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PRIVACY POLICY
We care about your privacy and the purpose of this Privacy Policy is to provide you with
information about the processing of personal data, including while using Avee Player.
Data controller and contact details
Avee Player
Adress: Pils iela 2, a/k Nr.3, Sigulda, LV-2150
E-mail: support@aveeplayer.com
Website: https://aveeplayer.com/
"Avee Player" music player is an application (from now on - Application) that allows you
to listen to and visualize all your favourite music beats using the built-in spectrum visualizer
templates, and even more, edit and personalize your music in the video maker section to
export your creations as unique.The Application has two versions, Web and Mobile (paid
and free). Their capabilities and features may differ.
Avee Player, which also maintains the website https://aveeplayer.com/ (from now on -
Website), informs that concerning processing your personal data, it is considered a data
controller within the meaning of the General Data Protection Regulation (from now on -
GDPR).
Scope of the privacy policy
This Privacy Policy is applicable in the following scenarios:
When you visit our Website.
When you utilize our services through an Application.
When you engage with us through various other means.
Applicable law
The usage of the Application is regulated by Latvian law, and as we are located in Latvia,
we are also subject to the provisions of the GDPR.
Depending on your geographical location, additional data protection laws may be relevant.
Further details regarding this can be found in our Privacy Policy below.
The personal data we collect, the purposes of our processing and the legal basis for this
processing
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Personal data means any information relating to an identified or identifiable natural person (also
data subject), including a visitor to the Website or a user of the Application.
In some instances, there may be situations where we need to process your personal data. In
connection with the use of the Application, we process the following personal data:
PURPOSE
CATEGORIES OF
PERSONAL DATA
LEGAL BASIS
To deliver our services, we
engage in the processing of your
personal data, which includes:
Payment processing: If you
use a paid (premium) version
of the application, your
personal data will be
processed to facilitate payment
transactions.
Customer support
communication: We use your
personal data to maintain
communication with you as
part of our customer support
services, ensuring that we can
address your inquiries and
resolve any issues effectively.
Quality control and error
prevention: We conduct
analysis, assessment, and
improvements to our
application to ensure its quality
and minimize technical errors.
Use of Application. During the
installation process, the
Application requests
permission from the user with
the message: "Allow Avee
Player to access photos,
media, and other files on your
device." When the user grants
this permission, it allows Avee
Player to access audio files on
their device, which are then
made available in the App's
Library. Users can customize
their audio files within the
Application, such as adding
Data for payment required
by Google Play Store and/or
data requested by bank, etc.
The Application does not
see this data.
Data related to the operation
of the Application for crash
diagnostics and analytics,
as well as technical data
from the user's device for
analytics and diagnostics:
Crash reports:
information about
Application crashes,
errors, or issues
users encounter.
This data helps
identify and resolve
software bugs and
improve stability;
Device information:
Technical details
about the user's
device, such as the
operating system
version.
Customer support data,
e.g., users may share their
thoughts, opinions, or
suggestions about the
application's design,
usability, or overall
performance.
Based on the End-
User License
Agreement (EULA).
Our legitimate interest
to improve our services
and ensure their
effectiveness.
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images and .gif files for audio
visualization. For our part, we
do not see user data.
Also, while the Application asks
for microphone permission, it
doesn't access the microphone
itself to listen for audio from the
device, but rather uses this
permission to access the global
audio stream at the software
level. The native playback
engine uses it and is currently
only kept for compatibility
reasons.
Created content: The user
creates an Audio Visualizer
template that can be saved as
a separate file (.viz) in the
memory of his device (phone or
computer), which can then be
reloaded and further clouded
and exported as a video file in
.mp4 format.
The Application operates without
requiring user registration or profile
creation. The Application does not
use any cookies.
Additionally, it is not linked or
integrated with any social
networks. Users can save
exported files in the .mp4 format
and visualization files in the .viz
format directly to their device's
memory. Subsequently, if they
wish to do so, they can upload
these files to social networks or
other platforms of their choice.
This approach allows for a user-
friendly and flexible experience,
respecting individual preferences
for data sharing.
