Privacy policy

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The domain name www.the-dubai-life.com, www.the-new-life.com (hereinafter referred to as “Website”) is owned and managed by TRDL ( TRDL FZ CO and TRDL REAL ESTATE ),companies incorporated in the Emirate of Dubai, Dubai, UAE (hereinafter referred to as “TRDL”). 

For the purpose of these terms of use, wherever the context so requires “you”, “yourself”, “client” or “user” or similar terminology are all in use in reference to the individual user of this Website. The terms “we”, “us”, “our”, “ours” shall refer to PRDL.

This Privacy Policy (hereinafter referred to as “Policy”) describes how we and/or our subsidiary (ies) and/or affiliate(s) protect your personal information provided to us on our Website and how we use that information in connection with the service offered through the Website and must be read in conjunction with our Terms and Conditions (“Terms”).

We wish to assure you that the PRDL is strongly committed to protecting the privacy of its users and has taken all necessary and reasonable measures in line with the best industry practice to protect the confidentiality of your personal information and its transmission through our website.

You understand and acknowledge that this policy is effective from the date and time a user registers with the site (“Effective Date”) and accept the terms and conditions laid out on the Website.

1. We may alter this Privacy Policy as needed for certain products and services and to abide by local laws or regulations around the world, such as by providing supplemental information in certain countries.

1. 2. OWNER AND DATA CONTROLLER

1. 3. TRDL FZ CO / TRDL REAL ESTATE

___________, Dubai, PO Box ______, UAE

1. 4. DPO Contact

2. ________, Dubai, P.O. Box _________, UAE

1. 1. DPO contact email: [email protected]

Owner contact email: info@ the-dubai-life.com

DEFINITIONS AND INTERPRETATION

2. 2. Cookies / Identifiers: Portions of code are placed on a User’s device in order to identify them.

2. 3. Cookie Policy: The TRDL FZ CO, TRDL REAL ESTATE Cookie Policy, a copy of which can be found on either the TRDL FZ CO, TRDL REAL ESTATE Website or Mobile App.

2. 4. 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 Platform. The Data Controller, unless otherwise specified, is the Owner of this Platform.

2. 5. Data Processing / Processing: The methods used to collect and Process a User’s Personal Data on the Platform and the processes used which govern the integrity of the Data Processing.

2. 6. 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 Subject: The natural or legal person to whom the Personal Data belongs to.

2. 8. 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.

2. 10. Online Services: The App and Website

Owner: TRDL FZ CO, TRDL REAL ESTATE  Companies incorporated in the UAE.

2. 11. Personal Data (or Data): Any information that directly, indirectly, or in connection with other information, such as a username or password allows the identification or identifiability of a natural person.

2. 12. Platform: The Online Services, Kiosks and In-Store Services and their associated content which collects and processes a User’s Personal Data.

2. 13. Privacy Policy: This document which outlines how the Platform collects, processes, and retains a User’s Personal Data.

2. 14. Service: The Service provided by the Platform as described in the Terms that may be found on either the TRDL FZ CO, TRDL REAL ESTATE Website or Mobile App.

2. 14. 1. Usage Data: Information collected automatically through this Platform (or third-party services employed by this Platform), which can include:

1. 1. 1. the IP addresses or domain names of the computers utilised by the Users who use this Platform;

the URI (Uniform Resource Identifier) addresses, the time of the request;

1. 1. 1. the method utilised to submit the request to the server, the size of the file received in response;
      2. the numerical code indicating the status of the server’s answer (successful outcome, error, etc.);
      3. the country of origin, the features of the browser and the operating system utilised by the User;

the various time details per visit (e.g., the time spent on each page within the Application);

1. 1. 1. the details about the path followed within the Application with special reference to the sequence of pages visited;

other parameters about the device operating system and/or the User’s IT environment.

2. 16. 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).

2. 17. This privacy policy relates solely to This Platform, if not stated otherwise within this document.

