Privacy Policy

Babelpeak Inc. (“Babelpeak,” “Company,” “us” or “we”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit, interact with and/or register on our Website located at Babelpeak.com (“Website”) as well as mobile the Applications available on Apple Store and Google Play markets (hereinafter referred to as the Applications, defined below) and/or any third-party products or services, such as mobile applications, websites, online platforms that utilize Babelpeak’s Services (defined below) via API, and any person that downloads and uses Babelpeak Applications or Babelpeak Website in any possible for usage way (hereinafter referred to as “you”, “your”, “user”). Please, note that any collection and use of Personal Data (defined below) or Personal Information (defined below) by third parties made via their products or services that utilize our API is subject to their respective privacy policies and terms. This Privacy Policy applies to such products and services only regarding information that was collected directly via our API and obtained by us.

This Privacy Policy applies to information we collect: (i) on or through our Website, Application(s), and/or Services, (ii) when you contact us directly offline, and (iii) when you interact with our advertising and Application(s) on third-party websites and services, if those Application(s) or advertising include links to this policy. “Application(s),” as used herein, is defined as a mobile application owned by us and available on Apple Store and Google Play markets. “Services,” as used herein, are defined as functionality that a user receives when using our Application(s), platforms, and/or third-party products or services that utilize such functions via application program interface (API) provided by us (including, but not limited to, via widgets).

This Privacy Policy does not apply to information collected: (i) through any other means, including any other website operated by Babelpeak or any third party, or (ii) by any third party, including through any application or content (including advertising) that may be linked to or be accessible from or on our Website, Application(s), or Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website, Application(s) or Services. By accessing or using our Website, Application(s) or Services, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Privacy Policy). Your continued use of our Website, Application(s) or Services after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates.

Notice to California Residents. This Privacy Policy will govern use of your “Personal Information,” which the California Consumer Privacy Act of 2018 (CCPA) defines as information that directly or indirectly identifies, describes, relates to, is capable of being associated with, or can reasonably link to a particular consumer or household. Examples include real name; an alias, postal address, e-mail address unique personal or online identifier, internet protocol (IP address), account name, social security number (SSN), driver’s license or passport number, or other similar identifiers. Personal Information does not include “publicly available” information, which includes information lawfully made available from federal, state or local government records, or information in a form that does not, own its own, permit direct association with any specific individual. If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, please see our Privacy Notice for California Residents.

Notice to European Economic Area (EEA) and UK Residents. This Privacy Policy will govern use of your “Personal Data,” which the EU General Data Protection Regulation 2016/1679 (GDPR) defines as any information relating to an identified or identifiable data subject. Examples include data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual. Personal Data does not include data in a form that does not, on its own, permit direct association with any specific individual. If you are an EEA and/or UK resident, applicable privacy laws may provide you with additional rights regarding our use of your Personal Data. To learn more about your European privacy rights, please see our Privacy Notice for European Residents.

1. CHILDREN UNDER THE AGE OF 16

Our Website, Application(s), and/or Services are not intended for children under 16 years of age (or age equivalent in the relevant jurisdiction). No one under the age of 16 may provide any information to or on our Website, Application and/or Services. We do not knowingly collect Personal Data or Personal Information from children under 16. If you are under 16, please do not attempt to send any personal information about yourself to us. If we learn that we have collected or received Personal Data or Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please e-mail us at bertozzi.jacopo@gmail.com

2. TYPES OF INFORMATION WE COLLECT

We collect several types of information from and about users of our Website, Application(s), and/or Services, including: (i) information that directly or indirectly identifies, describes, relates to, is capable of being associated with, or can reasonably link to a particular consumer or household (see Personal Information defined above); (ii) data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual (see Personal Data defined above); (iii) information or data that is about you, but in a form that does not, own its own, permit direct association with you (e.g., sex, age, body measurements, language preference, occupation, or the like); (iv) information or data about your interaction with (or use of) our Website, Application(s), or Services, which may include your Internet connection, the equipment you use to access our Website, Application(s), or Services, and details relating to your use of our Website, Application(s), or Services; and (v) information or data about your interaction with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

