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LEGAL

Privacy Policy

Updated December 15, 2021

Privacy Policy of releese

Releese collects some Personal Data from its Users.

This document contains a section dedicated to California consumers and their privacy rights.

This document contains a section dedicated to Virginia consumers 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

RELEESE INNOVATIONS LTD. - 2030 rue de Vitre, Terrebonne, Quebec, Canada J6X3M9

Owner contact email: help@releese.io

Types of Data collected

Among the types of Personal Data that releese collects, by itself or through third parties, there are: Usage Data; Trackers; email address; Universally unique identifier (UUID); unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data; device information; purchase history; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; first name; last name; phone number; username; password; social media accounts ; gender; date of birth; physical address; company name; country; Email; Data communicated while using the service; geographic position; workplace; number of sessions; billing address; language; payment info; profession; county; ZIP/Postal code; city; VAT Number; fax number; state; field of activity; User ID; number of employees; website; Data communicated in order to use the Service.

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 releese.
Unless specified otherwise, all Data requested by releese is mandatory and failure to provide this Data may make it impossible for releese to provide its services. In cases where releese 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 releese or by the owners of third-party services used by releese 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 releese and confirm that they have the third party's consent to provide the Data to 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 releese (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 of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow 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: Handling payments, Displaying content from external platforms, Tag Management, Remarketing and behavioral targeting, Advertising, Analytics, Registration and authentication, Hosting and backend infrastructure, SPAM protection, Managing contacts and sending messages, User database management, Managing landing and invitation pages, Managing support and contact requests, Handling activities related to productivity, Heat mapping and session recording, Contacting the User, Data transfer outside the EU, Data transfer outside of the UK and Registration and authentication provided directly by releese.

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”.

Detailed information on the processing of Personal Data

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

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on releese, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside releese. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section How to opt-out of interest-based advertising in this document.

Microsoft Advertising (Microsoft Corporation)

Microsoft Advertising is an advertising service provided by Microsoft Corporation.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

Google Ad Manager

Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to understand Google's use of Data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of releese and User behavior concerning ads, products and services offered.

Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

Facebook Lookalike Audience

Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of releese or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.

Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

LinkedIn Ads

LinkedIn Ads is an advertising service provided by LinkedIn Ireland Unlimited Company or by LinkedIn Corporation, depending on how the Owner manages the Data processing.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

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.

Twitter Ads conversion tracking (Twitter, Inc.)

Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on releese.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Microsoft Advertising Universal Event Tracking (Microsoft Corporation)

Microsoft Advertising Universal Event Tracking is an analytics service provided by Microsoft Corporation that connects data from the Microsoft Advertising network with actions performed on releese.

Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Facebook Analytics for Apps

Facebook Analytics for Apps is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing,

Personal Data processed: Tracker; 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.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

MixPanel (MixPanel)

MixPanel is an analytics service provided by Mixpanel Inc.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google Analytics

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of releese, 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.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

TikTok conversion tracking

TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc., TikTok Information Technologies UK Limited , Bytedance, TikTok Technology Limited or by TikTok Pte. Ltd., depending on how the Owner manages the Data processing, that connects data from the TikTok advertising network with actions performed on releese. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of releese.

Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; India – Privacy Policy; Ireland – Privacy Policy; Singapore – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Tracker; Usage Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Facebook Ads conversion tracking (Facebook pixel)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta advertising network with actions performed on releese. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

YouTube Analytics and Reporting API

YouTube Analytics and Reporting API is a video content analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Through this Service, releese may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; device information; Tracker; Usage Data; User ID; username.

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

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Meta Events Manager (Meta Platforms Ireland Limited)

Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on releese.

Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

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 releese, 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.

Personal Data processed: Trackers; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Contacting the User

Mailing list or newsletter (releese)

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 releese. Your email address might also be added to this list as a result of signing up to releese or after making a purchase.

Personal Data processed: city; company name; country; county; date of birth; email address; first name; gender; last name; phone number; physical address; profession; Tracker; Usage Data; ZIP/Postal code.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information; biometric information; internet information; employment related information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Contact form (releese)

By filling in the contact form with their Data, the User authorizes releese 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: city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; physical address; profession; state; User ID; various types of Data; VAT Number; website; ZIP/Postal code.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information; biometric information; internet information; employment related information; inferred information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Data transfer outside of the UK

The Owner is allowed to transfer Personal Data collected within the UK to third countries only subject to specific legal requirements (so-called restricted transfers). Restricted transfers may take place according to the conditions specified below.

