App Privace Policy

We believe you should always know what data we collect from you and how we use it, this privacy statement explains how Basbes mobile application collects, uses, and discloses information about you to make your user experience better.

This App Privacy Policy was last updated November 1, 2020‎ and applies beginning November 1, 2020‎.

You are probably reading this because an Application you downloaded uses our Services and directed you to read this Privacy Statement so you can understand how we collect, use and share information about you when you use the Application, our Services, or otherwise interact with us, as well as what your choices are regarding the collection, use and sharing of your information.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

Who we are

Basbes Inc. (“Basbes,” “we,” “us,” or “our”) provides messaging services via our ‎mobile applications with messaging functionality (“Application”) .

Where This Privacy Policy Applies

This Privacy Statement explains how Basbes ‎collects, uses, and discloses information about you when you access or use our mobile Application located ‎at Google Play App Store, and other products and services that link to this Privacy ‎Policy (collectively, the “Services”). To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy — not this Privacy Policy — applies. For information about how Basbes collects, uses, and ‎discloses information about you when you access or use our Website, please ‎see our Website Privacy Policy. ‎

Privacy Policy Changes

Because we’re always looking for new and innovative ways to enhance our Services, we may change this Privacy Policy from time to time. If we make changes, we will notify you ‎by posting the updated policy on the Services; the “Last Updated” legend above indicates when ‎this Privacy Policy was last revised. In some cases, we may provide you with additional notice, ‎such as adding a statement to our homepage or sending an email notification to you. Any ‎changes will become effective when we post the revised Privacy Policy. Your use of the ‎Services following such changes means that you acknowledge the updated Privacy Policy.‎

Policy summary

Personal Data collected for the following purposes and using the following services:

  • Device permissions for Personal Data access
    • Device permissions for Personal Data access
      • Personal Data: Camera permission, Microphone permission, Storage permission and Social media accounts permission.
  • Registration and authentication
    • Google OAuth, Twitter OAuth and Facebook Authentication
      • Personal Data: various types of Data as specified in the privacy policy of the service.
    • Firebase Authentication
      • Personal Data: email address; first name; last name; password; social media accounts
    • Direct registration
      • Personal Data: Cookies; email address; first name; last name; password
  • Access to third-party accounts
    • Facebook account access
      • Permissions: Cookies; Full name; Email; Photos
    • Twitter account access
      • Personal Data: Cookies; email address; first name; last name
    • Gmail account access
      • Personal Data: Cookies; email address; first name; last name
  • Hosting and backend infrastructure
    • Firebase Cloud Functions
      • Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
    • Firebase Realtime Database
      • Personal Data processed: Usage Data; User’s profile information; Messages sent between users; various types of Data as specified in the privacy policy of the service.
    • Firebase Cloud Storage
      • Personal Data processed: Usage Data; User’s photos; User’s videos; various types of Data as specified in the privacy policy of the service.
  • Platform services and hosting
    • Google Play Store
      • Personal Data: Usage Data
  • Sending messages
    • Firebase Cloud Messaging and Firebase Notifications
      • Personal Data: various types of Data as specified in the privacy policy of the service
  • Social features
    • Firebase Dynamic Links and Firebase Invites
      • Personal Data: various types of Data as specified in the privacy policy of the service
  • Content performance and features testing (A/B testing)
    • Firebase Remote Config
      • Personal Data: various types of Data as specified in the privacy policy of the service
  • Analytics
    • Google Analytics for Firebase
      • Personal Data: Application opens; Application updates; Cookies; device information; first launches; geography/region; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
    • Facebook Analytics for Apps
      • Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
    • Crashlytics
      • Personal Data: Crash information; device information; Universally unique identifier (UUID)
  • Contacting the User
    • Contact form
      • Personal Data: email address; first name; last name; phone number.
  • Mailing list or newsletter
    • Personal Data: email address; first name; last name; phone number; Cookies
  • Displaying content from external platforms
    1. Google Fonts
      • Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service.
    2. SPAM protection
      • Google reCAPTCHA
        • Personal Data: Cookies; Usage Data
    3. Tag Management
      • Google Tag Manager
        • Personal Data: Usage Data

Full policy

What data we collect

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Camera permission, Microphone permission, Storage permission and Social media accounts permission; Cookies; Usage Data; first name; last name; phone number; email address; password; Personal photo; Birth date; Gender; Relationship status; Work; education; Hobbies; social accounts’ links; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; Universally unique identifier (UUID); Crash information; geography/region; number of Users ; number of sessions; session duration; Application opens; Application updates; first launches; operating systems.