A. INFORMATION WE COLLECT DIRECTLY FROM YOU

We collect information directly from you when you provide it to us, which may include information you provide to us: (i) through e-mail, messages, chat rooms, our Website, Application(s), or Services; (ii) offline when you contact us in writing or by telephone, including when you contact customer support; (iii) at the time of registering and/or subscribing to use our Website, Application(s), or Services; (iv) when you voluntarily enter a contest or promotion or take a survey sponsored by us; or (v) when you report a problem with our Website, Application(s) or Services, including when you contact our technical support.

Different forms on our Website or Applications (e.g. registration form) may also collect your name, email, phone number, company name (if applicable), country, area, zip code, address, password or other data to help you with your experience. Provision of such contact information is voluntary, unless in the relevant forms pointed that this data is necessary for use of our Website, Application and/or the Services.

In order to provide you with the ability to use Applications or the Services, we need to obtain such information: photos of the user (for body measurement process performed using a camera of a smartphone or other device that user owns), height, weight, measurements of your body (e.g. chest width, chest depth, hips width; we obtain such information due to body measurement process via our Services), gender, age.

When using the Application and/or the Services, you may be required to provide billing information. This information is required by us to verify your identity, and invoice you (if applicable).

B. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

In addition to any information that we collect directly from you, we may use a variety of technologies that automatically (or passively) collect certain information or data whenever you visit or interact with our Website or while using our Application(s) or Services, or whenever you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

We do not treat information collected by automatic data collection technologies as Personal Data or Personal Information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data or Personal Information by a relevant law or regulation, we will also treat these identifiers as Personal Data or Personal Information. Similarly, to the extent that information or data we collect that is not considered Personal Data or Personal Information is combined with Personal Data or Personal Information, we treat the combined information as Personal Data or Personal Information for the purposes of this Privacy Policy and compliance with relevant laws and regulations.

The technologies we use for automatic data collection may include:

Cookies. Cookie is a small piece of data that is stored on your device to help websites, software services and apps remember things about you. They are used to personalize content and ads, to operate the Website, provide social media features, analyze how the Website is used. Other technologies, including web storage and identifiers associated with your device (clear gifs, web beacons etc.), may be used for similar purposes. In this Policy, we say “Cookies” to refer to all of these technologies.

Cookies may include:

Session Cookies: enable certain features of our Website and Services and are deleted from your device when you disconnect from or leave our Website or Application(s).
Persistent Cookies: remain after you close your browser and may be used by your browser on subsequent visits to our Website. Persistent Cookies can be removed by you.
First-Party Cookies: Cookies that are used by us.
Third-Party Cookies: Cookies that are used by our partners. Because of how Cookies work, we cannot access Third-Party Cookies; nor can other organizations access the information in the Cookies we use on our Website or Services.
Web Beacons. A Web Beacon (also known as a web bug, pixel tag or a clear GIF) is a clear graphic image that is delivered through a web browser or HTML e-mail. The Web Beacon operates as a tag that records a user’s visit to a particular web page or viewing of a particular e-mail. It is also often used in conjunction with a Cookie and provided as part of a third-party tracking service. Web Beacons may be used to monitor the behavior of a user visiting a website or sending an e-mail. A Web Beacon can pass along information such as the IP address of the computer that retrieved the image, the time the Web Beacon was viewed and for how long, the type of browser that retrieved the image, as well as previously set Cookie values.

You may set your browser to notify you or decline the receipt of cookies. Please note, however, that such settings do not prevent the collection or processing of Personal Information or Personal Data about you, as otherwise provided in this policy. Moreover, certain features of our Website, Application(s) or Services may not function properly or be available if your browser is configured to disable Cookies and/or any of the other automatic data collection technologies described herein.

