Privacy Policy of www.geniopay.com

This Website collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

GenioPay Ltd.
Kemp House, 160 City Road,
London, United Kingdom, EC1V 2NX

Owner contact email: dpo@geniopay.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data; first name; last name; phone number; company name; country; email address; User ID; Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; Application opens; operating systems; ZIP/Postal code; date of birth; city; address; username; various types of Data; password; VAT Number; Tax ID; county; Social Security number (SSN); picture; profile picture; website; budget; number of employees; billing address; field of activity; house number; language; Data communicated while using the service; geographic position; payment data.

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 Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 Website or by the owners of third-party services used by this Website 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, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.

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 Website (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.

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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“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;
• 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.

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 are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire 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 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 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 erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

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, Access to third-party accounts, Contacting the User, Analytics, Content commenting, User database management, Traffic optimization and distribution, Tag Management, SPAM protection, Social features, Remarketing and behavioral targeting, Registration and authentication provided directly by this Website, Registration and authentication, Platform services and hosting, Managing support and contact requests, Managing landing and invitation pages, Managing data collection and online surveys, Managing contacts and sending messages, Location-based interactions, Interaction with online survey platforms, Interaction with live chat platforms, Infrastructure monitoring, Hosting and backend infrastructure, Heat mapping and session recording, Handling payments, Content performance and features testing (A/B testing) and Advertising.

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”.

Facebook permissions asked by this Website

This Website may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Contact email

Access the User's contact email address.

Email

Provides access to the User's primary email address.