Latest update: ______ March 2022

DATA COLLECTION

3. 2. We may collect personally identifiable information like name, telephone number, date of birth, shipping address, e-mail address, etc., personal information and sensitive personal information. Other information that we may collect includes location details, IP address, logs, metadata, and other Personal Data we get from communications done through e-mails, SMS, instant messages, and calls.

3. 3. We may also maintain a record of your product interest and acquire information about you for our present and/or future affiliates. If you choose to post messages on our message boards, online/ offline chats or other message areas or leave feedback for other users, we may retain this information.

3. 4. We may collect information about the location of your device to facilitate your use of certain features of our Services, device ID, device type, determine the speed at which your device is travelling, add location-based filters. We may collect information about the hardware model, operating system and version, unique device identifier, phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information. This information includes, but is not limited to demographic data, navigation data, additional contact data and additional data about you from other sources, such as public authorities, to the extent permitted by law.

3. 5. Moreover, if you permit the website/application to access the address book on your device through the permission system used by your device platform, we may access and store names, contact and messages information from your address book to facilitate any form of interactions through our Services and for other purposes specified in this Privacy Policy.

3. 6. All the aforesaid information is service dependent, and we may use the above-said user information to, maintain, protect, and improve services (including advertising services) and/or for developing new services. Users can always refuse to supply personally identifiable or any other information, with the condition that it may prevent them from engaging in certain website-related activities and functionalities.

3. 7. You acknowledge that our third-party services providers may need to collect certain additional information, e.g.- your credit or debit card number and expiration date, bank routing and account number. We may also aggregate non-personal information about you and other customers who visit our Website.

1. 1. 1. We may receive personal data about individuals who do not interact with us directly. For example, our clients, service providers, and partners may provide us with information about individuals other than themselves when using our products or services. In addition, the Company may obtain personal data from other participants in a transaction processing chain, such as card associations and debit network operators and their members. The types of information we receive about third parties includes:

1. 1. 1. Information about the personnel of our clients, service providers, or partners, such as the business contact information that our clients, service providers, or partners provide to us in the context of our contractual relationships with them
      2. Information about potential job candidates, such as when a recruiter contacts us about an individual who may become a candidate for a job at our Company
      3. Information about customers of our clients that our clients send to us or allow us to collect in the context of the services that the Company performs, such as information related to financial transactions initiated by the customer, account registrations, and in some cases, the information needed to verify a customer’s identity and details of products or services purchased, and as otherwise stated in an applicable specific privacy notice for a Company product or service. Where our technology is incorporated into a merchant’s mobile application or website, we also may automatically collect certain information of the type described in the section below titled “Information collected via automated means.”

3. 8. Information obtained when processing transactions, such as information about payment transactions.

Types of Data Collected

1. 1. 1. Among the types of Personal Data that This Platform collects, by itself or through third parties, there are: email address; Usage Data; first name; last name; phone number; Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position.
      2. 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.
      3. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using This Platform.
      4. Unless specified otherwise, all Data requested by This Platform is mandatory and failure to provide this Data may make it impossible for This Platform to provide its services. In cases where This Platform 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.
      5. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
      6. Any use of Cookies, or of other tracking tools, by This Platform or by the owners of third-party services used by This Platform 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.

3. 9. Users are responsible for any third-party Personal Data obtained, published, or shared through This Platform and confirm that they have the third party’s consent to provide the Data to the Owner.

3. 10. We and our service providers may collect information about individuals that is publicly available, including by searching publicly accessible government lists of restricted or sanctioned persons (such as the Specially Designated Nationals And Blocked Persons List), public records databases (such as company registries and regulatory filings), and by searching media and the internet. We and or our third-party verification providers may also collect information from private or commercially available sources, such as by requesting reports or information from credit reference and fraud prevention agencies to the extent permitted under applicable law.

3. 11. We may also maintain pages for our company and our products and services on a variety of third-party platforms, such as LinkedIn, Facebook, Twitter, Google, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them, we will treat that information in accordance with this Privacy Policy.