Information or data obtained by us with the use of automatic data collection technologies may include:

Internet Protocol (IP) addresses;
Device or mobile IDs and/or the device model and type;
Browser information, operating system information, and/or language preferences;
The location and the preceding and succeeding websites you have visited, including which pages/parts/icons of the Website your interacted with;
Applications you click on and how often; and
The pages of our Website or Application(s) you visit, and how long you spend on each page.

How we use Cookies and information or data obtained by us via Cookies:

We use the Cookies for lots of essential things — like helping you log in and tailoring your experience while using the Website or the Services. We may also use Cookies to better understand how you interact with the Website, Application(s) and Services, to monitor aggregate usage by our users and web traffic routing on the Website, to improve the Services, to help us understand your preferences based on previous or current Website activity, which enables us to provide you with the improved Services. The Cookies we use generally fall into one of the following categories:

Category of Cookies	Why we use these Cookies
Essential (Necessary)	Necessary cookies are absolutely essential for the Website to function properly. These cookies ensure basic functionalities and to identify and prevent security risks.
Functional	Functional Cookies help to perform certain functionalities like sharing the content of the Website on social media platforms, collect feedbacks, and other third-party features.
Performance	Performance Cookies are used to understand and analyze the key performance indexes of the Website which helps in delivering a better user experience. For example, we can use these Cookies to learn more about which features are most popular with our users and which ones might need some tweaks.
Analytics	Analytical Cookies are used to understand how users interact with the Website. These Cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement (Marketing)	We may use these Cookies to deliver advertisements, to make them more relevant and meaningful to you, and to track the efficiency of our advertising campaign. These Cookies track visitors across websites and collect information to provide customized ads.

3. HOW WE MAY USE YOUR INFORMATION

In addition to the uses described immediately above, we may use information collected from you when you use our Website, Services, or Application(s), register or sign up for an Application or Service, sign up for our newsletter, respond to a survey or to our marketing communication, browse an Application, or use our Website, Services or their features. We do not sell your Personal Information or Personal Data. We may use information collected from you in the following ways:

Provision of Services. We will use your information or data to provide you with Services via the Applications and/or our Website as follows:

Your photo will be converted to the parameters instantly after uploading them into the Service or Application and deleted immediately after the completion of the modeling process (we never store or transmit your photo to anyone), other data will be used for modeling of user’s body parameters and 3D model only.

If you access our Services via third-party websites, apps, products, platforms or services, we may provide your information to such third parties for the provision of such third-party services in connection with our Services to you. This also applies to cases when you (as an end-user) receive a link to our Services (e.g., link to a widget) from a third party, who is Babelpeak’s client. When you access and use our Services via such third-party sites, products, services, and/or via links from a third party, who is Babelpeak’s client, you agree with a data transfer to such third party. For example, when you receive a link to our widget from a tailor, who is our client, we may receive the following information about you: (i) your body parameters; (ii) full name (where such information was provided by you to that tailor (our client)); (iii) email and phone number (where you provided such information to that tailor (our client) or in our widget registration form). You acknowledge and agree that in case if you get access to our Services via a link from a third party, you agree with a data transfer (of the information above) to such third party.

Please, consider that if you download your photo through our showcase the Applications or Services (as the demo Application or Service is still in testing), it may be accessed by our employees in order to provide consultation (if necessary) or better interaction between us and you. All of our employees are bound with confidentiality obligations (as described below) and cannot disclose such information to third parties.

We may use your contact information in order to provide Services to you, to create your account, respond to your inquiries, requests, complaints as well as support the provision of Services (including technical and customer support), to contact you for the purpose of operational requirements (e.g. for technical updates or updates on changes in our usage policies).

We may also use your contact information to send you company updates and marketing offers when permitted by law or regulation). We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address via our newsletter subscription form. Contacting us is voluntary, and we send emails only to those who first contact us

You may choose to contact us through the Website to receive more information about the job openings or apply for a vacancy via a web form on the Website. If you contact us via our job application form, we may process your contact information, information on your professional skills, and other information about you, which you decided to share with us in your CV. The provision of such information is voluntary and it’s up to you only. Your CV also may contain information about your age, citizenship, salary expectations, etc. Still, we strongly ask you not to put any sensitive data in your CV.

