Privacy Policy

1. Automatic collection of information

When you open the Website, our servers automatically record information that your browser
sends. This data may include information such as your device’s IP address, browser type, and
version, operating system type and version, language preferences or the webpage you were
visiting before you came to the Website and Services, pages of the Website and Services that you
visit, the time spent on those pages, information you search for on the Website, access times and
dates, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish
statistical information regarding the usage and traffic of the Website and Services. This statistical
information is not otherwise aggregated in such a way that would identify any particular User of
the system.

2. Use and processing of collected information

We act as a data controller and a data processor when handling Personal Information, unless we
have entered into a data processing agreement with you in which case you would be the data
controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We
act in the capacity of a data controller when we ask you to submit your Personal Information that
is necessary to ensure your access and use of the Website and Services. In such instances, we are
a data controller because we determine the purposes and means of the processing of
Personal Information.
We act in the capacity of a data processor in situations when you submit Personal Information
through the Website and Services. We do not own, control, or make decisions about the submitted
Personal Information, and such Personal Information is processed only in accordance with your
instructions. In such instances, the User providing Personal Information acts as a data controller.
In order to make the Website and Services available to you, or to meet a legal obligation, we may
need to collect and use certain Personal Information. If you do not provide the information that
we request, we may not be able to provide you with the requested products or services. Any of the
information we collect from you may be used for the following purposes:

• Respond to inquiries and offer support
• Protect from abuse and malicious users
• Run and operate the Website and Services

Processing your Personal Information depends on how you interact with the Website and
Services, where you are located in the world and if one of the following applies: (a) you have given
your consent for one or more specific purposes; (b) provision of information is necessary for the
performance of this Policy with you and/or for any pre-contractual obligations thereof; (c)
processing is necessary for compliance with a legal obligation to which you are subject; (d)
processing is related to a task that is carried out in the public interest or in the exercise of official
authority vested in us; (e) processing is necessary for the purposes of the legitimate interests
pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to
such processing by opting out, without having to rely on consent or any other of the legal bases.
In any case, we will be happy to clarify the specific legal basis that applies to the processing, and
in particular whether the provision of Personal Information is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.

3. Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any
Service you have requested, we may share your non-personally identifiable information with our
contracted companies, and service providers (collectively, “Service Providers”) we rely upon to
assist in the operation of the Website and Services available to you and whose privacy policies
are consistent with ours or who agree to abide by our policies with respect to your information.
We will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to
perform services on our behalf or comply with legal requirements. Service Providers are given the
information they need only in order to perform their designated functions, and we do not
authorize them to use or disclose any of the provided information for their own marketing or other
purposes.

4. Retention of information

We will retain and use your Personal Information for the period necessary to comply with our legal
obligations, to enforce our Policy, resolve disputes, and unless a longer retention period is
required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after
you update or delete it, but not in a manner that would identify you personally. Once the retention
period expires, Personal Information 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 the
expiration of the retention period.

5. Cookies

Our Website and Services use “cookies” to help personalize your online experience. A cookie is a
text file that is placed on your hard disk by a web page server. Cookies cannot be used to run
programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only
be read by a web server in the domain that issued the cookie to you.
We may use cookies to collect, store, and track information for security and personalization, and
for statistical purposes. Please note that you have the ability to accept or decline cookies. Most
web browsers automatically accept cookies by default, but you can modify your browser settings
to decline cookies if you prefer.

6. Data Analytics

Our Website and Services may use third-party analytics tools that use cookies, web beacons, or
other similar information-gathering technologies to collect standard internet activity and usage
information. The information gathered is used to compile statistical reports on User activity such
as how often Users visit our Website and Services, what pages they visit and for how long, etc. We
use the information obtained from these analytics tools to monitor the performance and improve
our Website and Services. We do not use third-party analytics tools to track or to collect any
personally identifiable information of our Users and we will not associate any information
gathered from the statistical reports with any individual User.

