 

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

  Place of processing: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers. 

  This processing constitutes: 

• • a Sale in the United States 

• • a Sharing in California 

• • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana 

• Google OAuth (Google Ireland Limited)

  Google OAuth is a registration and authentication service provided by Google Ireland Limited 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: Ireland – Privacy Policy. 

  Category of Personal Information collected according to the CCPA: identifiers. 

  This processing constitutes: 

• • a Sale in the United States 

• • a Sharing in California 

• • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana 

 

Further information about the processing of Personal Data 

• Equal protection of User Data

  This Application shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies. 

   

The Service is not directed to children under the age of 13 

Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application. 

 

Cookie Policy 

This Application uses Trackers. To learn more, Users may consult the Cookie Policy. 

 

Further Information for Users 

 

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. 

• 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. 

 

Further information about retention time 

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 

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 fulfil 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 rights of Users based on the General Data Protection Regulation (GDPR) 

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

In particular, Users have the right to do the following, to the extent permitted by law: 

 

• 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. 

• 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 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 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. 

• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. 

Users are also entitled to learn about the legal basis for Data transfers abroad including 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. 

 

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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients. 

 

Transfer of Personal Data outside of the United Kingdom 

 

Data transfer abroad based on standard contractual clauses (UK) 

If this is the condition for Data transfer, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission. 

This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document. 

 

Further information for Users in Switzerland 

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

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

 

The rights of Users according to the Swiss Federal Act on Data Protection 

Users may exercise certain rights regarding their Data within the limits of law, including the following: 

• right of access to Personal Data; 

• right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited); 

• right to receive their Personal Data and have it transferred to another controller (data portability); 

• right to ask for incorrect Personal Data to be corrected. 

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. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law. 

 

Transfer of Personal Data outside of Switzerland 

 

Transfer of Data outside of Switzerland based on the Users’ consent 

If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland if Users consent to such transfer. When collecting Users’ consent, the Owner makes sure to provide all the information that Users need to make an educated decision and to understand the implications and consequences of providing or denying their consent.

Users may withdraw their consent at any time. 

 

Further information for Users in Brazil 

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). 
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the “Lei Geral de Proteção de Dados” (the “LGPD”), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy. 
This part of the document uses the term “personal information“ as it is defined in the LGPD. 

The grounds on which we process your personal information 

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows: 

• your consent to the relevant processing activities; 

• compliance with a legal or regulatory obligation that lies with us; 

• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments; 

• studies conducted by research entities, preferably carried out on anonymized personal information; 

• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract; 

• the exercising of our rights in judicial, administrative or arbitration procedures; 

• protection or physical safety of yourself or a third party; 

• the protection of health – in procedures carried out by health entities or professionals; 

• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and 

• credit protection. 

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

 

Categories of personal information processed 

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document. 

 

Why we process your personal information 

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

 

Your Brazilian privacy rights, how to file a request and our response to your requests 

 

Your Brazilian privacy rights 

You have the right to: 

• obtain confirmation of the existence of processing activities on your personal information; 

• access to your personal information; 

• have incomplete, inaccurate or outdated personal information rectified; 

• obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD; 

• obtain information on the possibility to provide or deny your consent and the consequences thereof; 

• obtain information about the third parties with whom we share your personal information; 

• obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded; 

• obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply; 

• revoke your consent at any time; 

• lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies; 

• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law; 

• request clear and adequate information regarding the criteria and procedures used for an automated decision; and 

• request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality. 

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights. 

 

How to file your request 

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative. 

 

How and when we will respond to your request 

We will strive to promptly respond to your requests. 
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so. 

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. 
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. 
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your 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. 

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side. 

 

Transfer of personal information outside of Brazil permitted by the law 

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases: 

• 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; 

• when the transfer is necessary to protect your life or physical security or those of a third party; 

• when the transfer is authorized by the ANPD; 

• when the transfer results from a commitment undertaken in an international cooperation agreement; 

• when the transfer is necessary for the execution of a public policy or legal attribution of public service; 

• 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. 

Additional information for Users in Brazil 

 

Transfer of personal information outside of Brazil based on your consent 

We can transfer your personal information outside of the Brazilian territory if you consent to such transfer. When we ask for your consent, we’ll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent. Such information will be given in clear and plain language and in such a way that you’ll be able to clearly distinguish these requests from other consent requests that we may possibly ask. You may withdraw your consent at any time. 

 

Further information for Users in the United States 

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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana. 

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

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

 

Notice at collection 

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information. 

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected. 