You may refuse or revoke your consent to use Personal Information or Personal Data for the above purposes at any time by contacting us via e-mail at bertozzi.jacopo@gmail.com.

Analytics, Service Improvement & Notifications. We may use any information collected from you, including information that does not qualify as Personal Information or Personal Data to: (i) to personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested; (ii) to improve the Application, Website and Services in order to better serve you and/or to provide Services more effectively; (iii) to ensure continuous improvement and development of the Application(s), and Services; (iv) to administer our Website, the Application(s) and accompanying Services and to diagnose possible problems; (v) to send periodic e-mails regarding your order or our other products and services, our news or educational materials and/or our partners’ services (which we believe may be interesting for you).

We may collect, use, transfer, and disclose “publicly available” information and/or non-personal data, which includes information lawfully made available from federal, state or local government records, or information in a form that does not, own its own, permit direct association with you for any purpose pointed in this Privacy Policy. For example, we may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where the Website, Services or Application is used so that we can better understand customer behavior and improve our products, services, and advertising. If a relevant law or regulation treats all or part of this information as personal, we would treat it the same way.

We may collect information regarding customer activities on our Website, Services, and an Application and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our Website, Services, or the Application are of most interest. Aggregated data is considered information in a form that does not, own its own, permit direct association with any specific individual.

We may collect and store details of how you use our Application(s), Services, and the Website including search queries. This information may be used to improve the relevancy of results provided by the Application, Services, and the Website. Except in limited instances to ensure quality of the Application, Services, and our Website over the Internet, such information will not be associated with your IP address.

If combine information or data in a form that does not, own its own, permit direct association with any specific individual with Personal Information or Personal Data, the combined information will be treated as Personal Information or Personal Data for as long as it remains combined.

We use log data to understand and analyze trends, to administer our Website, to learn about user behavior on our Website, to improve our product and services, and to gather demographic information about our user base as a whole. As this type of information does not, own its own, permit direct association with any specific individual, we may use it in our marketing and advertising services.

In some of our e-mail messages, we use a “click-through URL” linked to content on our Website, our Services or our Application(s). When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our Website, Service, or the Application. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the e-mail messages.

Pixel tags enable us to send e-mail messages in a format that users can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to users.

To provide location-based services we may collect, use, and share precise location data, including the real-time geographic location of your access to our Website and/or the Application. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. We may be obliged to handle such information as Personal Information or Personal Data in order to comply with a relevant law or regulation.

Promotional Offers and other Marketing Purposes. We may use Information obtained from you (e.g. your contact information) for marketing purposes. For example, by subscribing to our newsletter you may receive tips and announcements straight to your e-mail account. We may also send you promotional material about our Application(s), the Services, or Website, or our partners’ services (that we believe may interest you).

You may choose not to receive our promotional or marketing e-mails (all or any part thereof) by clicking on the “unsubscribe” link in the e-mails that you receive from us. Moreover, in order to unsubscribe, you can contact us at any time via e-mail at bertozzi.jacopo@gmail.com.

Please note that even if you unsubscribe from our promotional or marketing e-mails, we may continue to send you Service-related notifications, or reply to your queries and feedback you provide us. Moreover, we may still use and share your Information with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you, and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data or Personal Information are authorized to use your Personal Data or Personal Information only as necessary to provide these non-marketing services.

We may also use information about the content you view, the date and time that you view this content, the Services you purchase, or your location information associated with your IP address. We use these types of Information to serve you more relevant advertisements. We collect information about where you saw the ads we serve you and what ads you clicked on.

For example, you may see certain ads on our Website or other websites because we contract with third-party companies to target our ads based on Information we or they have collected, including Information that was collected through automated means (such as Cookies). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts. You can read more about these companies and their services in Section 4 [DISCLOSURE OF YOUR INFORMATION] and Section 6 [INTEGRATED THIRD PARTIES, SOCIAL MEDIA & WIDGETS], below.

