Privacy Policy of Sniffer Social

Full policy

Owner and Data Controller

Sniffer Social Limited
71-75 Shelton Street Covent Garden
United Kingdom
LONDON
WC2H 9JQ
GREAT BRITAIN

Owner contact email: info@sniffersocial.uk

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: country; app information; Usage Data; Trackers; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; company name; state; email address; Calendar permission; Contacts permission; Camera permission; Precise location permission (continuous); Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Microphone permission; Phone permission; Sensors permission; SMS permission; Storage permission; Reminders permission; HomeKit permission; Motion sensors permission; Bluetooth sharing permission; Social media accounts permission; Microphone permission, without recording; NFC Reader permission ; Biometric Data access permission; Media Library permission (Music); Photo Library permission; Health Data read permission; Health Data update permission ; Siri permission; Apple's speech recognition servers permission; Google Assistant permission; Google Home permission; Call permission; Camera permission, without saving or recording; Write-only Photo Library permission; operating systems; language; device information; number of Users; city; session statistics; latitude (of city); longitude (of city); browser information; Data communicated while using the service; date of birth; device logs; first name; last name; phone number; username; gender; profession; county; ZIP/Postal code; physical address; website; various types of Data; password; geographic position; profile picture; screenshots; payment info; purchase history; billing address; shipping address; session duration; scroll-to-page interactions; time zone; interaction events; diagnostic events; page events; custom events; layout details; positional information; User ID; crash data; diagnostics; advertising data; product interaction; search history; Universally unique identifier (UUID); unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

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, if available.

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

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 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 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: Beta Testing, SPAM protection, Analytics, Contacting the User, Device permissions for Personal Data access, Advertising, Access to third-party accounts, Backup saving and management, Content performance and features testing (A/B testing), Data transfer outside of the UK, Data transfer outside the EU, Handling activities related to productivity, Handling payments, Heat mapping and session recording, Infrastructure monitoring, Location-based interactions and Platform services and hosting.

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 Application

This Application 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 Application 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.

About Me

Provides access to the 'About Me' section of the profile.

Access Friend Lists

Provides access to any friend lists the User created.

Age range

Provides access to the User's age range.

App Notifications

Send notifications.

Birthday

Provides access to the birthday.

Contact email

Access the User's contact email address.

Gender

Provides access to the User's gender.

Photos

Provides access to the photos the User has uploaded, and photos the User has been tagged in.

User location

Allows reading the city name as listed in the location field of a User’s Facebook profile.

Device permissions for Personal Data access

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

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

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

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

Apple's speech recognition servers permission

Used for sending the User's Data to Apple's speech recognition servers.

Approximate location permission (continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.

Biometric Data access permission

Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.

Bluetooth sharing permission

Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.

Calendar permission

Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.

Call permission

Used for accessing a host of typical features associated with telephony.

Camera permission

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

Camera permission, without saving or recording

Used for accessing the camera or capturing images and video from the device.
This Application does not save or record the camera output.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

Google Assistant permission

Used for sending the User's Data to Google Assistant (an artificial intelligence-powered virtual assistant).

Google Home permission

Used for accessing the Google Home and Chromecast devices and enabling this Application to interact with physical accessories in the User's surrounding environment.

Health Data read permission

Allows reading the User’s health Data.

Health Data update permission

Allows the updating of the User’s health Data.

HomeKit permission

Used for accessing the HomeKit framework and enabling this app to interact with physical accessories in the User's surrounding environment.

Media Library permission (Music)

Allows accessing the User's Media Library audio Data.

Microphone permission

Allows accessing and recording microphone audio from the User's device.

Microphone permission, without recording

Allows accessing and recording microphone audio from the User's device. The recording feature is not used on this Application.

Motion sensors permission

Used for accessing the User's device motion sensors to measure the User's activity such as step counts, stairs climbed, and movement type (walking, cycling, etc.).

NFC Reader permission

Allows this Application to read contact-less tags.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

Photo Library permission

Allows access to the User's Photo Library.

Precise location permission (continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.

Reminders permission

Used for accessing the Reminders app on the User's device, including the reading, adding and removing of entries.

Sensors permission

Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.

Siri permission

Used for sending the User's Data to Siri (an artificial intelligence-powered virtual assistant).

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Social media accounts permission

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

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Write-only Photo Library permission

Allows write-only access to the User's photo library.

Detailed information on the processing of Personal Data

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

• Access to third-party accounts

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

  Facebook account access (Meta Platforms, Inc.)

  This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: About Me; Access Friend Lists; Age range; App Notifications; Birthday; Contact email; Gender; Photos; User location.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; california Consumer Records Statute information; biometric information; internet information; sensorial information.

• 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 Application, 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 Application. For more information, please check the privacy policies of the relevant services.
  Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

  AdUnity (AdUnity Ltd)

  AdUnity is an advertising service provided by AdUnity Ltd.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United Kingdom – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 LLC)

  Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, 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: Trackers; Usage Data.