3. 12. When you access our websites or use our mobile applications, we, our service providers, and our partners may automatically collect information about you, your computer or mobile device, and activity on our websites or mobile applications. Typically, this information includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising),browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on or in our websites or mobile applications, such as pages or screens you accessed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.

4. Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected via various mechanisms, such as via cookies, web beacons, embedded scripts, through our mobile applications, and similar technologies. This type of information may also be collected when you read our HTML-enabled emails.

DATA PROCESSING

Methods of Processing

4. 2. The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. Data Processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain persons involved with the operation of the Platform (such as but not limited to: administration, sales, marketing, legal, and system administration) or external parties (such as but not limited to: third party technical service providers, mail carriers, hosting providers, IT companies and communications agencies) appointed, if necessary, as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.

1. 1. 1. 1. Legal Basis of Data Processing

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

1. 1. 1. 1. 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 Data 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;
         2. 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;

1. 1. 1. 1. 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;

4. 2. 2. Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

4. 3. In any case, the Owner will help to clarify the specific legal basis that applies to the Data 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

1. 1. 1. Data Processing is carried out at the Owner’s operating offices and in any other places where the parties involved in the Data Processing are located.
      2. 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 refer to the section “Detailed information on the Processing of Personal Data”.
      3. Users are also entitled to learn about the legal basis of Data transfers to a country outside of the European Union, or to any international organisation 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 Personal Data.

4. 4. If any such transfer takes place, Users can find out more by checking the relevant sections of this Privacy Policy or inquire with the Owner using the information provided in the contact section.

Retention time

1. Personal Data shall be processed and stored for as long as required by the purpose/s it has been collected for. Therefore:
2. Personal Data collected for purposes related to the performance of a contract between the Owner and the User and shall be retained until such contract has been fully executed.

2. 0. 2. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this Privacy Policy or by contacting the Owner.

2. 0. 2. The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such Data 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.

2. 5. 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 the expiration of the retention period.

The purposes of Processing

1. 1. 1. Personal Data belonging to 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) or to detect any malicious or fraudulent activity. In addition, Personal Data may be used for the following, but not limited to, purposes: advertising, analytics, contacting the user, displaying content from external platforms, handling payments, location-based interactions, managing contacts and sending messages, Platform services and hosting, backend infrastructure, User database management, SPAM protection, and tag management.

5. For specific information about how the Personal Data is used for each purpose, the User may refer to the below section “Detailed information on the Processing of Personal Data”.

1. 1. DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
      1. Personal Data is collected for the following purposes and using the following Services:

Advertising

1. 1. 1. This service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on the Platform, possibly based on User interests. This does not mean that all Personal Data is 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 behavioural retargeting technique, i.e., displaying ads tailored to the User’s interests and behaviour, including those detected outside of the Platform. For more information, please check the privacy policies of the relevant services.
      2. 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.

5. 2. Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ad settings in general.

1. 1. 1. Crimtan (Crimtan Holdings Limited)
      2. Crimtan is an advertising service provided by Crimtan Holdings Limited.
      3. Personal Data processed: Cookies; Usage Data.

5. 3. Place of Processing: United Kingdom – Privacy Policy – Opt-out.

Category of personal data collected: Internet information.

Analytics

5. 4. The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google LLC)

1. Google Analytics is a web analysis service provided by Google LLC (“Google”). Google analyses the Data collected to track and examine the use of this Platform, to prepare reports on its activities and share them with the Owner and other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
2. Personal Data processed: Cookies; Usage Data.

3. 5. Place of Processing: United States – Privacy Policy – Opt-Out. Privacy Shield participant.
      1. Category of personal data collected: Internet information.

Google Analytics Advertising Reporting Features

3. 5. 1. Google Analytics has Advertising Reporting Features activated on this Platform, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users’ ads interaction Data) and, if enabled, demographic Data (information about age and gender of Users).

Users can opt out of Google’s use of Cookies by visiting Google’s Ads Settings.

1. 1. 1. Personal Data processed: Cookies; unique device Identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

3. 6. Place of Processing: United States – Privacy Policy – Opt-Out. Privacy Shield participant.

Category of personal data collected: Internet information and Identifiers.

