This Application 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. Policy summary Personal Data collected for the following purposes and using the following services: Access to third-party accounts Facebook account access Permissions: Age range; Contact email; Current City; Email; Gender Analytics Google Analytics and Google Analytics with anonymized IP Personal Data: Cookies; Usage Data Contacting the User Contact form Personal Data: city; email address; first name; last name; phone number; ZIP/Postal code Mailing list or newsletter Personal Data: email address; first name; last name; phone number; ZIP/Postal code Phone contact Personal Data: phone number Content commenting Facebook Comments Personal Data: Cookies; Usage Data Content performance and features testing (A/B testing) Google Optimize Personal Data: Cookies; Usage Data Data transfer outside the EU Other legal basis for Data transfer abroad Personal Data: various types of Data Displaying content from external platforms Google Fonts Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service YouTube video widget Personal Data: Cookies; Usage Data Heat mapping and session recording Hotjar Heat Maps & Recordings Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service Interaction with data collection platforms and other third parties GetResponse widget Personal Data: Cookies; email address; first name; Usage Data Interaction with external social networks and platforms YouTube button and social widgets Personal Data: Usage Data Interaction with online survey platforms Hotjar Poll & Survey widgets Personal Data: Cookies; Usage Data; various types of Data Location-based interactions Geolocation Personal Data: geographic position Managing landing and invitation pages Leadpages Personal Data: email address; Usage Data; various types of Data as specified in the privacy policy of the service Lander and Unbounce Personal Data: Cookies; email address; Usage Data Platform services and hosting WordPress.com Personal Data: various types of Data as specified in the privacy policy of the service Remarketing and behavioral targeting Google Ads Remarketing, Remarketing with Google Analytics, Google Signals, Facebook Remarketing and Twitter Remarketing Personal Data: Cookies; Usage Data Facebook Custom Audience Personal Data: Cookies; email address Social features Public profile Personal Data: email address; first name; gender; last name; phone number SPAM protection Google reCAPTCHA Personal Data: Cookies; Usage Data User database management Salesforce Sales Cloud, Pardot and Salesforce Marketing Cloud Personal Data: various types of Data as specified in the privacy policy of the service Further information about Personal Data 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. 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. Push notifications for direct marketing This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application). 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 this Application 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. Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy. Unique device identification This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences. Contact information Owner and Data Controller Tax Debt Helpers 187 Withney Mesa Drive Henderson, NV, 89094 Owner contact email: [email protected] Full policy Owner and Data Controller Tax Debt Helpers 187 Withney Mesa Drive Henderson, NV, 89094 Owner contact email: [email protected] Types of Data collected Among the types of Personal Data that this Application collects, by itself or through third parties, there are: first name; last name; phone number; email address; ZIP/Postal code; city; Cookies; Usage Data; various types of Data; geographic position; gender. 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 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: Contacting the User, Analytics, Access to third-party accounts, Remarketing and behavioral targeting, Interaction with data collection platforms and other third parties, Interaction with external social networks and platforms, User database management, Data transfer outside the EU, Content performance and features testing (A/B testing), Displaying content from external platforms, Location-based interactions, Content commenting, Managing landing and invitation pages, Platform services and hosting, SPAM protection, Heat mapping and session recording, Interaction with online survey platforms and Social features. 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. Age range Provides access to the User’s age range. Contact email Access the User’s contact email address. Current City Provides access to the User’s current location. Email Provides access to the User’s primary email address. Gender Provides access to the User’s gender. 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 (this Application) This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook, Inc. Permissions asked: Age range; Contact email; Current City; Email; Gender. 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 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: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Google Analytics with anonymized IP (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. This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. 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: city; email address; first name; last name; phone number; ZIP/Postal code. 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: email address; first name; last name; phone number; ZIP/Postal code. Phone contact (this Application) Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests. Personal Data processed: phone number. Content commenting Content commenting services allow Users to make and publish their comments on the contents of this Application. 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. 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. 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. Google Optimize (Google LLC) Google Optimize is an A/B testing service provided by Google LLC (“Google”). 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. 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. 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. 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. Displaying content from external platforms This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. 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 LLC) Google Fonts is a typeface visualization service provided by Google LLC that allows this Application 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. YouTube video widget (Google LLC) YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Heat mapping and session recording Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. 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. 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. Interaction with data collection platforms and other third parties This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data. 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. GetResponse widget (Implix Sp. z o.o.) The GetResponse widget is a service for interacting with the GetResponse email address management and message sending service provided by Implix Sp. z o.o. Personal Data processed: Cookies; email address; first name; Usage Data. Place of processing: Poland – Privacy Policy. Interaction with external social networks and platforms This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile. YouTube button and social widgets (Google LLC) The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC. Personal Data processed: 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 Application. 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 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. 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. Leadpages (Avenue 81, Inc.) Leadpages is a landing page management service provided by Avenue 81, Inc., that allows this Application 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. Lander (Lander, Inc) Lander is a landing page management service provided by Lander, Inc, that allows this Application to collect the email addresses of Users interested in its service. Lander 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. Unbounce (Unbounce Marketing Solutions Inc.) Unbounce is a landing page management service provided by Unbounce Marketing Solutions Inc., that allows this Application to collect the email addresses of Users interested in its service. Unbounce 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: Canada – Privacy Policy. 