Users can enquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on standard contractual clauses (UK) (releese)

If this is the legal basis, 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.

Personal Data processed: various types of Data.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

Data transfer outside the EU

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on standard contractual clauses (releese)

If this is the legal basis, 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.

Personal Data processed: various types of Data.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of releese and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts

Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows releese to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

YouTube Data API

YouTube Data API is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows releese to incorporate functions normally executed on YouTube so that Users can watch, find, and manage YouTube content directly on releese.

Through this Service, releese may collect Data directly or indirectly on or from Users’ devices, including by making use of Trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; device information; Tracker; Usage Data; User ID; username.

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

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Handling activities related to productivity

This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.

Gmail

Gmail is a service that manages email communication provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Such email communication is not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside this service for advertising purposes in any other way.

Personal Data processed: email address.

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

Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

Handling payments

Unless otherwise specified, releese 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. Releese 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.

Stripe

Stripe is a payment service provided by Stripe Inc, Stripe Technology Europe Ltd or by Stripe Payments Ltd, depending on how the Owner manages the Data processing.

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; United Kingdom – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

Payment by bank transfer (releese)

In the event that the chosen payment method is a direct bank transfer to the current account indicated by releese, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.

Personal Data processed: company name; first name; last name; payment info; physical address.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information.

Heat mapping and session recording

Heat mapping services are used to display the areas of releese that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

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

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Microsoft Clarity (Microsoft Corporation)

Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Hosting and backend infrastructure

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

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.

Google Cloud Storage

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

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

Place of processing: United States – Privacy Policy; Canada – Privacy Policy; Brazil – Privacy Policy; Belgium – Privacy Policy; United Kingdom – Privacy Policy; Germany – Privacy Policy; Netherlands – Privacy Policy; Taiwan – Privacy Policy; Japan – Privacy Policy; India – Privacy Policy; Singapore – Privacy Policy; Australia – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

Managing contacts and sending messages

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.

Sendgrid (Sendgrid)

Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

Personal Data processed: company name; country; date of birth; email address; first name; gender; last name; phone number; physical address; Tracker; Usage Data; username.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information; biometric information; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

Appcues (Appcues, Inc.)

Appcues is a message sending service provided by Appcues, Inc. Appcues may also be used to manage the creation, deployment, administration, distribution and analysis of online forms and surveys.

Personal Data processed: billing address; company name; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; language; last name; number of sessions; phone number; physical address; purchase history; Tracker; Usage Data; username; workplace.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information; biometric information; internet information; geolocation data; employment related information; inferred information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

Managing landing and invitation pages

This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.

Leadpages (Avenue 81, Inc.)

Leadpages is a landing page management service provided by Avenue 81, Inc., that allows releese to collect the email addresses of Users interested in its service.
Leadpages allows 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 the created landing pages.

Personal Data processed: email address; Usage Data; 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 CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Managing support and contact requests

This type of service allows releese to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Help Scout (Help Scout Inc. )

Help Scout is a support and contact request management service provided by Help Scout Inc. .

Personal Data processed: Data communicated while using the service; Tracker; 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 CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Registration and authentication

By registering or authenticating, Users allow releese 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, releese 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.

Facebook Authentication

Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

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

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Facebook Oauth

Facebook Oauth is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

Personal Data processed: Tracker; various types of Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Firebase Authentication

Firebase Authentication is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. 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; phone number; social media accounts ; username.

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

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Sign in with Apple (Apple Inc.)

Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.

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

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Registration and authentication provided directly by releese

By registering or authenticating, Users allow releese to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct registration (releese)

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

Personal Data processed: various types of Data.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

Remarketing and behavioral targeting

This type of service allows releese and its partners to inform, optimize and serve advertising based on past use of releese by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

LinkedIn Website Retargeting (LinkedIn Corporation)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of releese with the LinkedIn advertising network.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

Twitter Remarketing (Twitter, Inc.)

Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of releese with the Twitter advertising network.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

Twitter Tailored Audiences (Twitter, Inc.)

Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of releese with the Twitter advertising network.