7. Privacy of children

We do not knowingly collect any Personal Information from children under the age of 18. If you
are under the age of 18, please do not submit any Personal Information through the Website and
Services. If you have reason to believe that a child under the age of 18 has provided Personal
Information to us through the Website and Services, please contact us to request that we delete
that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help
enforce this Policy by instructing their children never to provide Personal Information through the
Website and Services without their permission. We also ask that all parents and legal guardians
overseeing the care of children take the necessary precautions to ensure that their children are
instructed to never give out Personal Information when online without their permission.

8. Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do
not want to have your online activity tracked. Tracking is not the same as using or collecting
information in connection with a website. For these purposes, tracking refers to collecting
personally identifiable information from users who use or visit a website or online service as they
move across different websites over time. How browsers communicate the Do Not Track signal is
not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to
Do Not Track signals communicated by your browser. Even so, as described in more detail
throughout this Policy, we limit our use and collection of your Personal Information. For a
description of Do Not Track protocols for browsers and mobile devices or to learn more about the
choices available to you, visit internetcookies.com.

9. Social media features

Our Website and Services may include social media features, such as the Facebook and Twitter
buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media
Features may collect your IP address, what page you are visiting on our Website and Services, and
may set a cookie to enable Social Media Features to function properly. Social Media Features are
hosted either by their respective providers or directly on our Website and Services. Your
interactions with these Social Media Features are governed by the privacy policy of their
respective providers.

10. Email marketing

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are
committed to keeping your email address confidential and will not disclose your email address to
any third parties except as allowed in the information use and processing section. We will
maintain the information sent via email in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all emails sent from us will clearly state who the email is
from and provide clear information on how to contact the sender. You may choose to stop
receiving our newsletter or marketing emails by following the unsubscribe instructions included in
these emails or by contacting us.

11. Links to other resources

The Website and Services contain links to other resources that are not owned or controlled by us.
Please be aware that we are not responsible for the privacy practices of such other resources or
third parties. We encourage you to be aware when you leave the Website and Services and to read
the privacy statements of each and every resource that may collect Personal Information.

12. Information security

We secure information you provide on computer servers in a controlled, secure environment,
protected from unauthorized access, use, or disclosure. We maintain reasonable administrative,
technical, and physical safeguards in an effort to protect against unauthorized access, use,
modification, and disclosure of Personal Information in our control and custody. However, no data
transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (a) there
are security and privacy limitations of the Internet which are beyond our control; (b) the security,
integrity, and privacy of any and all information and data exchanged between you and the Website
and Services cannot be guaranteed; and (c) any such information and data may be viewed or
tampered with in transit by a third party, despite best efforts.

13. Data breach

In the event we become aware that the security of the Website and Services has been
compromised or Users’ Personal Information has been disclosed to unrelated third parties as a
result of external activity, including, but not limited to, security attacks or fraud, we reserve the
right to take reasonably appropriate measures, including, but not limited to, investigation and
reporting, as well as notification to and cooperation with law enforcement authorities.
In the event of a data breach, we will make reasonable efforts to notify affected individuals if we
believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is
otherwise required by law. When we do, we will post a notice on the Website, send you an email.
In jurisdictions where required, we may also report the breach to relevant authorities in
accordance with applicable data protection regulations.

14. Changes and amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any
time at our discretion. When we do, we will post a notification on the main page of the Website,
send you an email to notify you. We may also provide notice to you in other ways at our discretion,
such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised
Policy unless otherwise specified. Your continued use of the Website and Services after the
effective date of the revised Policy (or such other act specified at that time) will constitute your
consent to those changes. However, we will not, without your consent, use your Personal
Information in a manner materially different than what was stated at the time your Personal
Information was collected.

15. Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By
accessing and using the Website and Services and submitting your information you agree to be
bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not
authorized to access or use the Website and Services.

16. Contacting us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold
about you, or if you wish to exercise your rights, we encourage you to contact us using the
contacts bellow.
We will attempt to resolve complaints and disputes and make every reasonable effort to honor
your wish to exercise your rights as quickly as possible and in any event, within the timescales
provided by applicable data protection laws.
If you believe your concerns have not been adequately addressed, you may escalate the matter to
the appropriate data protection authority in your region, in accordance with applicable privacy
laws.