Privacy Policy

Mode and place of processing of Data

Method of processing

The Owner will take appropriate security measures to prevent unauthorized access, disclosure, alteration or unauthorized destruction of the Data.
The processing of Data 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 accessed by certain types of persons involved with the operation of this Service (this site) (administration, sales, marketing, legal administration of the system) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, when necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis for processing

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

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

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

Place

The data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users also have the right to learn about the legal basis for Data transfers to countries outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to protect their Data.

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

Retention time

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

Therefore:

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

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

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

The purposes of the 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: Registration and authentication and Hosting and backend infrastructure.

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

Detailed information on the processing of Personal Data

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

• Hosting and backend infrastructure

  These types of services have the purpose of hosting Data and files that enable this site to run and be distributed, as well as to provide infrastructure to run features or parts of this service (this site).

  Some services listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

  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 service's privacy policy.

  Place of processing: United States – Privacy Policy .

• Registration and authentication

  By registering or authenticating, Users allow this service (this site) to identify them and give them access to dedicated services.
  Depending on what is described below, registration and authentication services may be provided by third parties. In this case, this site may 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 consult the description of each service.

  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 other identity providers and save the information on its platform.

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

  Place of processing: United States – Privacy Policy .

The rights of Users

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

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

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and to request that it be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data for any purpose other than storing it.
• Have their Personal Data erased or otherwise removed. Users have the right, under certain circumstances, to obtain the deletion of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision applies provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract of which the User is a party or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

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

Users must know, however, that if their Personal Data is processed for direct marketing purposes they can object to such processing at any time without providing any justification. Users can refer to the respective sections of this document.

How to exercise these rights

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

Additional information about the collection and processing of Data

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 Service (this site) or the related Services.
The User declares to be aware that the Owner may be required to disclose Personal Data upon request of government authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this site may provide the User with additional and contextual information about specific services or the collection and processing of Personal Data upon request.

System logs and maintenance

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

Information not contained in this policy

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

How "Do Not Track" requests are handled

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

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time, by notifying its Users on this page and possibly within this Service (this site) and/or – as technically and legally feasible – sending a notice to Users through any available contact information of the Owner. It is highly recommended to check this page regularly, referring to the date of the last modification listed at the bottom.

If the changes affect processing activities carried out on the basis of the User's consent, the Owner shall collect new consent from the User, where required.

Information for Users residing in Brazil

This part of the document integrates and complements the information contained in the rest of this privacy policy and is provided by the entity that operates this site and, as the case may be, its controllers, subsidiaries and affiliates (for the purposes of this section, hereinafter collectively referred to through the pronouns "we", "us", "our" and "ours").
The provisions contained in this section shall apply to all Users who are residents in Brazil, according to the "Lei geral de Proteção de Dados" (Users will hereinafter be referred to through the pronouns "you" and "your"). For such Users, these provisions supersede all other possibly divergent or conflicting provisions contained in this privacy policy.
This part of the document uses the term "personal information", as defined in the Lei Geral de Proteção de Dados ( LGPD ).

What we base our processing of your personal information on

We may process your personal information only if we have a legal basis for such processing. The legal bases are as follows:

• your consent to the respective processing activities;
• compliance with a legal or regulatory obligation imposed on us;
• the fulfillment of policies made public 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 execution of a contract and its preliminary procedures, in cases where you are a party to the contract;
• the exercise of our rights in judicial, administrative or arbitration proceedings;
• protection or physical safety of you 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 freedoms do not prevail over such interests; and
• credit protection.

For more information about the legal bases, you can contact us at any time through the contact details provided in this document.

Categories of personal information processed

To find out which categories of your personal information are processed, you may read the section entitled "Detailed information on the processing of Personal Data" in this document.

Why we process your personal information

To find out why we process your personal information, you may read the sections entitled "Detailed information on the processing of Personal Data" and "The purposes of the processing" in this document.

Your privacy rights as a Brazilian, how to submit a request and our responses to your requests

Your privacy rights as a Brazilian

You have the right to:

• obtain confirmation about the existence of processing activities of your personal information;
• access your personal information;
• have your incomplete, inaccurate or outdated personal information corrected;
• obtain the anonymization, blocking or elimination of your personal information that is unnecessary or processed in non-compliance with the LGPD;
• obtain information about the possibility of providing or refusing your consent and the respective consequences;
• 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 anonymized information) to another product or service provider, provided that our commercial and industrial secrets remain protected;
• obtain the deletion of your personal information processed based on your consent, unless one or more exceptions provided in art. 16 of the LGPD apply;
• withdraw your consent at any time;
• file a complaint regarding your personal information to the ANPD (Autoridade Nacional de Proteção de Dados) or consumer protection agencies;
• object to a processing activity in cases where the processing is not carried out in accordance with the provisions of the law;
• obtain clear and adequate information about the criteria and procedures used for an automated decision; and
• request the review of decisions taken exclusively based on the automated processing of your personal information that affect your interests. This includes decisions to define your personal, professional, consumer and credit profile or aspects of your personality.

You will never be discriminated against or suffer any kind of prejudice if you exercise your rights.

How to submit your request

You may submit your express request to exercise your rights free of charge, at any time, using the contact details provided in this document or through your legal representative.

How and when we will respond to your request

We will make every effort to respond immediately to your requests.
In any case, if it is impossible, we will make sure to communicate to you the factual or legal reasons that prevent us from immediately complying, or from complying in any other way, with your requests. In cases where we are not processing your personal information, we will indicate the physical or legal person to whom you should direct your requests, if we are in a position to do so.

If you submit an access or confirmation of processing request for personal information, please specify whether you want your personal information to be delivered in electronic or printed format.
You must also inform us whether you want us to respond to your request immediately, in which case we will respond in a simplified manner, or if you need a complete response.
In the latter case, we will respond within 15 days from the date of your request, providing all information about the origin of your personal information, confirmation of the existence or not of records, any criteria used for the processing and the purposes of the processing, while protecting our commercial and industrial secrets.

If you request a correction, deletion, anonymization or blocking of personal information , we will immediately communicate your request to other parties with whom we share your personal information, in order to allow these third parties to also comply with your request – except in cases where such communication proves impossible or involves a disproportionate effort on our part.

Transfer of personal information outside Brazil permitted by law

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

• when the transfer is necessary for international judicial cooperation between public agencies of intelligence, investigation and Public Ministry, according to the legal means provided in international law;
• when the transfer is necessary to protect your life or physical safety or that of third parties;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment assumed in an international cooperation agreement;
• when the transfer is necessary for the fulfillment of a public policy or statutory service attribution;
• when the transfer is necessary for the fulfillment of a legal or regulatory obligation, the execution of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration proceedings.