Commercial Communications:
We use your personal data to
E-mail.
Consent of the data
subject.
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inform you about our services and
other updates.
You have the option to
unsubscribe from receiving
commercial communications at
any time. For instance, you can do
so by clicking the designated link in
an e-mail or reaching out to us at
support@aveeplayer.com.
Please note that the processing of
your unsubscribe request may be
subject to technological
constraints, which should not
exceed 48 hours.
In connection with the use of the Website, we process the following personal data:
PURPOSE
CATEGORIES OF
PERSONAL DATA
LEGAL BASIS
Communication: collecting and
processing questions, suggestions
and other information sent to
prepare replies and ensure
communication with the
addressee/submitter.
Name, contact details, other
personal information in the
question, suggestions, etc.
Consent of the data
subject: Personal data
is collected when an
individual willingly
submits information to
us through their
deliberate action. This
may include voluntarily
providing information
through e-mail.
Based on the End-User
License Agreement
(EULA): If an individual
is a user of our services,
the processing of their
personal data may also
be governed by the
terms outlined in the
EULA.
Donations: You can contribute
funds to support the enhancement
of our Application.
Name, surname, payment
details.
Payment is facilitated
through an agreement
established by
deliberate actions and
conclusive steps.
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Cookies. Only one essential
cookie is utilized for website
functionality; its usage does not
necessitate the visitor's consent.
Cookie name: elementor.
Cookie purpose description: Used
in context with the website's
WordPress theme. The cookie
allows us to implement or change
the website's content in real time.
Type: HTML.
Expiry: Persistent.
Cookie name: elementor.
Our legitimate interest
to make the Website
usable.
We only process your personal data for the purpose for which it was initially collected.
Data sources
Avee Player obtains your personal data through several means:
Directly from you: Personal data is collected directly from you, the data subject, through
various interactions, such as when you provide feedback.
Data processing within the Application: Some personal data may be generated due to your
Application use, such as crash reports.
Received from Third Parties: In specific instances, Avee Player may receive your personal
data from third parties. For example, this could occur when authorities or other entities
provide personal data based on their instructions or for compliance purposes.
Recipients of personal data
Your personal data is maintained securely and is not inappropriately shared with unauthorized
parties. However, personal data may be transferred under the following circumstances:
Payment Service Providers: Personal data may be shared with payment service providers
to facilitate financial transactions.
Legal Obligations: In certain situations, Avee Player may be obligated by law or regulation
to disclose data to public authorities. For example, this could include compliance with
requests from the State Revenue Service.
Cooperation Partners: Avee Player may need to share information, including personal data,
with its business partners, such as e-mail marketing platform providers or technical
analytics. Avee Player exercises due diligence in selecting service providers who process
personal data on its behalf. These providers are assessed for their adherence to
appropriate security measures, alignment with Avee Player's instructions and requirements,
and compliance with relevant regulations. These partner companies are prohibited from
using your personal data for any purpose other than the specified and authorized one.
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The user's personal data may be employed for legal purposes by Avee Player, both in a
court of law and in the preliminary phases that precede potential legal action, particularly in
cases stemming from the improper use of this Application or its related services.
Place of data processing
Avee Player predominantly processes personal data within the European Economic Area (EEA).
In cases where there is a need to transfer personal data to countries outside the EEA, Avee Player
is committed to adhering to the procedures established by the GDPR. These procedures are
implemented to guarantee the secure processing of personal data and maintain a level of
protection equivalent to that mandated by the GDPR.
It's important to note that Application data is not stored in the cloud, and user profiles are not
created. The outcomes of user interactions with the Application are downloaded directly to the
user's device, ensuring data privacy and security. This approach aligns with the user's control over
their data.
Storage periods for personal data
Personal information is retained for the following reasons:
To achieve the stated purpose: Data is kept for as long as necessary to achieve the specific
purpose for which it was collected. Once that purpose is fulfilled, the data may be deleted
or anonymized.
Legal or Regulatory Obligations: Data may be retained to comply with legal or regulatory
requirements that require certain data to be processed or retained for a specific period.