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. WordPress.com (Automattic Inc.) WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Application. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Remarketing and behavioral targeting This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application 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. Google Ads Remarketing (Google LLC) Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Application 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. Remarketing with Google Analytics (Google LLC) Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC 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. Facebook Custom Audience (Facebook, Inc.) Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application 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. Google Signals (Google LLC) This Application uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Application with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users’ cross device behaviors. If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Facebook Remarketing (Facebook, Inc.) Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Twitter Remarketing (Twitter, Inc.) Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Social features Public profile (this Application) Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users’ interactions with this Application. Personal Data processed: email address; first name; gender; last name; phone number. 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: Cookies; Usage Data. 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 Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application. 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. Pardot (Salesforce.com, inc.) Pardot 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. 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. Further information about Personal Data 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. 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. Push notifications for direct marketing This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application). 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 this Application 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. Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy. Unique device identification This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences. 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. 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 Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment. User The individual using this Application who, unless otherwise specified, coincides with the Data Subject. Data Subject The natural person to whom the Personal Data refers. Data Processor (or 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 Application. The Data Controller, unless otherwise specified, is the Owner of this Application. This Application The means by which the Personal Data of the User is collected and processed. Service The service provided by this Application as described in the relative terms (if available) and on this site/application. European Union (or EU) Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area. Cookie Cookies are Trackers consisting of small sets of data stored in the User’s browser. Tracker Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device. Legal information This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.
This document informs Users about the technologies that help this Application to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Application. For simplicity, all such technologies are defined as “Trackers” within this document – unless there is a reason to differentiate. For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker. Some of the purposes for which Trackers are used may also require the User’s consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document. This Application uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them. The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session. In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers – in the linked privacy policies of the respective third-party providers or by contacting the Owner. Activities strictly necessary for the operation of this Application and delivery of the Service This Application uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service. Third-party Trackers 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. Lander (Lander, Inc) Lander is a landing page management service provided by Lander, Inc, that allows this Application to collect the email addresses of Users interested in its service. Lander 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 and Usage Data. Place of processing: United States – Privacy Policy. Unbounce (Unbounce Marketing Solutions Inc.) Unbounce is a landing page management service provided by Unbounce Marketing Solutions Inc., that allows this Application to collect the email addresses of Users interested in its service. Unbounce 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 and Usage Data. Place of processing: Canada – Privacy Policy. 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: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Other activities involving the use of Trackers Experience enhancement This Application uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms. Content commenting Content commenting services allow Users to make and publish their comments on the contents of this Application. 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. 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 and Usage Data. Place of processing: United States – Privacy Policy. Displaying content from external platforms This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. 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. YouTube video widget (Google LLC) YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Interaction with data collection platforms and other third parties This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data. 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. GetResponse widget (Implix Sp. z o.o.) The GetResponse widget is a service for interacting with the GetResponse email address management and message sending service provided by Implix Sp. z o.o. Personal Data processed: Cookies, email address, first name and Usage Data. Place of processing: Poland – 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 Application. 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 and various types of Data. Place of processing: Malta – Privacy Policy – Opt Out. Measurement This Application uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service. 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: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Anonymized analytics services The services contained in this section allow the Owner, through the use of third-party Trackers, to collect and manage analytics in an anonymized form. Google Analytics with anonymized IP (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. This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. 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. Google Optimize (Google LLC) Google Optimize is an A/B testing service provided by Google LLC (“Google”). Google may use Personal Data to contextualize and personalize the ads of its own advertising network. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Heat mapping and session recording Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. 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. 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 and various types of Data as specified in the privacy policy of the service. Place of processing: Malta – Privacy Policy – Opt Out. Targeting & Advertising This Application uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads. Remarketing and behavioral targeting This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application 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. Google Ads Remarketing (Google LLC) Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Application 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 and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Remarketing with Google Analytics (Google LLC) Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC 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 and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Facebook Custom Audience (Facebook, Inc.) Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application 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 and email address. Place of processing: United States – Privacy Policy – Opt Out. Google Signals (Google LLC) This Application uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Application with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users’ cross device behaviors. If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Facebook Remarketing (Facebook, Inc.) Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Twitter Remarketing (Twitter, Inc.) Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. How to manage preferences and provide or withdraw consent There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant: Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers. Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available. It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent. Other Trackers in the browser’s local memory may be cleared by deleting the browsing history. With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party’s privacy policy, or by contacting the third party. Locating Tracker Settings Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome Mozilla Firefox Apple Safari Microsoft Internet Explorer Microsoft Edge Brave Opera Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings, such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings, view and look for the relevant setting). Advertising industry specific opt-outs Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document. The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps. Owner and Data Controller Tax Debt Helpers 187 Withney Mesa Drive Henderson, NV, 89094 Owner contact email: [email protected] Since the use of third-party Trackers through this Application cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document. Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by this Application. 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 Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment. User The individual using this Application who, unless otherwise specified, coincides with the Data Subject. Data Subject The natural person to whom the Personal Data refers. Data Processor (or 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 Application. The Data Controller, unless otherwise specified, is the Owner of this Application. This Application The means by which the Personal Data of the User is collected and processed. Service The service provided by this Application as described in the relative terms (if available) and on this site/application. European Union (or EU) Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area. Cookie Cookies are Trackers consisting of small sets of data stored in the User’s browser. Tracker Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device. Legal information This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document. Latest update: October 16, 2019 iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address; Cookies; Usage Data; first name; last name; gender; phone number; company name; address; state; city; ZIP/Postal code. 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. If broader protection standards are applicable, 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: User database management, Interaction with external social networks and platforms, Analytics, Access to third-party accounts, Contacting the User 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 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. Age range Provides access to the User’s age range. Contact email Access the User’s contact email address. Current City Provides access to the User’s current location. Email Provides access to the User’s primary email address. Family Members and Relationship Status Provides access to the User’s family and personal relationships and relationship status. Groups Provides access to the list of groups the User is a member of. 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 (this Application) This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook, Inc. Permissions asked: Age range; Contact email; Current City; Email; Family Members and Relationship Status; Groups. Place of processing: United States – Privacy Policy. Category of personal data collected according to CCPA: identifiers; california Consumer Records Statute information; internet information; inferred 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 Cookies or other Identifiers 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. 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. Amazon Mobile Ads (Amazon) Amazon Mobile Ads is an advertising service provided by Amazon.com, Inc. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Category of personal data 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: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of personal data 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. Google Analytics with anonymized IP (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. This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of personal data 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. 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: address; city; company name; email address; first name; gender; last name; phone number; state. Category of personal data collected according to CCPA: identifiers; commercial information; biometric 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: address; city; company name; email address; first name; last name; phone number; state; ZIP/Postal code. Category of personal data collected according to CCPA: identifiers; commercial information. Interaction with external social networks and platforms This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile. Facebook Like button and social widgets (Facebook, Inc.) The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Category of personal data 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. LinkedIn button and social widgets (LinkedIn Corporation) The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Category of personal data 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. Twitter Tweet button and social widgets (Twitter, Inc.) The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Category of personal data 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. User database management This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application. ActiveCampaign (ActiveCampaign, Inc.) ActiveCampaign is a User database management service provided by ActiveCampaign, Inc. Personal Data processed: Cookies; email address; various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Category of personal data 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. The rights of Users Users may exercise certain rights regarding their Data processed by the Owner. Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them. 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. Applicability of broader protection standards While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards. Such broader protection standards apply when the processing: is performed by an Owner based within the EU; concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users; concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU. 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 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. 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 Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment. User The individual using this Application who, unless otherwise specified, coincides with the Data Subject. Data Subject The natural person to whom the Personal Data refers. Data Processor (or 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 Application. The Data Controller, unless otherwise specified, is the Owner of this Application. This Application The means by which the Personal Data of the User is collected and processed. Service The service provided by this Application as described in the relative terms (if available) and on this site/application. European Union (or EU) Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area. Cookie Cookies are Trackers consisting of small sets of data stored in the User’s browser. Tracker Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device. Legal information This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document. Latest update: June 26, 2020 iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.