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

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

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

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

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

How we collect your Data

Information you give us

You choose to give us certain information when using our services. This includes:

  • When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your full name, personal photo, gender, relationship status and date of birth.
  • When you complete your profile, you can share with us additional information, such as details on your personality, Relationship status, horoscope, lifestyle, interests, hobbies, work, education, links to your social media profiles and other details about you, as well as content such as your photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your, sexual orientation, religious beliefs and political views. By choosing to provide this information, you consent to our processing of that information.
  • When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
  • When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
  • If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
  • If you contact us you provide information such as your name, phone and email.
  • If you subscribe to our newsletter you provide information such as your name, phone and email.
  • Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

  • Other Users Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
  • Social Media You may be able to use your social media login (such as Facebook Login) to create and log into your Basbes account. This saves you from having to remember yet another user name and password.
  • Other Partners We may receive info about you from our partners, for instance where Basbes ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

Information collected when you use our Services

When you use our services, we collect information about which features you’ve used, how you’ve used them, which pages you have visited and the devices you use to access our services. See below for more details:

  • Usage Information We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
  • Device information We collect information from and about the device(s) you use to access our services, including:
    • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
    • information on your wireless and mobile network connection, like your service provider and signal strength.
    • information on device sensors such as accelerometers, gyroscopes and compasses.
    • information on device sound level, as We use sound to search for users around you.
  • Other information with your consent If you give us permission to your microphone, you can search for nearby users using ultrasonic sound. The access to your microphone never happens on background, We only use it when you are searching for users around you. If you decline permission for us to access your microphone, we will not use it, in this case you will not be able to search for nearby users, but you still can be visible to others. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

Cookies and Other Similar Data Collection Technologies

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing app installs, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features.

We may, or we may allow others to, provide analytics services and serve advertisements on our behalf across the Internet and in the Application. We or these entities may use cookies, web beacons, user resettable device identifiers and other technologies to collect information about your use of the Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in Applications, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.

You may stop us from collecting further information for marketing and advertising purposes by disabling the Advertising ID on your mobile device. For more information on how to manage the privacy settings in your mobile device see, for example: https://www.apple.com/privacy/manage-your-privacy/ for your iOS device. For Android devices, see “Limit Ad Tracking” in your device’s privacy settings. You may also contact the manufacturer of your mobile device for instructions about opting out from ad tracking.

Even if you disable the Advertising ID in your mobile device, keep in mind that you may still receive (i) content, including branded content, from use of our Services, provided that our content recommendations will not be personalized to you, (ii) interest based advertising, including from third parties to whom your Advertising ID had been previously disclosed and (iii) advertising from third parties, though such advertising may not be based on your interests and preferences. For any privacy or data-protection-related questions, please contact the Owner..

Mode and place of processing the Data

Methods of processing

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

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

Legal basis of processing

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

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

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

Place

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

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

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

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

Retention time

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

Therefore:

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

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

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

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Contacting the User, Content commenting, Displaying content from external platforms , SPAM protection and Tag Management.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

Depending on the User’s specific device, this Application may request certain permissions that allow it to access the User’s device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Microphone permission

Allows accessing and recording microphone audio from the User’s device.

Social media accounts permission

Used for accessing the User’s social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

This Application requests certain permissions from Users that allow it to access the User’s device Data as described below.

Device permissions for Personal Data access (this Application)

This Application requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.

Personal Data processed: Camera permission; Microphone permission; Social media accounts permission; Storage permission.

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

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Direct registration (this Application)

The User registers by filling out the registration form and providing the Personal Data directly to this Application.

Personal Data processed: Cookies; email address; first name; last name; password.

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

Firebase Authentication

Firebase Authentication is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

Personal Data processed: email address; first name; last name; password; social media accounts .

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Facebook Authentication

Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Application is accessed from, and is connected to the Facebook social network.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Twitter OAuth (Twitter, Inc.)

Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.

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

Place of processing: United States – Privacy Policy. Privacy Shield participant.

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

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

Google OAuth

Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, and is connected to the Google network.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.

These services are not activated automatically, but require explicit authorization by the User.