Protection of our Interests, Safety. We may use your Personal Information or Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of Applications, Services and/or our Website and protect the rights and property of our Company, its users and/or partners.

Compliance with Legal and Regulatory Requirements. We may also use/disclose your information collected by us in order to comply with applicable legal requirements, industry standards, and our policies. We may disclose your Information in situations that we believe to be: (i) emergencies involving potential threats to the physical safety of any person or property if we believe that your Information in any way relates to that threat; (ii) you use our Services, our Website or Application(s) in a way that we believe may be illegal or inappropriate.

Business Process Management. We may provide some of your Personal Information or Personal Data to our partners, contractors, affiliates if it is necessary for performing agreements between you and us (e.g. agreements, orders, etc.) or if it is an essential part of how the services work (to the extent permitted under a relevant law or regulation).

4. DISCLOSURE OF YOUR INFORMATION

Babelpeak will not pass your Personal Data to third parties, with the exception of when it is required by functions of the Application(s)s or Services — e.g., sharing to Facebook or Twitter, and in that case, the privacy of data transmitted is guaranteed by those third parties, which may or may not request the right to use your Personal Data or Personal Information; if you access our Services via third-party sites, products, or services, we may provide information on your body parameters to such third-parties for the aim of the provision of such third-party services to you. For example, in case if you get access to our Services via a third-party site, such as an online store, we will provide information on your body parameters to such third-party for the aim of the provision of such third-party services to you — e.g., selection of clothes according to your parameters, or it is required by law (or regulation) or with your explicit consent.

Service providers. We may use a third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors, etc.) to perform certain business-related functions. Examples of such functions include, but are not limited to: data storage services, database maintenance services, mailing, and payment processing. When we use such third party to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will make sure that each third party will be required by contract to keep such Personal Data confidential, make necessary steps to protect such Personal Data, and not to use it for any purpose other than providing services to us and other provisions as required by law or regulation.

We use the following third-party service providers:

Service	Service Provider	Purpose	Link to Service Provider’s Privacy Policy
Runpod.io	Runpod	Computation	https://www.runpod.io/legal/privacy-policy
WebDock.io	Webdock	Server providing	https://www.getwebdock.com/privacy-policy

We may also share your information or data with other service providers for the abovementioned purposes, with which we will establish cooperation.

Before transferring any Personal Data or Personal Information to third party (processor, contractor, affiliate, partner, contractor, supplier, vendor etc.) we shall make reasonable check of such third party regarding its compliance with the applicable law.

Compliance with laws and law enforcement entities. We may disclose Personal Information or Personal Data if required to do so by law or to comply with a legal obligation, or if we believe in good faith that such action is necessary to: (i) protect our rights or property and our customers or (ii) protect the property or safety of users of our Website, Services or Application(s) and the accompanying services, legal owners of our Website, Services or Application(s); (iii) or any third party. If we will be required by law to disclose any of your Personal Information or Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, court or administrative order.

Business Transfers. We reserve the right to sell, assign, or transfer our business or assets. In any such event or similar event, including but not limiting to a corporate sale, merger, reorganization, dissolution, etc., Personal Information or Personal Data may be part of the transferred assets. You acknowledge that such transfers may occur and that any acquirer or successor of ours may continue to use your Personal Information or Personal Data as set forth in this Privacy Policy.

Other Third Parties. We may also make certain information in a form that does not, own its own, permit direct association with you available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, the functionality available through the Service, statistics and other use. This is information is not associated with any Personal Information or Personal Data that can identify any individual person.

California residents may have additional rights and choices. To learn more about your California privacy rights, please see our Privacy Notice for California Residents.

European residents may have additional rights and choices. To learn more about your European privacy rights, please see our Privacy Notice for European Residents.

