This Application collects some Personal Data from its Users.

Users may be subject to different protection standards and broader standards may therefore apply to some. Users can contact the Owner, to learn more about such standards.

This document contains a section dedicated to Users in the European Union and their privacy rights. This document contains a section dedicated to Users in the United States and their privacy rights.

This document contains a section dedicated to Users in Switzerland and their privacy rights. This document contains a section dedicated to Brazilian Users and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

ZingZing Softworks - 18, Si Sinhay, Almaty, Kazakhstan

Owner contact email: ...

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

Usage and Interaction Data: Trackers, Usage Data, Product Interaction, session statistics, session duration, number of sessions.
Device Information: Device information, unique device identifiers for advertising (e.g., Google Advertiser ID or IDFA), operating systems, Universally unique identifier (UUID).
Identifiers: User ID (such as an anonymous Firebase Auth ID, referred to as "Customer ID" within the Application).
Diagnostic Data: Crash data, performance data.
Location Data: Coarse location (e.g., city or country).
Financial Data: Purchase history, payment information (processed by app stores), scan credit balance.
User Content: Photos or videos (submitted for ingredient analysis — processed in-memory and not stored on our servers), ingredient text recognized on-device, customer support data communicated while using the service, feedback text submitted through in-app forms.
Health and Profile Data: Allergies, health conditions (diseases), dietary preferences, pregnancy/nursing status, age range for child profiles, free-text health notes. All profile data is associated with an anonymous Firebase UID and does not contain personally identifiable information such as name or email.
Advertising Data: Data collected by third-party advertising services, including: coarse location, device identifiers, user ID, purchase history, product interaction data, advertising data, and gender signal (female — inferred only when the User marks pregnancy/nursing status in their profile, used solely for ad relevance).

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.

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.

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.

Retention time

Specific Data Retention Periods

Photos and ingredient texts submitted for analysis: Not stored on our servers. All analysis is performed in-memory (stateless processing) and the data is immediately discarded after the result is returned to the User. When the on-device text recognition confidence is high, only the recognized text (not the photo) is transmitted to the server. When no text is detected on-device, no data is transmitted to the server at all.
Photos submitted via report/complaint: Retained for up to 3 months for manual quality review, then permanently deleted.
User profile data (allergies, health conditions, dietary preferences, child profiles, etc.): Retained for as long as the User's account remains active.
Feedback text: Retained for as long as the User's account remains active.
Scan credit balance and usage history: Retained for as long as the User's account remains active.
Inactive accounts: All data associated with accounts that have had no activity for 24 consecutive months is automatically and permanently deleted.
Analytics and diagnostic data: Retained according to the respective third-party provider's retention policies (see "Detailed information on the processing of Personal Data" section).

How Users can request deletion of their Data

Users may request the deletion of all data associated with their account at any time. To do so:

Locate your anonymous Customer ID within the Application (visible in the app navigation drawer and at the bottom of the subscription screen).
Send an email to ... including your Customer ID and a request to delete your data.
The Owner will permanently delete all data associated with that Customer ID within 30 days of receiving the request.

Upon deletion, all profiles, settings, scan credits, feedback history, and any other data linked to the Customer ID are irreversibly removed.

Additionally, inactive accounts are automatically purged after 24 months of inactivity as described above.

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, Advertising, Personalized product analysis, Content performance and features testing (A/B testing), Data transfer outside of the UK, Data transfer outside the EU, Device permissions for Personal Data access, Handling payments, Hosting and backend infrastructure and Infrastructure monitoring.

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

Allows access to the User's Camera.

Detailed information on the processing of Personal Data

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

Analytics

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.

Adapty (Adapty Tech Inc.)

Adapty is a service that provides infrastructure for in-app purchases, subscriptions, and paywall A/B testing. It helps manage user subscription status and provides analytics on purchase events.

If we receive a refund request for an in-app purchase, we may provide Apple with information about the user's in-app purchase activity through Adapty. This could include details such as time since app installation, total app usage time, an anonymous account identifier, whether the in-app purchase was fully consumed, whether it included a trial period, the total amount spent, and the total amount refunded.

Personal Data processed: Purchase history; Trackers; User ID; Usage Data; Device information.

Place of processing: United States – Privacy Policy.

UXCam (UXCam Inc.)

UXCam is an analytics service that helps the Owner understand user behavior by providing session replay, heatmaps, and crash analytics. This helps improve the user experience and identify issues within the application. The camera view is fully blurred in all session recordings to protect user privacy. UXCam is completely disabled if the User withdraws their consent for analytics and tracking via the consent management dialog or the Application settings.

Personal Data processed: Coarse location; Crash data; Device information; Performance data; Trackers; Usage Data; User ID.

Place of processing: United States – Privacy Policy.

Analytics collected directly

This Application uses an internal analytics system that does not involve third parties. Personal Data processed: Trackers; Usage Data.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Appsflyer (AppsFlyer Ltd)

Appsflyer is an analytics and mobile marketing attribution platform. It helps the Owner understand which advertising campaigns bring Users to this Application and analyze their post-install activity. This data is used for advertising performance measurement, analytics, and fraud prevention.