Fulfilment of contractual obligations: Where personal data is processed as part of a
contractual agreement, it may be retained for the duration of the contract and a reasonable
period after that to resolve any disputes or to comply with post-contractual obligations.
Consent-Based Processing: Where data processing is based on the data subject's consent,
personal data will only be processed for as long as the consent remains valid and has not
been withdrawn by the data subject.
Safety requirements
Avee Player is dedicated to safeguarding your personal data by employing and continually
enhancing security measures. These measures are designed to shield your information from
unauthorized access, accidental loss, disclosure, or destruction. Avee Player utilizes cutting-edge
technology and adheres to stringent technical and organizational requirements to protect your data.
Rights of the data subject
Data protection grants you several rights to influence the processing of your personal data by Avee
Player. To exercise these rights, please get in touch with Avee Player. Avee Player will respond
within one month. If necessary, this period may be extended by two additional months, accounting
for the complexity and volume of requests. Avee Player will notify you of any such extension and
the reasons for the delay within one month of receiving your request.
Your rights include:
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Access to Personal Data: You have the right to confirm whether Avee Player processes
your personal data and, if so, request a copy of the processed personal data, provided free
of charge. Avee Player may charge a reasonable fee or refuse to comply with the request
in cases of manifestly unfounded or excessive requests.
Correction of Personal Data: If your data has changed or is inaccurate, you can request
that Avee Player correct, update, or amend the information.
Withdrawal of Consent: If Avee Player processes your personal data based on your
consent, you can withdraw your consent at any time. This action will halt further processing
for the specified purpose without affecting prior lawful processing.
Erasure: Under specific circumstances, you can request the erasure of your personal data,
unless legal requirements dictate otherwise.
Restriction of Processing and Objection: You can ask Avee Player to restrict the processing
of your personal data in certain situations, except when processing is mandated by law.
Data Portability: Under certain conditions, you can receive or transfer your data to another
data controller. This right pertains to data provided to Avee Player based on your consent
or contract.
Notification of Personal Data Breach: Avee Player will inform you if a personal data breach
could result in a high risk to your rights and freedoms.
While we highly value your privacy and encourage you to reach out to us with any questions
or concerns regarding your personal data, it's important to remember that you have the right
to seek legal recourse if you believe that your personal data is being processed in an
inappropriate or unlawful manner. You can choose to either approach the courts or contact
the relevant data protection authorities to address any issues or disputes related to the
processing of your personal data. Here, you can find a list of data protection authorities:
https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Further information on data subject rights is available in the GDPR, which can be found online at:
https://eur-lex.europa.eu/legal-content/LV/TXT/?uri=CELEX%3A32016R0679.
Changes
Avee Player reserves the right to update this Privacy Policy by posting the most current version on
its Website and within the Application. In the event of material changes, we will notify you in other
ways.
The Privacy Policy was last updated in 2023, September 6.
Version. 1.0.
Further information for Users in Brazil
This section of the document integrates with and supplements the information contained in the rest
of the Privacy Policy and is provided by the entity running this Application.
This section applies to all Users in Brazil (Users are referred to below, simply as "you", "your",
"yours"), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it
supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term "personal information "as it is defined in the LGPD.
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The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing.
Legal bases are as follows:
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts,
agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal
information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party
to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail
over such interests; and
credit protection.
To learn more about the legal bases, you can contact us any time using the contact details provided
in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section
titled "The personal data we collect, the purposes of our processing and the legal basis for this
processing" within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled "The
personal data we collect, the purposes of our processing and the legal basis for this processing"
within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive
personal information, or of information that is not being processed in compliance with the
LGPD;
obtain information on the possibility to provide or deny your consent and the consequences
thereof;
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obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for
anonymized information) to another service or product provider, provided that our
commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was
based upon your consent, unless one or more exceptions provided for in art. 16 of the
LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data
Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance
with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an
automated decision; and
request the review of decisions made solely on the basis of the automated processing of
your personal information, which affect your interests. These include decisions to define
your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against or otherwise suffer any detriment if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by
using the contact details provided in this document or via your legal representative.