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

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  AWStats (this Application)

  AWStats is an open-source web analytics software used by this Application to analyze Data directly without the help of third parties. AWStats allows analyzing these log files in order to examine web traffic patterns.

  Personal Data processed: country; operating systems; Usage Data.

  Category of personal information collected according to CCPA: identifiers; internet information.

  Cloudflare Web Analytics (Cloudflare Inc.)

  Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare Inc. that gives the Owner insight into the use of this Application by Users without needing to identify them. Further information may be found here and within the service's privacy policy.

  Personal Data processed: device information; language; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information; inferred information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Analytics 4 (Google LLC)

  Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, 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.
  In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

  Personal Data processed: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage Data.

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

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Backup saving and management

  This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.

  OVH Storage and backup

  OVH Storage and backup is a service to save and manage backups provided by OVH US LLC, OVH Hosting Ltd., OVH Srl, OVH HISPANO SL, OVH S.A.S., OVH GmbH, OVH BV, OVH HEBERGEMENT INC, OVH SINGAPORE PTE LTD or by OVH AUSTRALIA PTY LTD, depending on how the Owner manages the Data processing.

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

  Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; Italy – Privacy Policy; Spain – Privacy Policy; France – Privacy Policy; Germany – Privacy Policy; Netherlands – Privacy Policy; Canada – Privacy Policy; Singapore – Privacy Policy; Australia – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Beta Testing

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

  TestFlight (Apple Inc.)

  TestFlight is a beta testing service provided by Apple Inc.

  Personal Data processed: app information; country; 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 CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  HockeyApp (Microsoft Corporation)

  HockeyApp is a beta testing service provided by Microsoft Corporation.

  Personal Data processed: app information; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; last name; phone number; Trackers; Usage Data; username; 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 CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Play Beta Testing

  Google Play Beta Testing is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service.

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

  Category of personal information collected according to CCPA: identifiers; biometric information; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Contacting the User

  Contact form (this Application)

  By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: company name; email address; state; Trackers.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

  Mailing list or newsletter (this Application)

  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 Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

  Personal Data processed: city; company name; country; county; date of birth; email address; first name; gender; last name; phone number; physical address; profession; state; Trackers; Usage Data; website; ZIP/Postal code.

  Category of personal information collected according to CCPA: identifiers; commercial information; biometric information; internet information; employment related information.

• 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 Application.

  Firebase Remote Config

  Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  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.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Data transfer outside of the UK

  The Owner is allowed to transfer Personal Data collected within the UK to third countries only subject to specific legal requirements (so-called "restricted transfers"). Restricted transfers may take place according to the conditions specified below.

  Users can enquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on consent (UK) (this Application)

  If this is the legal basis, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.

  In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

  Data transfer abroad based on standard contractual clauses (UK) (this Application)

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

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

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

  Data transfers according to a UK adequacy regulation (this Application)

  If this is the legal basis, the transfer of Personal Data from the UK to third countries may take place according to a so called “adequacy regulation” of the UK Government.

  The UK Government adopts adequacy regulations for specific countries or territories whenever such countries or territories guarantee Personal Data protection standards comparable to those set forth by UK data protection legislation. Users can find an updated list of all adequacy regulations on the website of the Information Commissioner’s Office (ICO).

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

  Other legal basis for Data transfer abroad (UK) (this Application)

  If no other legal basis applies, Personal Data shall be transferred from the UK to third countries only if at least one of the following conditions is met:

  • the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
  • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
  • the transfer is necessary for important reasons of public interest;
  • the transfer is necessary for establishment, exercise or defence of legal claims;
  • the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
  • the data transferred is sourced from a public register created under UK law;
  • subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.

  In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on consent (this Application)

  If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
  In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

  Data transfer abroad based on standard contractual clauses (this Application)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
  This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

  Other legal basis for Data transfer abroad (this Application)

  If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:

  • the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
  • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
  • the transfer is necessary for important reasons of public interest;
  • the transfer is necessary for establishment, exercise or defence of legal claims;
  • the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
  • the data transferred is sourced from a public register created under the law of the country that the data originates from;
  • subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.

  In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

  Data transfer to countries that guarantee European standards (this Application)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
  The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

• Device permissions for Personal Data access

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

  Device permissions for Personal Data access (this Application)

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

  Personal Data processed: Apple's speech recognition servers permission; Approximate location permission (continuous); Approximate location permission (non-continuous); Biometric Data access permission; Bluetooth sharing permission; Calendar permission; Call permission; Camera permission; Camera permission, without saving or recording; Contacts permission; Google Assistant permission; Google Home permission; Health Data read permission; Health Data update permission ; HomeKit permission; Media Library permission (Music); Microphone permission; Microphone permission, without recording; Motion sensors permission; NFC Reader permission ; Phone permission; Photo Library permission; Precise location permission (continuous); Precise location permission (non-continuous); Reminders permission; Sensors permission; Siri permission; SMS permission; Social media accounts permission; Storage permission; Write-only Photo Library permission.