Facebook account access (Facebook, Inc.)

This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.

Permissions asked: About Me; Cookies; Email; Photos.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

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

Twitter account access (Twitter, Inc.)

This service allows this Application to connect with the User’s account on the Twitter social network, provided by Twitter, Inc.

Personal Data processed: Cookies; email address; first name; last name; photos.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

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

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

Google account access (Twitter, Inc.)

This service allows this Application to connect with the User’s account on Google, provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, and is connected to the Google network.

Personal Data processed: Cookies; email address; first name; last name.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics for Firebase

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.
In order to understand Google’s use of Data, consult Google’s partner policy.

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data processed: Application opens; Application updates; Cookies; device information; first launches; geography/region; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Facebook Analytics for Apps

Facebook Analytics for Apps is an analytics service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Application is accessed from,

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Crashlytics

This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.

Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

Personal Data processed: Crash information; device information; Universally unique identifier (UUID).

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.

Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Google Play Store

This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Firebase Cloud Messaging

This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.

Users must be aware that disabling push notifications may negatively affect the utility of this Application.

Firebase Cloud Messaging is a message sending service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Firebase Notifications

Firebase Notifications is a message sending service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Firebase Dynamic Links

Firebase Dynamic Links is a social feature provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Firebase Invites

Firebase Invites is a social feature provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that enables Users to share this Application. The sharing may contain referral codes, or content from within this Application and may be done via email or SMS. Sharing is tracked with Google Analytics for Firebase, which informs the Owner that the User has opened or installed this Application via invite.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Contact form (this Website)‎

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: email address; first name; last name; phone number.

Category of personal data collected according to CCPA: identifiers.

Mailing list or newsletter (this Application)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data processed: Cookies; email address; first name; last name; phone number.

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

This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information.

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.

This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

Pages on this Application may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content even when Users do not use it, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Google Fonts

Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that allows this Application to incorporate content of this kind on its pages.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.

Firebase Remote Config

Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

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

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Firebase Cloud Functions

Firebase Cloud Functions is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

Firebase Realtime Database

Firebase Realtime Database is a hosting and database service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

Personal Data processed: Usage Data; User’s profile information; Messages sent between users; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

Firebase Cloud Storage

Firebase Cloud Functions is a hosting and backend service for files provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

Personal Data processed: Usage Data; User’s photos; User’s videos; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

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

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

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

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

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

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to “The California Consumer Privacy Act of 2018” (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

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

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

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Applicationand features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an Application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.

Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

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

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

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

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

  • the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
  • in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
    • for sales, the personal information categories purchased by each category of recipient; and
    • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

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

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the contact details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

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

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

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

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

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

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Information for Users residing in Brazil

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

How and when we are expected to handle your request

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

  • your consent to the relevant processing activities;
  • compliance with a legal or regulatory obligation that lies with us;
  • the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
  • studies conducted by research entities, preferably carried out on anonymized personal information;
  • the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
  • the exercising of our rights in judicial, administrative or arbitration procedures;
  • protection or physical safety of yourself or a third party;
  • the protection of health – in procedures carried out by health entities or professionals;
  • our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
  • credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

  • obtain confirmation of the existence of processing activities on your personal information;
  • access to your personal information;
  • have incomplete, inaccurate or outdated personal information rectified;
  • obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
  • obtain information on the possibility to provide or deny your consent and the consequences thereof;
  • obtain information about the third parties with whom we share your personal information;
  • obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
  • obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
  • revoke your consent at any time;
  • lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
  • oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
  • request clear and adequate information regarding the criteria and procedures used for an automated decision; and
  • request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

  • when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
  • when the transfer is necessary to protect your life or physical security or those of a third party;
  • when the transfer is authorized by the ANPD;
  • when the transfer results from a commitment undertaken in an international cooperation agreement;
  • when the transfer is necessary for the execution of a public policy or legal attribution of public service;
  • when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Definitions and legal references

Personal Data (or Data)

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

Usage Data

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

User

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

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

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

This Application

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

Service

The service provided by this Application or Website as described in the relative terms (if available) and on this site/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.

Cookies

Small sets of data stored in the User’s device.

How to Contact Us

If you have questions about this Privacy Policy, here’s how you can reach us.

We are more than happy to answer all your questions

Have questions or need help? Use the form to reach out and we will be in touch with you as quickly as possible.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document