How and when we will respond to your request
We will strive to respond to your requests promptly. In any case, should it be impossible for us to
do so, we'll make sure to communicate to you the factual or legal reasons that prevent us from
immediately, or otherwise ever, complying with your requests. In cases where we are not
processing your personal information, we will indicate to you the physical or legal person to whom
you should address your requests if we are in the position to do so.
If you file an access or personal information processing confirmation request, please make sure
that you specify whether you'd like your personal information to be delivered in electronic or printed
form.
You will also need to let us know whether you want us to answer your request immediately, in
which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In
the latter case, we'll respond within 15 days from the time of your request, providing you with all
the information on the origin of your personal information, confirmation on whether or not records
exist, any criteria used for the processing and the purposes of the processing, while safeguarding
our commercial and industrial secrets.
If you file a rectification, deletion, anonymization or personal information blocking request, we will
make sure to immediately communicate your request to other parties with whom we have shared
your personal information to enable such third parties to also comply with your request except
in cases where such communication is proven impossible or involves disproportionate effort on our
side.
Transfer of personal information outside of Brazil permitted by the law
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We are allowed to transfer your personal information outside of the Brazilian territory in the
following cases:
when the transfer is necessary for international legal cooperation between public
intelligence, investigation and prosecution bodies, according to the legal means provided
by international law;
when the transfer is necessary to protect your life or physical security or those of a third
party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation
agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of
public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the
carrying out of a contract or preliminary procedures related to a contract, or the regular
exercise of rights in judicial, administrative or arbitration procedures.
Further information for California consumers
This document section integrates with and supplements the information in the rest of the Privacy
Policy.
This section applies to all Users (Users are referred to below, simply as "you", "your", "yours"), who
are consumers residing in the state of California, United States of America, according to the
"California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy
Rights Act" (the "CPRA") and subsequent regulations. This section supersedes any possibly
divergent or conflicting information in the Privacy Policy for such consumers.
This part of the document uses the term "personal information "as defined in the California
Consumer Privacy Act (CCPA/CPRA).
Notice at collection
Categories of personal information collected, used, sold, or shared
To find out what categories of your personal information are processed, you can read the section
titled "The personal data we collect, the purposes of our processing and the legal basis for this
processing" within this document.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
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 "The personal data we collect, the purposes of our processing and
the legal basis for this processing" within this document), as well as for complying with the law and
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defending our rights before the competent authorities where our rights and interests are threatened
or we suffer actual damage.
Without your consent, we won't process your information for unexpected purposes or purposes
incompatible with the disclosed initial purposes.
How long do we keep your personal information?
Unless stated otherwise, we will not retain your personal information for longer than is reasonably
necessary for the purpose(s) for which they have been collected.
How we collect information: What are the sources of the personal information we collect?
We collect the categories mentioned above of personal information 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.
How we use the information we collect: disclosing your personal information with third
parties for business purposes.
Please see section "Recipients of personal data" of this document.
No sale of your personal information.
We do not sell or share your personal information. If we decide to, we will inform you beforehand
and grant you the right to opt out of such sale.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
a) The right to access personal information: the right to know and to portability
b) You have the right to request that we disclose to you:
the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In
particular, you have the right to request two separate lists from us where we disclose:
The categories of personal information that we sold or shared about you and the categories
of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose
and the categories of persons to whom it was disclosed for a business purpose.
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.
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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 notify any of our service providers and all third parties to whom we have sold or
shared the personal information to do so provided that this is technically feasible and doesn't
involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain
about you, taking into account the nature of the personal information and the purposes of the
processing of the personal information.
The right to opt out of the sale or sharing of personal information and to limit the use of your
sensitive personal information.
You have the right to opt out of selling or sharing your personal information. You also have the
right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-
discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that
we will not discriminate against you, including, but not limited to, by denying services, charging you
a different price, or providing a different level or quality of services just because you exercised your
consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling
your personal information, and that personal information or sale is necessary for us to provide you
with services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in
exchange for collecting, keeping, or selling your personal information, provided that the financial
incentive offered is reasonably related to the value of your personal information.
