Privacy Policy of vela.business
This Application collects some Personal Data from its Users.

Owner and Data Controller
Vela Technologies, LLC
201 W. 5th Street
11th Floor
Austin, TX 78701
Owner contact email: info@vela.business

Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data;
Trackers; city; ZIP/Postal code; state; province; country; county; latitude (of city); longitude (of city); metro area;
geography/region; IP address; device information; app information; device logs; operating systems; browser information;
language; launches; number of sessions; session duration; scroll-to-page interactions; mouse movements; scroll position;
keypress events; motion sensor events; touch events; video views; clicks; browsing history; search history; session statistics; page
views; interaction events; page events; custom events; Application opens; email address; first name; last name; company name;
job title; phone number; physical address.
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: Displaying content from external platforms, Spam and bots protection, Interaction with live
chat platforms, User database management, Analytics and Traffic optimization and distribution.
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:

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

Matomo Cloud (InnoCraft)

Matomo Cloud is an analytics service provided by InnoCraft.
Personal Data processed: interaction events.
Place of processing: New Zealand – 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

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.

Font Awesome (Fonticons, Inc. )

Font Awesome is a typeface visualization service provided by Fonticons, Inc. 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.
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

Google Fonts

Google Fonts is a typeface visualization service provided by Google LLC or by Google 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.
This processing constitutes:

a Sale in the United States

Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in
order to contact and be contacted by this Application‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do
not actively use the service. Moreover, live chat conversations may be logged.

HubSpot Chat (HubSpot, Inc.)

HubSpot Chat is a service for interacting with the HubSpot live chat platform provided by HubSpot, Inc.
Personal Data processed: company name; country; email address; first name; job title; last name.
Place of processing: United States – Privacy Policy; Germany – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:

a Sale in the United States
a Sharing in California

Spam and bots protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of
filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots
activities.

Cloudflare Bot Management (Cloudflare, Inc.)

Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.
Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country;
county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events;
language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of
sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history;
session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity
information; geolocation data; inferences drawn from other personal information.
This processing constitutes:

a Sharing in California

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

Cloudflare (Cloudflare, Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this

Application and the User's browser, while also allowing analytical data from this Application to be collected.
Personal Data processed: 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.

User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other
information that the User provides to this Application, as well as to track User activities through analytics features. This Personal
Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to
build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions
performed on this Application.

HubSpot CRM (HubSpot, Inc.)

HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: company name; country; email address; first name; last name; phone number; physical address; various
types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Germany – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:

a Sale in the United States

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

Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), 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,
and further information about Personal Data can be found in the section titled “Detailed information on the processing of
Personal Data” within this document.

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.

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.

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.

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.

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.

Internet or other electronic network activity information
Personal Information collected or disclosed: Usage data, Trackers, City, Zip/postal code, State, Province, Country,
County, Latitude (of city), Longitude (of city), Metro area, Geography/region, Ip address, Device information, App
information, Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session
duration, Scroll-to-page interactions, Mouse movements, Scroll position, Keypress events, Motion sensor events, Touch
events, Video views, Clicks, Browsing history, Search history, Session statistics, Page views, Interaction events, Page
events, Custom events, Application opens
Purposes:

Displaying content from external platforms
Spam and bots protection
Analytics

Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ: Yes
Targeted Advertising: ℹ: Yes
Third-parties: Fonticons, Inc. , Cloudflare, Inc., Google LLC, InnoCraft

Identifiers
Personal Information collected or disclosed: City, Zip/postal code, State, Province, Country, County, Latitude (of city),
Longitude (of city), Metro area, Geography/region, Usage data, Trackers, Ip address, Device information, App information,
Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session duration, Scroll-
to-page interactions, Mouse movements, Scroll position, Keypress events, Motion sensor events, Touch events, Video
views, Clicks, Browsing history, Search history, Session statistics, Page views, Interaction events, Page events, Custom
events, Application opens, Email address, First name, Last name, Company name, Job title, Various types of data as
specified in the privacy policy of the service, Phone number, Physical address
Purposes:

Spam and bots protection
Interaction with live chat platforms
User database management
Traffic optimization and distribution

Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ: Yes
Targeted Advertising: ℹ: Yes
Third-parties: Cloudflare, Inc., HubSpot, Inc.

Geolocation data
Personal Information collected or disclosed: City, Zip/postal code, State, Province, Country, County, Latitude (of city),
Longitude (of city), Metro area, Geography/region, Usage data, Trackers, Ip address, Device information, App information,

Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session duration, Scroll-
to-page interactions, Mouse movements, Scroll position, Keypress events, Motion sensor events, Touch events, Video
views, Clicks, Browsing history, Search history, Session statistics, Page views, Interaction events, Page events, Custom
events, Application opens
Purposes:

Spam and bots protection
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ: Yes
Targeted Advertising: ℹ: Yes
Third-parties: Cloudflare, Inc.

Inferences drawn from other personal information
Personal Information collected or disclosed: City, Zip/postal code, State, Province, Country, County, Latitude (of city),
Longitude (of city), Metro area, Geography/region, Usage data, Trackers, Ip address, Device information, App information,
Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session duration, Scroll-
to-page interactions, Mouse movements, Scroll position, Keypress events, Motion sensor events, Touch events, Video
views, Clicks, Browsing history, Search history, Session statistics, Page views, Interaction events, Page events, Custom
events, Application opens
Purposes:

Spam and bots protection
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ: Yes
Targeted Advertising: ℹ: Yes
Third-parties: Cloudflare, Inc.

Commercial information
Personal Information collected or disclosed: Country, Email address, First name, Last name, Company name, Job title,
Various types of data as specified in the privacy policy of the service, Phone number, Physical address
Purposes:

Interaction with live chat platforms
User database management

Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ: Yes
Targeted Advertising: ℹ: Yes
Third-parties: HubSpot, Inc.

ℹ 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 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.

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.

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: May 27, 2024