Users can opt out from interest-based ads by going to: Personalization and Data.

Personal Data processed: email address; Tracker.

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

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

AdRoll (NextRoll, Inc.)

AdRoll is an advertising service provided by NextRoll, Inc. AdRoll can serve targeted advertising on any device connected to the User, by processing their email address using a security technique called hashing.
AdRoll may also automatically collect certain types of data to serve personalized recommendations to the User, as stated in its privacy policy.

Personal Data processed: device information; purchase history; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

TikTok Remarketing

TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited , TikTok Inc., Bytedance, TikTok Technology Limited or by TikTok Pte. Ltd., depending on how the Owner manages the Data processing, that connects the activity of releese with the TikTok advertising network.

Personal Data processed: device information; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: United Kingdom – Privacy Policy; United States – Privacy Policy; India – Privacy Policy; Ireland – Privacy Policy; Singapore – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA

SPAM protection

This type of service analyzes the traffic of releese, 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 how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information; inferred information.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on releese 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 how the Owner manages the Data processing.

Personal Data processed: Tracker; Usage Data.

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

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

Segment (Twilio, Inc.)

Segment is a tag management service provided by Twilio, Inc.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to releese, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving releese.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on releese.

Pipedrive (Pipedrive OÜ)

Pipedrive is a User database management service provided by Pipedrive OÜ.

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

Place of processing: Estonia – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Drip (Drip Global, Inc.)

Drip is a User database management service provided by Drip Global, Inc. Drip leverages the User’s email address, which it can combine with Data that is gathered from releese and other sources (if any, indicated within this privacy policy), to enable releese to set up automations and communicate with Users in a personalized context and timing.

Personal Data processed: Email; Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

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 releese depends on the payment system used.

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.

Cookie Policy

Releese uses Trackers. To learn more, the User may consult the Cookie Policy.

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 releese 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, releese 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, releese and any third-party services may collect files that record interaction with releese (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 the beginning of this document.

How “Do Not Track” requests are handled

Releese 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 releese 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 releese 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 (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the California Consumer Privacy Act of 2018 (the CCPA), as updated by the California Privacy Rights Act (the CPRA) and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA/CPRA).

Notice at collection

Categories of personal information collected, used, sold, or shared

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

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information, biometric information, internet information, geolocation data, employment related information and inferred information.

We have collected the following categories of sensitive personal information: username, password, username, username, payment info, VAT Number, username and username

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

Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it

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

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

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

To fully exercise your right to limit the use or disclosure of your sensitive personal information you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on releese.

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

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

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

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

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

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

How long do we keep your personal information?

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

How we collect information: 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 releese.

For example, you directly provide your personal information when you submit requests via any forms on releese. You also provide personal information indirectly when you navigate releese, 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.

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

For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CPRA (CCPA amendment).

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

Sale or sharing of your personal information

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

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.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CPRA (CCPA amendment).
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CPRA (CCPA amendment), does not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and how you can exercise it

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

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on releese.

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

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

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

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

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

How long do we keep your personal information?

Your privacy rights under the California Consumer Privacy Act and how to exercise them

The right to access personal information: the right to know and to portability

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

the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

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

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

The right to request the deletion of your personal information

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

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so – provided that this is technically feasible and doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising your rights under the CPRA (CCPA amendment). This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

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

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

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

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

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

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

If you are an adult, you can make a verifiable request on behalf of a 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. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

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

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

Information for Virginia 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 controller 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 (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act (the VCDPA), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the VCDPA.

Categories of personal data processed

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

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, employment related information and inferred information

With your consent, we collect the following categories of sensitive data: VAT Number

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

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

Why we process your personal data

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

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How we use the data we collect: sharing of your personal data with third parties

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word third party means a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller as defined by the VCDPA.

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.

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

Processing of your personal data for targeted advertising

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

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

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

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

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

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

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

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

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

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

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 releese 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).

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.

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 releese (or third-party services employed in releese), which can include: the IP addresses or domain names of the computers utilized by the Users who use releese, 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 releese 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 releese. The Data Controller, unless otherwise specified, is the Owner of releese.

releese (or this Application)

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

Service

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

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.

Email

Provides access to the User's primary email address.

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 releese, if not stated otherwise within this document.

Latest update: January 09, 2023