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 Website 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.
  Facebook account access (Facebook, Inc.)
  This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook, Inc.Permissions asked: Contact email; Email.Place of processing: United States – Privacy Policy. Privacy Shield participant.
• Advertising
  This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
  In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
  Chartboost (Chartboost, Inc.)
  Chartboost is an advertising service provided by Chartboost Inc.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy.
• 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.
  Google Analytics (Google Ireland Limited)
  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.Personal Data processed: Cookies; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
  Alexa Metrics (Alexa Internet, Inc.)
  Alexa Metrics is an analytics service provided by Alexa Internet, Inc.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy – Opt Out.
  Analytics collected directly (this Website)
  This Website uses an internal analytics system that does not involve third parties.Personal Data processed: Cookies; Usage Data.Google Analytics Advertising Reporting Features (Google LLC)
  Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
  Google Analytics for Firebase (Google LLC)
  Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.
  In order to understand Google's use of Data, consultGoogle's partner policy.
  Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
  This Website uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
  Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.Personal Data processed: Application opens; Cookies; device information; geography/region; operating systems; Usage Data.Place of processing: United States – Privacy Policy. Privacy Shield participant.
  Twitter Ads conversion tracking (Twitter, Inc.)
  Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Website.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy. Privacy Shield participant.
  Chartbeat (Chartbeat)
  Chartbeat is an analytics service provided by Chartbeat Inc.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy.
• Contacting the User
  Contact form (this Website)
  By filling in the contact form with their Data, the User authorizes this Website 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: company name; country; email address; first name; last name; phone number; User ID.Phone contact (this Website)
  Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.Personal Data processed: phone number.Mailing list or newsletter (this Website)
  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.Personal Data processed: address; city; Cookies; country; date of birth; email address; first name; last name; phone number; Usage Data; ZIP/Postal code.
• Content commenting
  Content commenting services allow Users to make and publish their comments on the contents of this Website.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
  Comment system managed directly (this Website)
  This Website has its own internal content comment system.Personal Data processed: username.Disqus (Disqus)
  Disqus is a content commenting service provided by Big Heads Labs Inc.Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy – Opt out.
  Facebook Comments (Facebook, Inc.)
  Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy. Privacy Shield participant.
• Content performance and features testing (A/B testing)
  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.
  Google Optimize 360
  Google Optimize 360 is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, ("Google").
  This service allows the Owner to target groups of Users on the base of their past use of this Website. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.
  Google may use Personal Data to contextualize and personalize the ads of its own advertising network.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
• Displaying content from external platforms
  This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
  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.
  Google Fonts
  Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
  YouTube video widget
  YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
• Handling payments
  Unless otherwise specified, this Website 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 Website 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.
  Payment by bank transfer (this Website)
  In the event that the chosen payment method is a direct bank transfer to the current account indicated by this Website, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.Personal Data processed: address; company name; first name; last name; payment data.
• Heat mapping and session recording
  Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
  Some of these services may record sessions and make them available for later visual playback.
  Crazy Egg (Crazyegg)
  Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy.
  Hotjar Heat Maps & Recordings (Hotjar Ltd.)
  Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
  Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.Place of processing: Malta – Privacy Policy – Opt Out.
• Hosting and backend infrastructure
  This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.
  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.
  iubenda Consent Solution (iubenda srl)
  iubenda Consent Solution is a service that facilitates the collection and management of proofs of consent provided by iubenda srl.Personal Data processed: Data communicated while using the service.Place of processing: Italy – Privacy Policy.
  Microsoft Azure (Microsoft Corporation)
  Microsoft Azure is a hosting service provided by Microsoft Corporation.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy. Privacy Shield participant.
• Infrastructure monitoring
  This type of service allows this Website to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.
  Web Performance (Web Performance, Inc.)
  Web Performance is a monitoring service provided by Web Performance, Inc.Web Performance is a monitoring service provided by Web Performance, Inc.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy.
• 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 Website, in order to contact and be contacted by this Website‘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.
  Facebook Messenger Customer Chat
  The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from,Personal Data processed: Cookies; Data communicated while using the service; Usage Data.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
  LiveChat Widget (LiveChat, Inc.)
  The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.Personal Data processed: Cookies; Data communicated while using the service; Usage Data.Place of processing: United States – Privacy Policy.
• Interaction with online survey platforms
  This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Website.
  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.
  Hotjar Poll & Survey widgets (Hotjar Ltd.)
  The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.
  Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.Personal Data processed: Cookies; Usage Data; various types of Data.Place of processing: Malta – Privacy Policy – Opt Out.
• Location-based interactions
  Geolocation (this Website)
  This Website may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website.Personal Data processed: geographic position.Non-continuous geolocation (this Website)
  This Website may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.Personal Data processed: geographic position.
• Managing contacts and sending messages
  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
  Sendgrid (Sendgrid)
  Sendgrid is an email address management and message sending service provided by Sendgrid Inc.Personal Data processed: Cookies; email address; first name; last name; Usage Data.Place of processing: United States – Privacy Policy.
• Managing data collection and online surveys
  This type of service allows this Website to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
  The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
  These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
  Facebook lead ads
  Facebook lead ads is an advertising and data collection service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information.
  Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided.
  Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy.Personal Data processed: Data communicated while using the service; email address; first name; last name.Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out. Privacy Shield participant.
• Managing landing and invitation pages
  This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
  Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
  Instapage (Instapage, Inc.)
  Instapage is a landing page management service provided by Instapage, Inc., that allows this Website to collect the email addresses of Users interested in its service.
  Instapage allows the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the created landing pages.Personal Data processed: Cookies; email address; Usage Data.Place of processing: United States – Privacy Policy.
  Leadpages (Avenue 81, Inc.)
  Leadpages is a landing page management service provided by Avenue 81, Inc., that allows this Website to collect the email addresses of Users interested in its service.
  Leadpages allows the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the created landing pages.Personal Data processed: email address; Usage Data; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.
• Managing support and contact requests
  This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
  The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
  Salesforce Service Cloud (Salesforce.com, inc.)
  Salesforce Service Cloud is a support and contact request management service provided by salesforce.com, inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy. Privacy Shield participant.
• Platform services and hosting
  These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website 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.
  Apple App Store (Apple Inc.)
  This Website is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
  By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of this Website. 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: United States – Privacy Policy. Privacy Shield participant.
  Google Play Store
  This Website is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from.
  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: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
• Registration and authentication
  By registering or authenticating, Users allow this Website 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 Website 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.
  Facebook Authentication
  Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, and is connected to the Facebook social network.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
  Google OAuth
  Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, 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: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
• Registration and authentication provided directly by this Website
  By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
  Direct registration (this Website)
  The User registers by filling out the registration form and providing the Personal Data directly to this Website.Personal Data processed: address; billing address; budget; city; company name; Cookies; country; county; date of birth; email address; field of activity; first name; house number; language; last name; number of employees; password; phone number; picture; profile picture; Social Security number (SSN); Tax ID; Usage Data; User ID; username; various types of Data; VAT Number; website; ZIP/Postal code.
• Remarketing and behavioral targeting
  This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
  Twitter Remarketing (Twitter, Inc.)
  Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
  Twitter Tailored Audiences (Twitter, Inc.)
  Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network.
  Users can opt out from interest-based ads by going to: Personalization and Data.Personal Data processed: Cookies; email address.Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
  Perfect Audience (NowSpots, Inc.)
  Perfect Audience is an advertising service provided by NowSpots, Inc.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy – Opt Out.
  Remarketing with Google Analytics
  Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
  AdRoll (AdRoll, Inc.)
  AdRoll is an advertising service provided by AdRoll, Inc.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy – Opt Out.
  Facebook Remarketing
  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that connects the activity of this Website with the Facebook advertising network.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
  Facebook Custom Audience
  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that connects the activity of this Website with the Facebook advertising network.
  Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.Personal Data processed: Cookies; email address.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
  Google Ads Remarketing
  Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
  Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
• Social features
  Inviting and suggesting friends (this Website)
  This Website may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.Personal Data processed: various types of Data.
• SPAM protection
  This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
  Google reCAPTCHA
  Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
• Tag Management
  This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
  Google Tag Manager
  Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from.Personal Data processed: Usage Data.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
• Traffic optimization and distribution
  This type of service allows this Website 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 Website 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 Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.
• 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 Website, 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 Website.
  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 Website.
  HubSpot CRM (HubSpot, Inc.)
  HubSpot CRM is a User database management service provided by HubSpot, Inc.Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy. Privacy Shield participant.
  HubSpot Lead Management (HubSpot, Inc.)
  HubSpot Lead Management is a User database management service provided by HubSpot, Inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy. Privacy Shield participant.
  Salesforce Sales Cloud (Salesforce.com, inc.)
  Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy. Privacy Shield participant.
  Salesforce Marketing Cloud (Salesforce.com, inc.)
  Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

• Analysis and predictions based on the User’s Data (“profiling”)
  The Owner may use the Personal and Usage Data collected through this Website to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
  User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
  The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
• Personal Data collected through sources other than the User
  The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
  Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
• Push notifications based on the User's geographic location
  This Website may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
  Users must be aware that disabling push notifications may negatively affect the utility of this Website.
• Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD
  We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
  The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:
  
  • the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
  • the nature of the personal information subject to the transfer;
  • the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
  • the adoption of suitable security measures;
  • the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
  • any other pertinent circumstance related to the relevant transfer.

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 ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, 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, under certain circumstances, 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. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of 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 that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. 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. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Website uses Trackers. To learn more, the User may consult the Cookie Policy.

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 Website 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 Website 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 Website and any third-party services may collect files that record interaction with this Website (System logs) 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.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “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 Website 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)

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.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, 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 Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

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 Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

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.

Cookies

Small sets of data stored in the User's device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

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

Latest update: April 5, 2024