Privacy Policy
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Privacy Policy

Last updated January 01, 2024

Preliminary statement

Internet Marketing Ad (sometimes referred to in this policy as "We" or "Us" or "Our") maintains its online presence and provides services to customers and users via its Website at www.InternetMarketingAd.com ("Website"). The Website's primary purpose is: We help companies with Digital Marketing Services such as Content Writing, Email Copywriting and Content Strategy. One of the most important issues that any company must address is that of its customers' and users' privacy. We believe that Our Privacy Policy is one that adheres to all relevant laws, regulations, and customs while at the same time is readily accessible and understandable. We take great pride in the trust that you place in Us and Our Website. For Our Website to be effective, We must collect certain information from you. If you do not agree with any of the terms or practices described in this Privacy Policy, please do not access Our Website or applications. Through the use of Our Website, you are consenting to the provisions set forth in this Privacy Policy.

We reserve the right to make changes to this Privacy Policy at any time. If you want to make sure you are up to date with Our Privacy Policy, We advise you to visit this page frequently.

What does Our Privacy Policy cover?

This Privacy Policy covers Our treatment of your Personally Identifiable Information (as defined below) that We may collect when you access Our Website or any application. This Privacy Policy does not apply to the practices of any company that We do not control or own, people that We do not employ or directly manage, or third-party websites that We do not own, control, or manage. If you visit a website that We mention or link to, be sure to review that website's Privacy Policy.

Our policy allows Us to collect information from you in a manner that will allow you to retain control over your personal information, but still allow Us to make your online visit to Our Website safe, satisfying, and rewarding. We use your information to make it easier for you to access information and services provided on Our Website. The information allows Us to provide you with a personalized experience. Use of any of the services on Our Website is entirely voluntary; however, if you do not provide the Personally Identifiable Information if requested by Us, then We may elect not to make the related services available for your use.

Information We collect

There are two types of general information that are typically collected online: Anonymous Information and Personally Identifiable Information.

Anonymous Information is information that cannot be traced back to a specific person. While We may have a hit counter on web server where Our Website is hosted, that counter only tracks the number of hits, it does not collect any specific information about Our visitors. This is an example of Anonymous Information.

Personally Identifiable Information is information that tells Us about you and may include the following:

  • First & last name
  • Company name
  • Title
  • Phone number
  • Email address
  • Billing address
  • IP address
  • Website
  • Username
  • Trackers
  • Usage Data
  • Various types of Data

and similar information that helps identify you. This information is needed to allow Us to personalize your experience on Our Website. When We request Personally Identifiable Information from you, We may include a link to these privacy policies, and inform you what information is required and what information is optional.

We may collect information from you directly in several ways such as when you place an order, become a member, maintain a "wish list," complete a survey, or enter contest. We collect information if you sign up to receive a newsletter, or if you contact Us.

We may collect information about you from third parties so We can provide better, more personalized content and services for you, such as Our service and marketing partners, with whom We might co-brand, promote, or engage in joint marketing activities.

How We use your information

We use your information to improve your experience on Our Website. We may use the information to:

  • Process the transactions you request of Us, such as to register an account, process orders and credit card transactions.
  • Create and manage accounts.
  • Administer your participation in promotions, contests, and sweepstakes.
  • Respond to your requests for help, comments, or concerns about Our Website.
  • Notify you if We materially update Our Privacy Policy or terms of use.
  • Conduct market research, manage Our promotions, or tell you about Our products, services, or special offers on Our own products or third-party products We think you might find interesting.
  • Improve Our products and services, by combining information that We have collected offline, online, from third-party sites, and from devices to help Us understand and improve Our Website.
  • Protect against fraud and for security purposes.
  • Comply with legal or regulatory requirements.

Users who are children and their parents

Our Website does not knowingly collect Personally Identifiable Information from and about children. We are sensitive to the issues involved in collecting such information from children and have taken steps to ensure the privacy of any minors accessing Our Website. If it is determined that such information has been inadvertently collected, We will take the steps necessary to ensure that such information is deleted from Our database or that verifiable parental consent is obtained. Our Website established guidelines that operate in connection with Our adherence to the Federal Children's Online Privacy Protection Act of 1998 (COPPA): Children Online ACT. We strongly agree with the intent of COPPA and have structured Our COPPA policy to enable Us to collect only the information from children that is necessary for their access to Our Website service; and, then only after obtaining verifiable consent from their parents.