Telephone contact

1. Users that provided their telephone number might be contacted for commercial or promotional purposes related to this Platform, as well as for fulfilling support requests.

1. 1. 1. Personal Data processed: Telephone number.

Category of personal data collected: Identifiers.

Displaying content from external platforms

2. 8. This service allows Users to view content hosted on external platforms directly from the pages of this Platform and to 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

1. Google Fonts is a typeface visualisation service provided by Google LLC that allows this Platform to incorporate content of this kind on its pages.
2. Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

3. 9. Place of Processing: United States – Privacy Policy. Privacy Shield participant.

Category of personal data collected: Internet information.

YouTube

1. YouTube is a video content visualisation service provided by Google LLC whose widget allows this Platform to incorporate video content on its pages.
2. Personal Data processed: Cookies and Usage Data.

3. 10. Place of Processing: United States – Privacy Policy. Privacy Shield participant.

Category of personal data collected: Internet information.

Handling payments

3. 10. 2. Unless otherwise specified, this Platform processes any payments by debit or credit card, bank transfer or other means via external payment made to Authorised THE NEW LIFE – THE DUBAI LIFE Retailers and other appropriate service providers. In general, and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Platform is not involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed or not.

<Payment Gateway Provider Name>

1. Personal Data processed: Cookies, and Credit Card information
2. Place of Processing: United Arab Emirates

2. 0. 4. <Hyperlink Privacy Policy>

<__________ Bank>

Place of processing: UAE

<Hyperlink Privacy Policy>

Paying Prizes

2. 0. 5. If you are a prize winner, we will use personal and financial information you provide to us for anti-money laundering and payment processing, including sharing with our payment providers and jackpot insurance provider.

<Risk Intelligence/Credit check organization>

1. _________ is a risk intelligence database that is used to identify and manage financial, regulatory, and reputational risk and comply with Anti-Money Laundering regulations. The personal data collected will be used to screen against sanction lists, law enforcement watchlists, and lists of politically exposed persons (PEPs).

Place of processing: __________

<Hyperlink Privacy Policy>

Hosting and Backend Infrastructure

1. 1. 1. This type of service has the purpose of hosting Data and files that enable This Platform to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of This Platform.
      2. Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
         1. < hosting and backend service provider name>

_____________ is a hosting and backend service provided by Amazon Web Services, Inc.

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

Place of processing: __________

2. 12. <Hyperlink Privacy Policy>

2. 12. 1. Category of personal data collected according to CCPA: internet information.

Location-Based Interactions

Non-continuous geolocation (This Platform)

1. 1. 1. This Platform may collect, use, and share User location Data in order to provide location-based services.
      2. Most browsers and devices provide tools to opt-out from this feature by default. If explicit authorisation has been provided, the User’s location data may be tracked by This Platform.
      3. The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.

2. 13. Personal Data processed: geographic position.
       1. Category of personal data collected according to CCPA: geolocation data.

Platform Services and Hosting

2. 13. 1. These services have the purpose of hosting and running key components of This Platform, therefore allowing the provision of This Platform 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.
       2. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Apple App Store (Apple Inc.) 

1. 1. 1. 1. This Platform is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
         2. By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enable the Owner to view usage analytics data and measure the performance of This Platform. Much of this information is processed on an opt-in basis.

1. 1. 1. Users may opt-out of these analytics features directly through their device settings. More information on how to manage analysis settings can be found here.

Personal Data processed: Usage Data.

1. 1. 4. Place of processing: United States.

Privacy Policy

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

2. 13. 5. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt-out of the sale in the section detailing the rights of Californian consumers.

Google Play Store (Google LLC)

1. 1. 1. 1. This Platform is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
         2. By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis. 
   2. Users may opt-out of these analytics features directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

1. 1. 1. 4. Place of processing: United States.

Privacy Policy

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

2. 14. 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.

SPAM protection

1. 1. 1. This type of service analyses the traffic of This Platform, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

Google reCAPTCHA (Google LLC)

1. 1. 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.
   2. Personal Data processed: Cookies; Usage Data.