5. THIRD-PARTY COLLECTION OF INFORMATION OR DATA

For the convenience of our users and visitors, our Website, Application(s), Services, and/or e-mails may contain links to other sites, which are subject to different privacy policies. This Privacy Policy will not apply to any other site’s, applications, and/or services that are managed by us or otherwise are under our control, unless expressly pointed.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage our users to be aware when they leave our Website, Services or Application(s) and to read the privacy statements of any other sites or apps that collect personally identifiable information (i.e., Personal Information or Personal Data).

6. INTEGRATED THIRD PARTIES, SOCIAL MEDIA & WIDGETS

Our Website, Services, or Application(s) include (or may include) social media features and widgets (the “Features” or “Feature”). These Features may collect your IP address, which page you are visiting on our Website, Application(s), Services, and may set Cookies to enable a Feature to function properly. Features are either hosted by a third party or hosted directly on our Website and/or the Application. Your interactions with these Features are governed by the privacy policy of the company providing it.

When you use our Website, Services, or Application(s), or post on our Website or an Application forum, chat room, board, or social networking service (if any), the Personal Information or Personal Data and other content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Information or Personal Data you choose to share or submit in these instances. For example, if you post your name and e-mail address in a forum posting, that information is public. Please take care when using these Features. By submitting actions pointed above, unless otherwise prohibited by law or regulation, you grant us, our partners and affiliates a non-exclusive, unlimited, worldwide, royalty-free license to use, display, perform, copy, transmit, distribute, promote, alter, modify, manipulate or create derivative works with materials, texts, words, impressions and other information provided by you in such a way.

7. SURVEYS & CONTESTS

From time-to-time, we may receive information from you via surveys or contests. Participation in these surveys or contests is voluntary and you may choose whether or not to participate. Information requested may include contact information (such as name and address), demographic information (such as zip code, age) and business information (types and amounts of Services used, targeting specifications). Survey information will be used for purposes of monitoring and/or improving the use and satisfaction of our Website, Application(s), and Services and to notify the winners and award prizes (if any).

8. ACCESSING, CORRECTING, AND DELETING YOUR INFORMATION OR DATA. DATA RETENTION

We may retain your Personal Data or Personal Information for as long as is required to fulfill the purposes of the processing of the Personal Data or Personal Information as outlined in this Policy, or for a longer period as required according to the applicable law. Retention period will be determined considering the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Information at the earliest reasonable time. In general, we store your Personal Data up to 3 years and make a revision of it after that period. During such revision, we may either delete all of your Personal Data or keep it collected for the next 10 years if: we are providing you Services; you use the Application and Our Website; we are in the middle of dispute or you are our debtor; such information is still necessary for the purposes we collected it. We can delete your Personal Data or Personal Information any time and not wait for such period to end if purpose we collected it for no longer applies. We make no warranties your Personal Data will be available for any specific period of time (3 years, 10 years, or less or more etc.). Please consider that we have no obligations to notify you when deleting your Personal Data or Personal Information and can do it at our sole discretion.

It should be noted that you have certain rights in relation to your Personal Data or Personal Information. You may send us an e-mail at bertozzi.jacopo@gmail.com in order to exercise any of your rights regarding your Personal Data or Personal Information (to request access to, correct or delete any Personal Information or Personal Data that we have collected or you have provided to us, to restrict or object processing).

Please note that we cannot delete your Personal Information or Personal Data except by also deleting your user account. We may not make accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional rights and choices. To learn more about your California privacy rights, please see our Privacy Notice for California Residents.

European residents may have additional rights and choices. To learn more about your European privacy rights, please see our Privacy Notice for European Residents.

9. DATA SECURITY

We will maintain industry-standard physical, electronic and procedural safeguards designed to protect data in our possession from loss, misuse, any use not pointed in this Privacy Policy and unauthorized access. Wherever we collect Personal Information or Personal Data, we make all commercially reasonable efforts to provide the necessary level of encryption (to protect data both at rest and in transit), Anonymisation/Anonymization (defined below), and/or Pseudonymisation/Pseudonymization (defined below), as required by applicable law or regulation. We may provide such security measures by using third parties (e.g., processors, contractors, etc.). For purposes of this Privacy Policy, “Anonymisation” or “Anonymization” are defined as the processing data with the aim of irreversibly preventing the identification of the individual to whom it relates. For purposes of this Privacy Policy “Pseudonymisation” or “Pseudonymization” are defined as replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified.