We strongly recommend that any information about children submitted to Our Website be of the type that would typically appear in a local newspaper. Accordingly, information that is not appropriate for local newspapers should not be posted to Our Website.

Information We share

We will not sell, rent, or otherwise provide your Personally Identifiable Information to anyone except as provided in this Privacy Policy. However, We may send Personally Identifiable Information about Our users to other companies or people when:

  • We need to share your Personally Identifiable Information to provide a product or service that you requested;
  • We need to send the Personally Identifiable Information to third parties that provide services on Our behalf to provide you with a product or service you requested;
  • We use marketing partners to help Us audit the quality and effectiveness of advertisements, provide analytic services and similar services;
  • We use third parties (such as Google, Microsoft, and/or Meta) to collect and analyze information about the use of Our Website. This information helps Us provide relevant advertisements to you and measure the effectiveness of Our marketing campaigns;
  • We use third-party shipping and credit card processing partners to enable them to properly fulfill your product and service requests. Our partners are not permitted to retain, share, store or use this Personally Identifiable Information for any secondary or other purposes not directly related to fulfillment of your product and service requests;
  • We have your consent to share your Personally Identifiable Information;
  • We respond to subpoenas, court orders, or legal processes or take other steps to remain in compliance with applicable laws; or
  • We find that your actions on Our Website violate Our Terms of Use or any of Our usage guidelines for Our Services.

In most respects, you will deal directly with Our third-party advertisers and their shipping and credit card processing partners.Therefore, Our users should carefully review Our advertisers' privacy policies and terms and conditions prior to entering into a transaction with such advertisers.

Cookies

We collect information about you through online tracking. We use, as do third-party service providers, tracking technology like browser cookies, web beacons and pixels on Our Website, applications, and in emails We send to you. Cookies are pieces of Data stored on hard drives that contain information about you and your activity. Web beacons and pixels help Us understand how you interact with Our Website. Cookies are not linked to Personally Identifiable Information while users are on Our Website. Cookies may allow you to only log into the Website once while remembering your username and password for future access. Cookies may be rejected by you, but the rejection may result in more limited access to the services We provide since Our Services may be personalized to you. Cookies may also be used to allow access to sweepstakes, contests and other events. Some of Our advertisers utilize cookies; however, We do not have control over or access to their cookies. We use cookies to monitor Website activity, not user activity. If you choose not to accept cookies, you should be aware that you may not be able to experience the full functionality of Our Website. Our Website does not recognize "Do Not Track" browser signals.

Owner and Data Controller

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Trackers, Usage Data, city, device information, session statistics, browser information, first name, last name, email address, country, state, username, phone number, Data communicated while using the service, answers to questions, user content, contents of the email or message, profile picture, date of the message, time the message was sent, sender of the message, address, email address, company name, Tax ID, country, state, ZIP/Postal code, city, workplace, IP address, website, budget, number of employees, billing address, language, various types of Data.

Category of personal information collected according to the CCPA & CPRA: identifiers, commercial information, internet information, sensorial information, inferred information.

This processing constitutes:

  • Sharing according to the CCPA & CPRA
  • Targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for Us to provide Our Services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Services We offer.

Users who are uncertain about which Personal Data is mandatory are welcome to contact Our privacy officer.

Any use of Cookies — or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing a better user-expereince to User helps Us to offer Services required by the User, in addition to any other purposes described in this Privacy Policy and in the Cookie Policy.

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

Mode and place of processing the Data

Methods of processing

We takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data Processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Us, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Us. The updated list of these parties may be requested from Us at any time by emailing request to Our privacy officer.

Legal basis of processing

We may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations We may be allowed to process Personal Data until the User objects to such processing ('opt-out'), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European Data Protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which We are subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Us;
  • processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party.