Personal Data processed: Coarse location; Device information; Purchase history; Trackers; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Place of processing: Israel – Privacy Policy – privacy@appsflyer.com.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Google Analytics 4 (Google LLC)

Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

In order to understand Google's use of Data, consult their partner policy and their Business Data page. Personal Data processed: number of Users; session statistics; Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Google Analytics Advertising Reporting Features (Google LLC)

Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

In order to understand Google's use of Data, consult their partner policy and their Business Data page.

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

Place of processing: United States – Privacy Policy – Opt Out.

Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

Google Analytics Demographics and Interests reports (Google LLC)

Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).

Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example). Place of processing: United States – Privacy Policy – Opt Out.

Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

Google Analytics for Firebase (for apps) (Google LLC)

Google Analytics for Firebase (for apps) or Firebase Analytics is an analytics service provided by Google LLC. 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, Performance Monitoring, 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: device information; number of sessions; operating systems; session duration; Trackers; Usage Data. Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

User ID extension for Google Analytics (Google LLC)

Google Analytics on this Application makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device. The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Application. The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.

Personal Data processed: Trackers.

Place of processing: United States – Privacy Policy – Opt Out.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Advertising

This Application uses third-party advertising services to display banner and rewarded video advertisements. Advertising is shown to Users who are not Premium subscribers. Users can earn scan credits by watching rewarded advertisements.

CAS.AI (CleverAdsSolutions LLP)

CAS.AI is an advertising mediation platform that enables the display of advertisements within this Application, including banner ads and rewarded video ads. CAS.AI may collect and process certain data for the purpose of serving relevant advertisements. For Users in the European Union and certain US states, CAS.AI displays a consent management dialog in accordance with GDPR and applicable US privacy laws. Users may modify or withdraw their consent at any time through the Application settings. When consent is withdrawn, advertising-related data collection is disabled.

When the User marks pregnancy/nursing status in their profile, a gender signal ("female") is transmitted to CAS.AI solely for the purpose of improving ad relevance. This signal is anonymous and not linked to any personally identifiable information.

Personal Data processed: Coarse location; Device identifiers; User ID; Purchase history; Product Interaction; Advertising Data; Performance data; Crash data; gender signal (female, only when pregnancy/nursing is marked in the User's profile).

Place of processing: See Privacy Policy.

Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; commercial information; geolocation data.

Content performance and features testing (A/B testing)

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 (Google LLC)

Firebase Remote Config is an A/B testing and configuration service provided by Google LLC. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to the CCPA: identifiers.

Device permissions for Personal Data access

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 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.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Handling payments

Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Payments processed via the Apple App Store (Apple Inc.)

This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.

Personal Data processed: device information; email address; payment info; Trackers; Usage Data. Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

Payments processed via the Google Play Store (Google LLC)

This Application uses a payment service provided by Google LLC that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

Personal Data processed: device information; payment info; Trackers; Usage Data. Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to the CCPA: commercial information; internet or other electronic network activity information.

Hosting and backend infrastructure

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 Firestore (Google Ireland Limited)

Firebase Cloud Firestore is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: Netherlands – Privacy Policy.

Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

Firebase Cloud Functions (Google Ireland Limited)

Firebase Cloud Functions is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: Netherlands – Privacy Policy.

Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

Google Cloud (Google LLC)

Google Cloud is a cloud computing platform provided by Google LLC.

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

Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to the CCPA: identifiers.

Third-Party AI Inference Providers

This Application uses third-party AI inference providers to analyze ingredient compositions from photos or recognized text. The data (ingredient text or, when on-device recognition confidence is insufficient, images of product packaging) is transmitted to these services solely for the purpose of generating an analysis result. The Owner selects inference providers that adhere to a Zero Data Retention (ZDR) policy, meaning that submitted data is not stored, logged, or used for model training by the provider beyond the duration of the inference request. No personally identifiable information (such as name, email, or contact details) is transmitted to these services. Only the content necessary for ingredient analysis (text or image of product packaging) along with anonymous profile parameters (e.g., allergies, age group) required for personalized assessment are sent.

Personal Data processed: Data communicated while using the service (ingredient text or packaging images); anonymous profile parameters (allergies, health conditions, dietary preferences, age range).

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.

Infrastructure monitoring

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

Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: crash data; device information; Universally unique identifier (UUID). Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

Firebase Performance Monitoring (Google LLC)

Firebase Performance Monitoring is a service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. It collects technical performance metrics (such as app startup time, screen rendering, and network request latency) to help diagnose slowdowns and improve stability. Further detail on how Google processes such Data is described in Firebase’s privacy and security information.

Personal Data processed: Performance data; device information; Usage Data. Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Further information about the processing of Personal Data

Equal protection of User Data

This Application shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.

Rights for registered California Users under the age of 18

California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

If a registered User fits that description and posted content on this Application, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

The Service is intended for adults

Users declare themselves to be adult according to their applicable legislation. Minors may not use this Application.