• Identifiers

  Personal Information collected or disclosed: email address, first name, last name, phone number, Usage Data, various types of Data as specified in the privacy policy of the service, Trackers, device information, purchase history, various types of Data 

  Sensitive Personal Information collected or disclosed ℹ️: payment info, password 

  Purposes: 

• • Registration and authentication 

• • Contacting the User 

• • Building and running this Application 

• • Hosting and backend infrastructure 

• • Handling payments 

• • Data transfer outside of the UK 

• • Further information about Personal Data 

• • Beta Testing 

• • Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Only anonymazied and aggregated

    Targeted Advertising: ℹ️:  Only anonymazied and aggregated

    Third-parties: Apple Inc., this Application, Google LLC, Google Ireland Limited 

    Service providers or contractors: this Application 

     

• Internet or other electronic network activity information

  Personal Information collected or disclosed: Usage Data, various types of Data as specified in the privacy policy of the service, Trackers, first name, last name, email address, phone number, device information, purchase history, Data communicated while using the service, Social media accounts permission, Camera permission, Photo Library permission, IP address, diagnostics, search history 

  Sensitive Personal Information collected or disclosed ℹ️: payment info, Health Data read permission 

  Purposes: 

• • Hosting and backend infrastructure 

• • Displaying content from external platforms 

• • Handling payments 

• • Handling activities related to productivity 

• • Interaction with external social networks and platforms 

• • Device permissions for Personal Data access 

• • Collection of privacy-related preferences 

• • Platform services and hosting 

• • Beta Testing 

• • Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Only anonymazied and aggregated

    Targeted Advertising: ℹ️:  Only anonymazied and aggregated 

    Third-parties: Google LLC, Meta Platforms, Inc., Apple Inc., Google Ireland Limited, LinkedIn Corporation, X Corp., iubenda srl, Hostinger UK Limited, Meta Platforms Ireland Limited 

    Service providers or contractors: this Application 

     

• Commercial information

  Personal Information collected or disclosed: Trackers, first name, last name, email address, phone number, device information, purchase history 

  Sensitive Personal Information collected or disclosed ℹ️: payment info 

  Purposes: 

• • Handling payments 

• • Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Only anonymazied and aggregated

    Targeted Advertising: ℹ️:  Only anonymazied and aggregated 

    Third-parties: Apple Inc., Google LLC 

     

• Biometric information

  Personal Information collected or disclosed: Social media accounts permission, Camera permission, Photo Library permission 

  Sensitive Personal Information collected or disclosed ℹ️: Health Data read permission 

  Purposes: 

• • Device permissions for Personal Data access 

• • Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Only anonymazied and aggregated

    Targeted Advertising: ℹ️:  Only anonymazied and aggregated 

    Service providers or contractors: this Application 

     

• Employment related information

  Personal Information collected or disclosed: email address, first name, last name, phone number, profession, country, ZIP/Postal code, date of birth, city 

  Purposes: 

• • Contacting the User 

• • Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Only anonymazied and aggregated

    Targeted Advertising: ℹ️:  Only anonymazied and aggregated 

    This category of Personal Information was collected in the preceding 12 months but is collected no longer 

     

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy. 

To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy. 

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy. 

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent. 

 

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. 

 

Your privacy rights under US state laws 

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

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information; 

• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you; 

• the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information; 

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

• the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights. 

• the right to non-discrimination. 

Additional rights for Users residing in California 

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

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising; 

• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service. 

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana 

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have 

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; 

• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. 

Additional rights for users residing in Utah 

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

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

• The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. 

How to exercise your privacy rights under US state laws 

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 must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for 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 are an adult, you can make a request on behalf of a child under your parental authority. 

 

How to exercise your rights to opt out 

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

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner. 

 

How and when we are expected to handle your request 

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need. 

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint). 

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. 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 them. 

 

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. 

 

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. 

 

Definitions and legal references 

 

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

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. 

Sensitive Personal Information 

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law. 

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 Processor) 

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. 

Sale 

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information. 

Sharing 

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 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 California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information. 

Targeted advertising 

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law. 

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. 

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

Latest update: September 11, 2024 

iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided. 

 

This document has been created with the iubenda Privacy and Cookie Policy Generator (https://www.iubenda.com/en/privacy-and-cookie-policy-generator). See also the Terms and Conditions Generator (https://www.iubenda.com/en/terms-and-conditions-generator). iubenda (https://www.iubenda.com/en/) hosts this content and only collects the Personal Data strictly necessary (https://www.iubenda.com/privacy-policy/65675001) for it to be provided.