  Category of personal information collected according to CCPA: biometric information; internet information; geolocation data; sensorial information.

• Handling activities related to productivity

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

  Gmail

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

  Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; email address; first name; gender; geographic position; last name; password; phone number; physical address; profession; profile picture; screenshots; Trackers; Usage Data; username.

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

  Category of personal information collected according to CCPA: identifiers; commercial information; biometric information; internet information; geolocation data; sensorial information; employment related information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Handling payments

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

  Apple Pay (Apple Inc.)

  Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

  Android Pay

  Android Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows Users to make payments using their mobile phones.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; Trackers; 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.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

  Google Pay

  Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; Trackers; 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.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

• Heat mapping and session recording

  Heat mapping services are used to display the areas of this Application 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.

  Microsoft Clarity (Microsoft Corporation)

  Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
  Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.

  Personal Data processed: clicks; country; custom events; device information; diagnostic events; interaction events; layout details; mouse movements; page events; positional information; scroll-to-page interactions; session duration; time zone; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy; Germany – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Infrastructure monitoring

  This type of service allows this Application 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 Application.

  App Center - Diagnostics (Microsoft Corporation)

  App Center - Diagnostics is a monitoring service provided by Microsoft Corporation.

  Personal Data processed: crash data; device information; Trackers; Usage Data; User ID.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Location-based interactions

  Geolocation (this Application)

  This Application 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 Application.

  Personal Data processed: geographic position.

  Category of personal information collected according to CCPA: geolocation data.

  Non-continuous geolocation (this Application)

  This Application 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 Application.
  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.

  Category of personal information collected according to CCPA: geolocation data.

• Platform services and hosting

  These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
  Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Google Play Store

  This Application 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 how the Owner manages the Data processing.

  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.

  Category of personal information collected according to CCPA: internet information.

  App Store Connect (Apple Inc.)

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

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

  Personal Data processed: advertising data; diagnostics; product interaction; purchase history; search history; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data; User ID.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

• SPAM protection

  This type of service analyzes the traffic of this Application, 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 LLC)

  Google reCAPTCHA is a SPAM protection service provided by Google LLC.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information; inferred information.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• Push notifications based on the User's geographic location

  This Application 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 Application.

• Personal Data collected through sources other than the User

  The Owner of this Application 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.

• Equal protection of User Data

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

• Access the address book

  This Application may request access to your address book.

• Automated decision-making

  Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
  Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
  The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

  Consequences of automated decision-making processes for Users and rights of Users subjected to it

  As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
  In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

  To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

• Analysis and predictions based on the User’s Data (“profiling”)

  The Owner may use the Personal and Usage Data collected through this Application 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.

• Browser Fingerprinting

  Browser Fingerprinting creates an identifier based on a device's unique combination of characteristics (e.g. IP address, HTTP header, browser properties etc.), that allows to distinguish the User from other Users, thereby enabling to track the User's browsing behavior across the web. Browser Fingerprinting does not have an expiration date and cannot be deleted.

• localStorage

  localStorage allows this Application to store and access data right in the User's browser with no expiration date.

• Preference Cookies

  Preference Cookies store the User preferences detected on this Application in the local domain such as, for example, their timezone and region.

• Push notifications

  This Application may send push notifications to the User to achieve 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 change those settings for this Application, 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 Application.

• Rights for registered California Users under the age of 18

  California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

  If a registered User fits that description and posted content on this Application, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

  In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.

• The Service is intended for adults

  Users declare themselves to be adult according to their applicable legislation. Minors may not use this Application.

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

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

• The Service is directed to children under the age of 13

  This Application is directed to children under the age of 13. It doesn't require the child to disclose any more information than is reasonably necessary to participate in its activity.
  Parents may review the personal information about their child collected by this Application - if any - outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted by contacting the Owner. Parents may also agree to the collection and use of their child’s information, but still not allow disclosure to third parties, unless disclosure is integral to the Service.

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 Application 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 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) 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 Application 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 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.

Information for Californian consumers

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 provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, california Consumer Records Statute information, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information.

We will not collect additional categories of personal information without notifying you.

How we collect information: 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.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

• the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. 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 it.

Additional information about California privacy

CCPA: Collection of personal information about consumers below the age of 13

We collect personal information of consumers below the age of 13 and won't sell their data unless their parents or guardians have opted-in on behalf of those minors.

CCPA: Collection of personal information about consumers aged 13 to 16

We collect personal information of consumers between the age of 13 and 16 and won't sell their data unless those consumers have opted-in.

CCPA: Collection of personal information about minors

We do not knowingly collect personal information of consumers who are below the age of 16.