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, we must 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 understand, evaluate, and
respond to it appropriately.
We will not respond to any request if we cannot verify your identity and, therefore, confirm that the
personal information in our possession relates to you.
Making a verifiable consumer request does not require creating an account with us. We will use
any personal information collected from you in connection with the verification of your request
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solely for verification. We shall not further disclose the personal information, retain it longer than
necessary for verification purposes, or use it for unrelated purposes.
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 child under your parental
authority.
You can submit a maximum number of 2 requests over 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within ten 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 fulfil your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal
information collected on or after January 1, 2022, you have the right to request that we disclose
information beyond the 12 months, and we will provide it to you unless doing so proves impossible
or would involve a disproportionate effort.
Should we deny your request, we will explain to 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. We may charge a reasonable fee or refuse to act on the
request in such cases. In either case, we will communicate our choices and explain the reasons
behind them.
Further information for Virginia consumers
This document section integrates with and supplements the information in the rest of the Privacy
Policy.
This section applies to all Users (Users are referred to below simply as "you", "your", "yours"), who
are consumers residing in the Commonwealth of Virginia, according to the "Virginia Consumer
Data Protection Act" (the "VCDPA"), and, for such consumers, it supersedes any other possibly
divergent or conflicting information contained in the Privacy Policy.
This part of the document uses the term "personal data" as defined in the VCDPA.
Categories of personal data processed
To find out what categories of your personal information are processed, you can read the section
titled "The personal data we collect, the purposes of our processing and the legal basis for this
processing" within this document.
Categories of personal data we collect
We have collected the following categories of personal data: please see section The personal
data we collect, the purposes of our processing and the legal basis for this processing".
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
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Why we process your personal data
To find out why we process your personal information, you can read the sections titled "The
personal data we collect, the purposes of our processing and the legal basis for this processing"
within this document.
We won't process your information for unexpected purposes, or for purposes incompatible with the
purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided
in this document.
How we use the data we collect: sharing of your personal data with third parties
We do not share nor disclose your personal data with third parties.
Sale of your personal data
We do not sell your personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
Processing of your personal data for targeted advertising
We do not process your personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your personal data for
targeted advertising.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise
them
You may exercise certain rights regarding your data processed by us. In particular, you have the
right to do the following:
access personal data: the right to know. You have the right to request that we confirm
whether or not we are processing your personal data. You also have the right to access
such personal data.
correct inaccurate personal data. You have the right to request that we correct any
inaccurate personal data we maintain about you, taking into account the nature of the
personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any
of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and
usable format that allows you to transfer data easily to another entity provided that this
is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising,
the sale of personal data, or profiling in furtherance of decisions that produce legal or
similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the
VCDPA. This means that we will not, among other things, deny services, charge you a
different price, or provide a different level or quality of services just because you exercised
your consumer privacy rights. However, if you refuse to provide your personal data to us or
ask us to delete or stop selling your personal data, and that personal data or sale is
necessary for us to provide you with services, we may not be able to complete that
transaction. To the extent permitted by the law, we may offer a different price, rate, level,
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quality, or selection of services to you, including offering services for no fee, if you have
exercised your right to opt out, or our offer is related to your voluntary participation in a
bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via
the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our possession actually relate to
you. In such cases, we may request that you provide additional information which is reasonably
necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. We will use any
personal data collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it longer than necessary for
purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest 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.
Should we deny your request, we will explain to you the reasons behind our denial without undue
delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to
appeal such decision by submitting a request to us via the details provided in this document. Within
60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the decisions. If the
appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request
is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act
on the request. In either case, we will communicate our choices and explain the reasons behind
them.
Further information for Colorado consumers
This document section integrates with and supplements the information in the rest of the Privacy
Policy.
This section applies to all Users (Users are referred to below, simply as "you", "your", "yours"), who
are consumers residing in the State of Colorado, according to the "Colorado Privacy Act" (the
"CPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting
information contained in the privacy policy.