The safety and security of your information also depends on you. Do not to disclose your contact information, password, or other data that allows or enables unauthorized access to our Website, Application(s), or Services, and keep this information confidential. We urge you to be careful about giving out information in public areas of the Website like message boards, forums, or chat rooms. The information you share public areas may be viewed by any user of the Website.

Unfortunately, no method of transmission or method of electronic storage is 100% secure. Although we do our best to protect your Personal Information and Personal Data, we cannot guarantee that our Website or the data stored during your use of our Application(s) or Service(s) is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that our Website, Application(s) or Services are or will be protected from all viruses, security threats, or other vulnerabilities or that your Personal Information or Personal Data, and other information, will always be secure.

Privacy Safeguards within the Company. To make sure your Personal Information Personal Data is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Company. Only employees who need your Personal Information or Personal Data to perform a specific job (e.g. billing or customer service) are granted access to relevant personally identifiable information (Personal Data or Personal Data). All of our employees sign relevant non-disclosure agreement (NDA) and our security system is designed to ensure the possibility of identification of all the employees who had access/accessed Personal Information or Personal Data of our users. Access to the environments that contain end-users’ data requires a series of authentication and authorization controls, including multi-factor authentication (MFA).

Information Transferred to Third Parties. Before transferring any Personal Information or Personal Data to third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors, etc.) we shall make a reasonable check of such third party regarding its compliance with applicable laws or regulations.

Information Received from Third Parties. In cases where we receive your Personal Information or Personal Data from/via a third-party (i.e., controller of such data) during the fulfillment of contractual obligations, we act as a processor. In order to secure such Personal Data, we treat it with the same level of security as we treat Personal Data as if it were collected by us, as provided in this Privacy Policy (if applicable or if we are not obliged by the relevant contract to provide additional security measures). Additionally, we do not store such received Personal Data for a period longer than it is necessary for the fulfillment of the relevant contract with a third party who provided us with your Personal Data.

Storage of Personal and Other Information; Consent for Storage Outside Your Country of Residence. We will make commercially reasonable efforts to store the Personal Information or Personal Data of individuals in the regions where they live or operate in cases if we are required by law or regulation to do so. If storing of Personal Information or Personal Data in such way is not commercially reasonable, we will ensure that third parties who assist us with the storage of Personal Information or Personal Data (e.g., vendors, processors, etc.) are bound by an agreement that contains obligations of the third party to provide at least minimum necessary level of security and other provisions as required by law or regulation. Additionally, we will ensure that such an agreement contains the obligation of the third party to adopt necessary provisions into his agreements with other third parties (e.g., sub-contractors, sub-processors, etc.), if any. By using our Website, Application(s) or Services, you give us your unambiguous consent to store your Personal Data (or information that does not identify you individually, if applicable) outside of your country of residence (registration, domicile, centre of vital interests, economic region, etc.). You may request us to provide you with details concerning the safeguards employed by us to protect the Personal Information or Personal Data about you that is transferred to a third country, by contacting us via e-mail at bertozzi.jacopo@gmail.com.

10. CHANGES TO OUR PRIVACY POLICY

We will post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information or Personal Data, we will notify you through a notice on our Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.

11. NO RIGHTS OF THIRD PARTIES

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any Personal Data relating to users of the Site.

12. CONTACT INFORMATION

If you have any questions, concerns or complaints regarding the way we collect and handle your Personal Information or Personal Data, or if you have any thoughts or questions about this Privacy Policy, or regarding contact person (representative) for compliance with the relevant law or regulation, you can contact us at:

bertozzi.jacopo@gmail.com