2. 15. Place of processing: United States.
       1. Privacy Policy

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

Tag Management

2. 15. 1. This type of service helps the Owner to manage the tags or scripts needed on This Platform in a centralised fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

1. <Insert Name of Tag service provider if any otherwise delate 5.15>
2. __________ is a tag management service provided by _____ Inc. 
3. Personal Data processed: Cookies; Usage Data.

Place of processing: _____.

1. 1. 4. <Hyperlink Privacy Policy>.

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

4. 16. 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

1. 1. 1. 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 Platform, 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 Platform.
      2. 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 Platform.

<Insert Name of DB service provider if any otherwise delete 5.16>

6. Personal Data: address; country; email address; first name; last name; phone number- Privacy Policy

FURTHER INFORMATION ABOUT PERSONAL DATA

Push Notifications

1. 1. 1. This Platform may send push notifications to the User to achieve the purposes outlined in this privacy policy.
      2. 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 Platform, some, or all of the apps on the particular device.

6. 2. Users must be aware that disabling push notifications may negatively affect the utility of This Platform.

Selling goods and services online

1. 1. 1. The Personal Data collected are used to provide the User with services or to sell goods, including payment.

7. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by This Platform depends on the payment system used.

USER RIGHTS

1. 1. 1. Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
      2. 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.
      3. 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.
      4. 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.
      5. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
      6. 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.
      7. 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.
      8. 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.

7. 2. 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

7. 2. 2. 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 situation to justify the objection.

7. 3. 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

8. 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

9. This Platform uses Cookies and other Identifiers. To learn more, the User may consult the Cookies Policy <Insert Cookie Policy Hyperlink>.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

Legal action

9. 1. 2. 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 Platform or the related Services.

9. 2. 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

9. 3. In addition to the information contained in this privacy policy, This Platform 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

9. 4. For operation and maintenance purposes, This Platform and any third-party services may collect files that record interaction with This Platform (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information Not Contained in this Privacy Policy

9. 5. 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.

1. 1. 1. How “Do Not Track” Requests are Handled

This Platform does not support “Do Not Track” requests.

9. 6. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this Privacy Policy

1. 1. 1. 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 Platform 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.

10. 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

10. 2. 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 Platform and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

10. 3. 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.

10. 4. 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

10. 4. 2. In this section, we summarise the categories of personal information that we have collected, disclosed, or sold and the purposes thereof. You may 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

10. 4. 3. We have collected the following categories of personal information about you: identifiers, internet information and geolocation data. 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?

10. 4. 4. We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use This Platform.

10. 4. 5. For example, you directly provide your personal information when you submit requests via any forms on This Platform. You also provide personal information indirectly when you navigate This Platform, 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 Platform and features thereof.

10. 4. 5. 1. How we use the information we collect: sharing and disclosing your personal information with third parties for a business purpose
          2. 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.

10. 4. 6. We may also disclose your personal information to third parties when you explicitly ask or authorise 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

10. 4. 6. 2. 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”.

10. 4. 7. 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

10. 4. 7. 2. 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.

10. 4. 8. 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

10. 4. 9. If you’d like to know more or exercise your right to opt-out in regard to all the sales carried out by This Platform, 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?

1. 1. 1. 1. We may use your personal information to allow the operational functioning of This Platform 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.
         2. 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 actual damage.

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

1. 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:

1. 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;

1. 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

3. for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

1. 1. 1. 2. The disclosure described above will be limited to the personal information collected or used over the past 12 months.

3. 0. 2. 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

1. 1. 1. 1. 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 Platform, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

3. 0. 3. If no legal exception applies, because 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

1. 1. 1. 1. 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.

1. For us to respond to your request, it is necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
2. provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative.

2. 0. 4. describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

2. 0. 4. 1. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession relates to you.
         2. If you cannot personally submit a verifiable request, you can authorise 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.

1. 1. 1. 1. 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

1. 1. 1. 1. We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
         2. 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 fulfil your request.
         3. 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.