This part of the document uses the term "personal data" as defined in the CPA.
Categories of personal data processed
16
To find out what categories of your personal information are processed, you can read the section
titled "The personal data we collect, the purposes of our processing and the legal basis for this
processing" within this document.
Categories of personal data we collect
We have collected the following categories of personal data: please see section The personal
data we collect, the purposes of our processing and the legal basis for this processing".
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal information, you can read the sections titled "The
personal data we collect, the purposes of our processing and the legal basis for this processing"
within this document.
We won't process your information for unexpected purposes, or for purposes incompatible with the
purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided
in this document.
How we use the data we collect: sharing of your personal data with third parties
Please see section "Recipients of personal data" of this document.
For our purposes, the word "third party" means "a person, public authority, agency, or body other
than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by
the CPA.
Sale of your personal data
We do not sell your personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for
monetary or other valuable consideration by a controller to a third party" as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that
processes personal data on behalf of a controller does not constitute a sale. In addition, other
specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of
personal data to a third party for the provision of a product or service requested by you.
Processing of your personal data for targeted advertising
We do not process your personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your personal data for
targeted advertising.
For our purposes, the word "targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over time from the
consumer's activities across nonaffiliated websites, applications, or online services to predict
consumer preferences or interests" as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: "advertisements
directed to a consumer in response to the consumer's request for information or feedback;
advertisements based on activities within a controller's own websites or online applications or any
17
affiliated website or online application; advertisements based on the context of a consumer's
current search query, visit to an internet web site or online application; or processing personal data
solely to measure or report advertising frequency, performance or reach".
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the
right to do the following:
opt out of the processing of your personal data for the purposes of targeted advertising, the
sale of personal data, or profiling in furtherance of decisions that produce legal or similarly
significant effects concerning you.
access personal data. You have the right to request that we confirm whether or not we are
processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any
inaccurate personal data we maintain about you, taking into account the nature of the
personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any
of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and
usable format that allows you to transfer data easily to another entity provided that this is
technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a service, based solely
on the exercise of any of your rights and unrelated to the feasibility or the value of a service.
However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or
selection of services to you, including offering services for no fee, if our offer is related to your
voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card
program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via
the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to
exercise.
We will not respond to any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our possession actually relate to
you. In such cases, we may request that you provide additional information which is reasonably
necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. We will use any
personal data collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it longer than necessary for
purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45
days of its receipt. Should we need more time, we will explain to you the reasons why, and how
18
much more time we need. In this regard, please note that we may take up to 90 days to fulfill your
request.
Should we deny your request, we will explain to you the reasons behind our denial without undue
delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to
appeal such decision by submitting a request to us via the details provided in this document. Within
45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the decisions. If the
appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This document section integrates with and supplements the information in the rest of the Privacy
Policy.
This section applies to all Users (Users are referred to below, simply as "you", "your", "yours"), who
are consumers residing in the State of Connecticut, according to "An Act Concerning Personal
Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the
"CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting
information contained in the privacy policy.
This part of the document uses the term "personal data" as defined in the CTDPA.
Categories of personal data processed
To find out what categories of your personal information are processed, you can read the section
titled "The personal data we collect, the purposes of our processing and the legal basis for this
processing" within this document.
Categories of personal data we collect
We have collected the following categories of personal data: please see section The personal
data we collect, the purposes of our processing and the legal basis for this processing".
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal information, you can read the sections titled "The
personal data we collect, the purposes of our processing and the legal basis for this processing"
within this document.
We won't process your information for unexpected purposes, or for purposes incompatible with the
purposes originally disclosed, without your consent. You can freely give, deny, or withdraw such
consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
Please see section "Recipients of personal data" of this document.
For our purposes, the word "third party" means "a person, public authority, agency, or body other
than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by
the CTDPA.
19
Sale of your personal data
We do not sell your personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for
monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that
processes personal data on behalf of a controller does not constitute a sale. In addition, other
specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of
personal data to a third party for the provision of a product or service requested by you.