In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at Our operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, Data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

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

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Us and/or the organization using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

  • Personal Data collected for purposes related to the performance of a contract between Us and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of Our legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Us within the relevant sections of this document or by contacting Our privacy officer.

We may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to Data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow Us to provide Our Services, comply with its legal obligations, respond to enforcement requests, protect Our rights and interests (or those of Our Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Book a Call, Contacting the User, Displaying Content from External Platforms, Email Marketing, Interaction with Live Chat Platforms, Managing Contacts and Sending Messages, Payment Platforms, Privacy DSAR Request Form and Cookie Consent, Request Email Copywriting Samples, and Tag Management.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. We recommend that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising.

The rights of Users

Users may exercise certain rights regarding their Data processed by Us. Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with Us to find out which rights apply to them.

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time: Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data: Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data: Users have the right to learn if Data is being processed by Us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification: Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data: Users have the right to restrict the processing of their Data. In this case, We will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed: Users have the right to obtain the erasure of their Data from Us.
  • 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.
  • Lodge a complaint: Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Us or for the purposes of the legitimate interests pursued by Us, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether We are processing your Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to Us through the contact details provided in this document. These requests can be exercised free of charge and will be answered by Us as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by Us to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users' request, We will inform them about those recipients.

Applicability of broader protection standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by Us or third-party based within the EU;
  • concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
  • concerns the Personal Data of Users who are in the EU and allows Us to monitor such Users' behavior taking place in the EU.

Additional information about Data collection and processing

  • Legal action: The User's Personal Data may be used for legal purposes by Us in Court or in the stages leading to possible legal action arising from improper use of this Website or Our related Services. The User declares to be aware that We may be required to reveal personal data upon request of public authorities.
  • Additional information about User's Personal Data: In addition to the information contained in this Privacy Policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
  • System logs and maintenance: For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
  • Information not contained in this policy: More details concerning the collection or processing of Personal Data may be requested from Us at any time by contacting Our privacy officer.
  • How 'Do Not Track' requests are handled: This Website does not support 'Do Not Track' requests. To determine whether any of the third-party services Our Website uses honor 'Do Not Track' requests, please read their privacy policies.
  • Changes to this Privacy Policy: We reserve the right to make changes to this Privacy Policy at any time without notifying Users of this Website. It is strongly recommended to check this webpage often, referring to the date of the last modification listed at the top.
  • Should the changes affect processing activities performed on the basis of the User's consent, We shall collect new consent from the User, where required.

Each USA State that has an enforceable Privacy Act is listed here. More States are currently finalizing their Act.

  • California (CCPA & CPRA)

    This section of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by Us and, if the case may be, Our parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "We", "Us", "Our").

    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. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the Privacy Policy.

    Notice of collection

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

    Information we collect and the categories of personal information we collect: We have collected the following categories of personal information about you: identifiers and internet information.

    We may collect the following categories of sensitive personal information: Browser information, address, country, city, state, zipcode, IP address, device information, time, date, session statistics, Trackers, Usage Data, email address, first name, last name, title, phone number, username, company name, size, revenue, budget, website, cookies accepted/declined, and various types of Data.

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

    Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it: You have the right to request that we limit the use or disclosure of your sensitive personal information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer.

    We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.

    Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and we will instruct our service providers and contractors to do the same.

    We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request.

    Once you have exercised this right, we are required to wait at least 12 months before asking whether you have changed your mind.

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

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

    We won't process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

    How long do we keep your personal information: Unless stated otherwise inside the "Detailed information on the processing of Personal Data" section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

    How we collect information and what are the sources of the personal information we collect: We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Website.

    For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, 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 Our Services or with the functioning of this Website and features thereof.

    How we use the information we collect and disclosing of your personal information with third parties for a business purpose: For our purposes, the word "third party" means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.

    We disclose your personal information with the third parties listed in detail in the section titled "Detailed information on the processing of Personal Data" within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

    Sale or sharing of your personal information: For our purposes, the word "sale" means any "selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration", as defined by the CCPA.

    This means that, for example, a sale can happen whenever Our Website 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.

    For our purposes, the word "sharing" means any "sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged", as defined by the CCPA.

    Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.

    Your right to opt out of the sale or sharing of your personal information and how you can exercise it: We sell or share your personal information with the third parties listed in detail in the section titled "Detailed information on the processing of Personal Data" within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

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

    To fully exercise your right to opt out, you can contact Our privacy officer at any time.

    For a simplified opt-out method you can also use the privacy choices links provided in this document. If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control ("GPC"), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

    We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

    Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

    Your privacy rights under the California Consumer Privacy Act and how to exercise them. The right to access personal information and the right to know and to portability: 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.

    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 Website, 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 sale or sharing of personal information and to limit the use of your sensitive personal information: You have the right to opt out of the sale or sharing of 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 goods or services, charging you a different price, or providing a different level or quality of goods or 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 goods or 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, it's necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

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

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

    Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, 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 a period of 12 months.

    How and when we are expected to handle your request: We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

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

    Our disclosure(s) will cover the preceding 12-month period. 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-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

    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.

    California Residents: You have specific rights over your personal information. For more information visit: California Consumer Privacy Act website.

    How to exercise your rights

    You may submit Data Subject Access Request (DSAR) Form as a California resident requesting Do Not Sell My Personal Information.

    If you prefer to email a request to exercise these rights, contact Our: privacy officer.

    For all requests, please clearly state that the request is related to "Your California Privacy Rights" and provide your name, street address, city, state, zip code and an email address or phone number where you may be reached. We will acknowledge your request within ten business days. If you do not receive an acknowledgement, please contact Us again to make sure your request was submitted properly.

    You can always opt out or unsubscribe from marketing emails by emailing: Unsubscribe

    Verification

    Before We can respond to your request, We first must verify your identity using your personal information. If We are not able to verify your request, We will contact you for more information. If We are unable to verify your identify after a good faith attempt, We may deny the request and, if so, will explain the basis for the denial.

    You may designate an authorized agent

    You may designate someone to submit requests and act on your behalf (an "Authorized Agent"). To do so, you must provide Us with written permission to allow your Authorized Agent to act on your behalf.

    We will not discriminate against you

    We will not unlawfully discriminate against you for exercising any of these rights.

  • Colorado (CPA)

    This section of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by Us and, if the case may be, Our parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "We", "Us", "Our").

    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 terms "personal data" (and "sensitive data") as defined in the CPA.

    Categories of personal data processed: In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled "Detailed information on the processing of Personal Data" within this document.

    Categories of personal data we collect: We have collected the following categories of personal data: identifiers, commercial information, internet information, sensorial information, employment related information and inferred information. We also collect the following categories of sensitive data: Browser information, address, country, city, state, zipcode, IP address, device information, time, date, session statistics, Trackers, Usage Data, email address, first name, last name, title, phone number, username, company name, size, revenue, budget, website, cookies accepted/declined, and various types of Data.

    You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Website.

    Please note that certain exceptions set forth in the CPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

    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 data, you can read the sections titled "Detailed information on the processing of Personal Data" and "The purposes of 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 and share your personal data with third parties:

    We share your personal data with the third parties listed in detail in the section titled "Detailed information on the processing of Personal Data" within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

    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: As specified in the "Detailed information on the processing of Personal Data" within this document, we may use your personal data for targeted advertising purposes.

    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 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 right to opt out of the processing of your personal data for targeted advertising and how you can exercise it: You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact Our privacy officerat any time.

    For a simplified opt-out method you can also use the privacy choices link provided on this Website. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

    Universal opt-out mechanism and Global privacy control: If you want to submit requests to opt-out of the sale of personal data via a user-enabled global privacy control, like the Global Privacy Control ("GPC"), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

    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 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 goods or services to you, including offering goods or 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 our privacy officer.

    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. However, we may require you to use your existing account. 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 two requests per year.

  • Connecticut (CTDPA)

    This section of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by Us and, if the case may be, Our parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "We", "Us", "Our"). 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 terms "personal data" (and "sensitive data") as defined in the CTDPA.

    Categories of personal data processed: In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled "Detailed information on the processing of Personal Data" within this document.