This Application provides a "child profile" feature that allows adult Users (parents or guardians) to configure profiles for their children (with age ranges from 0 to 14+) for the purpose of scanning product compositions on their behalf. Child profiles are managed entirely by the adult User. Children do not access or operate this Application directly. The data entered into child profiles (age range, allergies, dietary restrictions) is stored anonymously and associated only with the adult User's anonymous account.

The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Under no circumstance persons under the age of 13 may use this Application. The child profile feature described above is a tool for parents/guardians and does not constitute access to the Service by minors.

Unique device identification

This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

User identification via a universally unique identifier (UUID)

This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, and may persist across reinstallation depending on the device platform's behavior. The User can view their identifier (referred to as "Customer ID") within the Application.

Consent Management

For Users located in the European Union and certain US states where consent is required by law, this Application displays a consent management dialog (provided by the advertising mediation service) upon first use. This dialog allows Users to grant or deny consent for data collection related to advertising, analytics, and tracking.

Users may modify or withdraw their consent at any time through the Application settings. When consent is fully withdrawn:

Advertising-related data collection and personalized ads are disabled.
UXCam session recording is completely disabled.
Analytics services (Crashlytics, Firebase Performance Monitoring, Google Analytics, AppsFlyer) are configured in accordance with the User's consent choices.
Adapty continues to function for subscription management purposes only, as it is essential for providing the paid service.

Processing of Health-Related Data

This Application allows Users to voluntarily provide health-related information in their profiles, including allergies, health conditions (diseases), dietary restrictions, pregnancy/nursing status, and age-related data for child profiles. This data qualifies as sensitive personal information under various applicable laws.

Legal basis: The processing of this data is based exclusively on the User's explicit, informed consent, provided by voluntarily entering such information into their profile.

Purpose: This data is used solely to provide personalized ingredient analysis — specifically, to determine whether a scanned product composition is compatible with the User's health conditions and restrictions.

Storage: This data is stored anonymously (associated only with an anonymous Firebase UID) and does not contain any personally identifiable information. It is retained while the account is active and automatically deleted after 24 months of inactivity.

Gender signal: When a User marks pregnancy/nursing status in their profile, an anonymous gender signal ("female") is transmitted to the advertising mediation service (CAS.AI) for the sole purpose of ad relevance. This signal is not linked to any personally identifiable information and ceases to be transmitted when the User removes the pregnancy/nursing marking from their profile.

Further Information for Users in the European Union

This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

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.

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.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent. For specific retention periods applicable to each type of data, please refer to the "Specific Data Retention Periods" section of this document.

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 fulfil a legal obligation or upon order of an authority.

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

The rights of Users based on the General Data Protection Regulation (GDPR)

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

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

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. 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 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 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. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including 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.

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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Transfer of Personal Data outside of the European Union

Data transfer abroad based on standard contractual clauses

If this is the condition for Data transfer, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission. This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Transfer of Personal Data outside of the United Kingdom

Data transfer abroad based on standard contractual clauses (UK)

If this is the condition for Data transfer, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.

This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Further information for Users in Switzerland

This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

The rights of Users according to the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of law, including the following: right of access to Personal Data;

right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited); right to receive their Personal Data and have it transferred to another controller (data portability); right to ask for incorrect Personal Data to be corrected.

How to exercise these rights

Transfer of Personal Data outside of Switzerland

Transfer of Data outside of Switzerland based on standard data protection clauses

If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland, if such transfer is carried out according to standard data protection clauses previously approved, established or recognized by the Federal Data Protection and Information Commissioner. This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by Swiss law. For further information, Users are requested to contact the Owner through the contact details provided in this document.

Further information for Users in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in the LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows: your consent to the relevant processing activities;

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

To 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.

Additional information for Users in Brazil

Transfer of personal information outside of Brazil based on contracts and other legal means

We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.

To do so, we may use one of the following legal means:

specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification; standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD; global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification; seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.

Further information for Users in the United States

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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

Internet or other electronic network activity information

Identifiers

Commercial information

Audio, electronic, visual, thermal, olfactory, or similar information

Inferences drawn from other personal information

You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

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 Application and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information; the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you; the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information; the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible; the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.

the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising; The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have

The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;

The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information.

Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have

The right to opt out of the processing of your Personal Information for Targeted Advertising; The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

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

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

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

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. 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 them.

Additional information for Users in the United States

We do not collect Personal Information about California consumers below the age of 16

We do not knowingly collect Personal Information of California consumers who are below the age of 16 nor do we Sell or Share it.

We do not collect Personal Information about Users below the age of 13 in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana

We do not knowingly collect Personal Information of Users who are below the age of 13 nor do we Sell or process their Information for Targeted Advertising purposes.

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) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

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

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.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

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.

Sensitive Personal Information

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

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 Processor)

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

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this 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 as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

Targeted advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)

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

Cookie

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

Tracker

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

Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to this Application, if not stated otherwise within this document. Latest update: May 13, 2026