Processing of your personal data for targeted advertising
We do not process your personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your personal data for
targeted advertising.
For our purposes, the word "targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over time from the
consumer's activities across non affiliated websites, applications, or online services to predict
consumer preferences or interests" as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: "advertisements
based on activities within a controller's own web sites or online applications; advertisements based
on the context of a consumer's current search query, visit to an internet web site or online
application; advertisements directed to a consumer in response to the consumer's request for
information or feedback; or processing personal data solely to measure or report advertising
frequency, performance or reach".
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the
right to do the following:
access personal data. You have the right to request that we confirm whether or not we are
processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any
inaccurate personal data we maintain about you, taking into account the nature of the
personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any
of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and
usable format that allows you to transfer data easily to another entity provided that this is
technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the
sale of personal data, or profiling in furtherance of decisions that produce legal or similarly
significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of a service, based solely
on the exercise of any of your rights and unrelated to the feasibility or the value of a service.
However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or
20
selection of services to you, including offering services for no fee, if our offer is related to your
voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card
program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via
the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to
exercise.
We will not respond to any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our possession actually relate to
you. In such cases, we may request that you provide additional information which is reasonably
necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. We will use any
personal data collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it longer than necessary for
purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest 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.
Should we deny your request, we will explain to you the reasons behind our denial without undue
delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to
appeal such decision by submitting a request to us via the details provided in this document. Within
45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the decisions. If the
appeal is denied, you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
Further information for Utah consumers
This document section integrates with and supplements the information in the rest of the Privacy
Policy.
This section applies to all Users (Users are referred to below, simply as "you", "your", "yours"), who
are consumers residing in the State of Utah, according to the "Consumer Privacy Act" (the
"UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting
information contained in the privacy policy.
This part of the document uses the term "personal data" as defined in the UCPA.
Categories of personal data processed
To find out what categories of your personal information are processed, you can read the section
titled "The personal data we collect, the purposes of our processing and the legal basis for this
processing" within this document.
21
Categories of personal data we collect
We have collected the following categories of personal data: please see section The personal
data we collect, the purposes of our processing and the legal basis for this processing".
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal information, you can read the sections titled "The
personal data we collect, the purposes of our processing and the legal basis for this processing"
within this document.
How we use the data we collect: sharing of your personal data with third parties
Please see section "Recipients of personal data" of this document.
For our purposes, the word "third party" means "a person other than: the consumer, controller, or
processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.
Sale of your personal data
We do not sell your personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for
monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.
Please note that according to the UCPA, the disclosure of personal data to a processor that
processes personal data on behalf of a controller does not constitute a sale. In addition, other
specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of
personal data to a third party for the provision of a product or service requested by you.
Processing of your personal data for targeted advertising
We do not process your personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your personal data for
targeted advertising.
For our purposes, the word "targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over time from the
consumer's activities across nonaffiliated websites, applications, or online services to predict
consumer preferences or interests" as defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: "advertisements
based on activities within a controller's own websites or online applications or any affiliated website
or online application; advertisements based on the context of a consumer's current search query,
visit to an web site or online application; advertisements directed to a consumer in response to the
consumer's request for information, product, a service or feedback; or processing personal data
solely to measure or report advertising performance, reach or frequency."
Your privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the
right to do the following:
22
access personal data. You have the right to request that we confirm whether or not we are
processing your personal data. You also have the right to access such personal data.
request the deletion of your personal data. You have the right to request that we delete any
of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and
usable format that allows you to transfer data easily to another entity provided that this is
technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising or
the sale of personal data.
In any case, we will not increase the cost of, or decrease the availability of, a product or service,
based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a
service. However, to the extent permitted by the law, we may offer a different price, rate, level,
quality, or selection of services to you, including offering services for no fee, if our offer is related
to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club
card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via
the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to
exercise.
We will not respond to any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our possession actually relate to
you. In such cases, we may request that you provide additional information which is reasonably
necessary to authenticate you and your request. We may retain your e-mail address to respond to
your request.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45
days of its receipt. Should we need more time, we will explain to you the reasons why, and h