    Categories of personal data we collect: We have collected the following categories of personal data: identifiers, commercial information, internet information, sensorial information, employment related information and inferred information. We also collect the following categories of sensitive data: Browser information, address, country, city, state, zipcode, IP address, device information, time, date, session statistics, Trackers, Usage Data, email address, first name, last name, title, phone number, username, company name, size, revenue, budget, website, cookies accepted/declined, and various types of Data.

    You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Website. In the event of withdrawal, we will stop processing the relevant data as soon as possible, but no later than 15 days after receiving your withdrawal request.

    Please note that certain exceptions set forth in the CTDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

    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 data, you can read the sections titled "Detailed information on the processing of Personal Data" and "The purposes of 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 and share your personal data with third parties: We share your personal data with the third parties listed in detail in the section titled "Detailed information on the processing of Personal Data" within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

    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.

    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 Us 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: As specified in the "Detailed information on the processing of Personal Data" within this document, we may use your personal data for targeted advertising purposes.

    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 Our 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 right to opt out of the processing of your personal data for targeted advertising and how you can exercise it: You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.

    To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

    For a simplified opt-out method you can also use the privacy choices link provided on this Website. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

    Universal opt-out mechanism and Global privacy control: If you want to submit requests to opt-out of the sale of personal data via a user-enabled global privacy control, like the Global Privacy Control ("GPC"), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

    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 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 goods or services to you, including offering goods or 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. However, we may require you to use your existing account. 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.

  • Utah (UCPA)

    This section of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by Us and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "We", "Us", "Our"). 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 terms "personal data" (and "sensitive data") as defined in the UCPA.

    Categories of personal data processed: In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled "Detailed information on the processing of Personal Data" within this document.

    Categories of personal data we collect: We have collected the following categories of personal data: identifiers, commercial information, internet information, sensorial information, employment related information and inferred information. We also collect the following categories of sensitive data: Browser information, address, country, city, state, zipcode, IP address, device information, time, date, session statistics, Trackers, Usage Data, email address, first name, last name, title, phone number, username, company name, size, revenue, budget, website, cookies accepted/declined, and various types of Data.

    You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Website.

    Please note that certain exceptions set forth in the UCPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

    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 data, you can read the sections titled "Detailed information on the processing of Personal Data" and "The purposes of processing" within this document.

    How we use the data we collect and share your personal data with third parties: We share your personal data with the third parties listed in detail in the section titled "Detailed information on the processing of Personal Data" within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

    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 Us 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 Us 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: As specified in the "Detailed information on the processing of Personal Data" within this document, we may use your personal data for targeted advertising purposes.

    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 Our 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 right to opt out of the processing of your personal data for targeted advertising and how you can exercise it: You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

    For a simplified opt-out method you can also use the privacy choices link provided on this Website. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

    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:

    • 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 goods or services to you, including offering goods or 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 email 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 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.

    We do not charge a fee to respond to your request, for up to one request per year.

  • Virginia (VCDPA)

    This section of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by Us running this Website and, if the case may be, Our parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "We", "Us", "Our"). 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 terms "personal data" (and "sensitive data") as defined in the VCDPA.

    Categories of personal data processed: In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled "Detailed information on the processing of Personal Data" within this document.

    Categories of personal data we collect: We have collected the following categories of personal data: identifiers, commercial information, internet information, sensorial information, employment related information and inferred information. We also collect the following categories of sensitive data: Browser information, address, country, city, state, zipcode, IP address, device information, time, date, session statistics, Trackers, Usage Data, email address, first name, last name, title, phone number, username, company name, size, revenue, budget, website, cookies accepted/declined, and various types of Data.

    You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Website.

    Please note that certain exceptions set forth in the VCDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

    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 data, you can read the sections titled "Detailed information on the processing of Personal Data" and "The purposes of 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 and share your personal data with third parties: We share your personal data with the third parties listed in detail in the section titled "Detailed information on the processing of Personal Data" within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

    For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

    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: For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.

    Please note that according to the VCDPA, targeted advertising does not include: "advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency".

    To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled "Detailed information on the processing of Personal Data" within this document.

    Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it: You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

    We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

    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 goods or services, charge you a different price, or provide a different level or quality of goods or 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 goods or 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, quality, or selection of goods or services to you, including offering goods or 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. However, we may require you to use your existing account. 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.

Definitions and Legal References

Personal Data (or Data): Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data: Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User: The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject: The natural person to whom the Personal Data refers.

Data Processor (or Processor): The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this Privacy Policy.

Data Controller (or Owner): The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

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

Service: The services listed in this Website as described in the relative terms and provided by Owner of this Website.

European Union (or EU): Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie: Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker: Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User's device.

Legal Information

This Privacy Policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This Privacy Policy relates solely to this Website, if not stated otherwise within this document.

Links

Our Website contains links to other websites. Some of these websites may display Our product logos, Our products, or other content provided by Us. Please understand that We are not responsible for the privacy practices of these other websites. We recommend that you be aware when you leave Our Website and that you read the privacy policies of the other websites to see how they treat information they collect. By providing access to third-party websites or advertisements, We are not endorsing the products or services provided by the owners or operators of such websites. Consequently, We will not be responsible for the accuracy, relevancy, availability, reliability, copyright compliance, legality or decency of the material contained in such third-party websites linked to Our Website. We strongly encourage you to make whatever investigation you feel is necessary or appropriate before proceeding with any online or offline transaction. This Privacy Policy applies only to the information collected by Us via Our Website.

Newsletters

We plan on publishing newsletters that you can subscribe to. These newsletters contain information that can add value to you and your business or some updates about Our website and will be sent via email. You will need to provide contact information in order to receive these newsletters.

Surveys, contests and sweepstakes

We may offer Our Users the opportunity to participate in surveys, contests and sweepstakes via Our Website. In order to participate, you will be asked to provide information. Participation in these events is voluntary, thereby providing you with a choice as to whether to provide the information requested or not. Information requested for these events may include contact information (name and address), demographic Data (zip code and age), and optional information (gender, likes, dislikes). Contact information will only be used to notify the winners and to award prizes. Any survey information will be used to improve and monitor Our Website and other services.

Security

We take Our commitment to protect your information seriously. When you submit sensitive information to Our Website, the information is protected both online and offline.

When Our registration and order forms request you to enter sensitive information (credit card or social security numbers), the information is encrypted and is protected with SSL technology.

Even though We use SSL encryption technology to protect your sensitive information online, We also employ internal procedures to protect sensitive information offline. Access to all of Our Users' sensitive information is restricted to only those employees that require access. We instruct Our employees during the course of their tenure regarding protecting Our users' confidential and sensitive information and We perform periodic checks of how the employees adhere to Our policies. We maintain Our servers in a secure and locked facility that restricts access to only those employees and technicians that require access. Our security policies are periodically reviewed and enhanced as necessary. Only authorized employees and technicians have access to the information provided by Our users.

Due to the nature of technology, you are also partially responsible for the security of their information. Since people have become accustomed to the internet, browser technology has made it easier for everyone to return to their favorite websites without re-entering their usernames and passwords. While this is easier for surfing, when Personally Identifiable Information is associated with the log-in information, your security could be affected. We strongly recommend that you do not save their username and password in your browsers and that you either remember their log-in information or store your usernames and passwords separately to avoid unauthorized access to your information from your devices.

Additional information regarding Our security practices can be obtained by emailing questions to Our privacy officer.

We also offer the following advice:

  • If you share your device with other people, remember to log off Our Website before leaving it.
  • Don't share your password with anyone. If you store your log in information in your computer, remember to password protect that information. No one from Our Website will ever ask for your password.
  • If asked, don't give out your personal information.
  • If you are unsure about the information you are providing, ask Us, another administrator, or another person before posting the information.
  • If there is information that you would not like to see in your local newspaper, don't post it to Our Website.
  • When in doubt, ask Our privacy officer.

Announcements

As We add new services to Our Website, We will inform Our Users of the additional features. We may also send announcements regarding updates to the service and information regarding maintenance. Since these messages contain important information regarding the service, Our users are not permitted to opt out of receiving these messages.

Corrections to personal information

If your Personally Identifiable Information changes, or you wish to terminate your participation in Our Services, We will try to provide a way to correct, update, or remove your Personally Identifiable Information from Our servers. These updates and removals can be initiated on Our Users' information pages by Our Website administrator or by sending a message to Our privacy officer. In extenuating circumstances, We can address these issues via telephone or regular U.S. Postal Service. Some information may remain on Our servers including in Our archived records after termination of an account.

Opting out

We value your privacy and provide you with the ability to "opt out" of having your information used for purposes not directly related to Our Website service and the purposes for which the information is requested. For instance, Our registration form has a box that can be checked for you to opt out of having their information used for marketing purposes or shared with third-party partners of Our Website.

If you previously accepted Our newsletter or promotional materials and no longer want to receive these messages, you may opt out of receiving additional messages by clicking the "Unsubscribe" link at the bottom of the message, replying with "unsubscribe" in the subject line of the email, or by emailing Us: Unsubscribe. You may also return to your information page to edit the information regarding receiving messages and newsletters and choose the opt-out option.

If any user information is being shared with third parties or collected by third parties, We provide prior notice to Our Users, in order to allow them to make an informed decision regarding allowing the information to be collected and proceeding with the third-party transaction or not.

Changes to Our Privacy Policy

Latest version of Our Privacy Policy will be posted on this web page and will have date of version at top of this web page. Our Privacy Policy will inform you of what information We collect, how We use the information, and under what circumstances, if any, We disclose the information to third parties. If at any time We decide to use Personally Identifiable Information in a manner different from that stated at the time the information was collected, We will notify you via an email. You will then have the opportunity to opt out of allowing Us to use the information. Users that fail to respond to the change of policy message will not have their information utilized pursuant to the new policies since We will implement the policies for all information collected from the time of the change forward. We will use the information in accordance with the Privacy Policy under which it was collected.

Enforcement

If you feel that Our Website is not following Our Privacy Policy, you may contact Us at Our office via telephone at (808) 393-8787. You may also direct inquiries to Our privacy officer. The Federal Trade Commission also has a complaint hotline that can be reached by phone at (202) 382-4357 or online at FTC.

Additional questions

Any additional questions regarding Our Privacy Policy can be asked via email by sending a message to Our privacy officer. You may also contact Us via USPS mail at:

ATTN: Privacy Officer
Michael D Molinare, DBA
Internet Marketing Ad
2775 N Roadrunner Pkwy #202
Las Cruces, NM 88011

European Union Privacy Rights - GDPR

If you are located in the European Union, you have specific rights over your personal information. GDPR resources General Data Protection Regulation - GDPR.

You have the right to request access

You have the right to request copies of your personal information. We may charge you a small fee for this service.

You have the right to request to rectify your Data

You have the right to request that We correct any information you believe is inaccurate. You also have the right to request We complete information you believe is incomplete. You may always correct and update your information by logging onto your account and editing your information.

You have the right to request erasure of your Data

Under certain conditions, you have the right to request that We delete your personal information.

You have the right to restrict processing

Under certain conditions, you have the right to object to the processing of your personal information.

You have the right to Data portability

Under certain conditions, you have the right to request We transfer personal information We have collected about you either to another organization, or directly to you.

How to exercise your rights

You may submit Data Subject Access Request (DSAR) Form if you are making a EU GDPR compliance request.

We have one month to respond to your request to exercise these rights. If you prefer to email request, contact Our: privacy officer.

For all requests, please clearly state that the request is related to "Your EU Privacy Rights" and provide your name, street address, city, state, zip code and an e-mail address or phone number where you may be reached.

If you make a request, We have one month to respond to you. We may require you to verify your identity before We may respond to you.

Although We urge you to contact Us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent Data protection authority.

Transfers to countries outside the European Union

We are based in the United States, so EU customers must transfer personal information to the United States for processing. The Commission has not found the laws of the United States to provide an adequate level of protection over personal information. We will only transfer your information to the United States based on your explicit consent.

Michael Molinare

Michael

As Director, Michael Molinare ensures the business delivers on its promise to clients and supports the team at Internet Marketing Ad with resources and coaching to achieve the results expected.