We would like to inform you about how we collect, use, and disclose personal data from and about you through this website and related mobile websites, applications, and widgets.

1. WHAT AND WHO DOES THIS PRIVACY POLICY COVER?

The Company is the data controller of the personal data (e.g., information that identifies a specific person, such as full name or email address) that we collect from and about you through the Company’s Services, which are processed in accordance with the terms of this Privacy Policy.

This Privacy Policy, as well as our Cookie Policy, applies to all users, including those who use the Company’s Services without being registered or subscribers to any of the Company’s Services and those who are registered or subscribers to any of the Company’s Services.

As defined in our Terms of Use, the Company’s Services are directed to a general audience, are not directed to children, and do not knowingly collect personal data from children under the age of 16.

2. WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

The Company collects (1) registration data, when you register or sign up for any of the Company’s Services, (2) public data and posts you share through the Company’s Services, (3) data you have allowed social media platforms to share with the Company, (4) activity data when you access and interact with a Company service. Specifically, the Company collects the following types of data from and about you:

1. Registration data, meaning the information you submit to register for a Company Service, for example, to create an account, post comments, receive a newsletter, or participate in a contest. Registration information may include, for example, your first name, last name, email address, gender, country, postal code, and date of birth.
2. Public data and posts consisting of comments or content you post on the Company’s Services and your personal data accompanying such posts or content, which may include your nickname, username, comments, likes, status, profile information, and picture. Public information and posts are always public, meaning they are available to everyone and may appear in search results on external search engines.
3. Social media data. If you access or log into a Company Service through a social media service or connect a Company Service to a social media service, the data we collect may also include your user ID and/or username associated with that social media service, any information or content you have allowed the social media service to share with us, as well as your profile picture, email address, or friends lists, and any personal data you have made public in connection with that social media service. When you access the Company’s Services via social media services or connect a Company Service to social media services, you authorize the Company to collect, store, and use such personal data and content in accordance with this Privacy Policy.
4. Activity data. When you access and interact with the Company’s Services, we may collect certain information about those visits. For example, to enable your connection to the Company’s Services, our servers receive and record information about your computer, device, and browser, possibly including your IP address, browser type, and other software or hardware information. If you access the Company’s Services from a mobile or other device, we may collect a unique device ID assigned to that device, geolocation data, or other transactional information for that device. We may also collect cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology commonly called “Flash cookies”). These technologies may be used to collect and store information about your use of the Company’s Services, such as pages you visited, video and other content you viewed, search queries you submitted, and advertisements you viewed. For more information, see our Cookie Policy.
5. Information from other sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services and commercially available sources.

We do not collect:

• Financial information from a payment service provider: In some cases, we may use an unrelated payment service to enable you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment through a Payment Service, you will be directed to a Payment Service webpage. Any information you provide to a Payment Service will be subject to the Payment Service’s privacy policy, not this Privacy Policy. We have no control over and are not responsible for any use by the Payment Service of information collected through the Payment Service.
• Sensitive information: We ask that you do not send us or disclose sensitive personal data (such as social security numbers, information about racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through the Company’s Services or otherwise.

Linked services
Finally, the Company’s Services may also link to websites, including social media sites, operated by non-affiliated companies, and may feature advertisements or offer content, functionality, games, newsletters, contests, or applications developed and maintained by non-affiliated companies. The Company is not responsible for the privacy practices of non-affiliated companies, and once you leave the Company’s Services or click on an advertisement, you should check the applicable Privacy Policy of the other service.

3) Functionality cookies
These cookies “remember” your preferences when browsing our site so that we can recommend appropriate products based on your needs. With these cookies, you enjoy a personalized version of our site, making it much easier to find exactly what you are looking for.

3. HOW DO WE USE YOUR PERSONAL DATA?

We use the personal data we collect from and about you to:

• Provide you with the Company’s Services and features,
• Measure, analyze, and improve the Company’s Services and features,
• Enhance your experience with the Company’s Services (both online and offline) by providing content you may find relevant and interesting,
• Enable you to comment on content and participate in online games, contests, or reward programs,
• Provide you with customer service and respond to your inquiries,
• Protect the rights of the Company and others. For example, the Company may use your personal data when it believes, in good faith, that such processing is necessary to: (i) protect, enforce, or defend the legal rights, safety, or property of the Company, its affiliates, or their employees, agents, contractors, licensors, and suppliers (including enforcing agreements and our terms of use), (ii) protect the safety, privacy, and security of users of the Company’s Services or the public, (iii) protect the Company and other involved third parties, such as the Company’s suppliers, from fraud or for risk management purposes,
• Comply with applicable laws or legal processes and/or respond to requests from competent governmental authorities,
• Complete a corporate transaction such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of the business, assets, or stock (including any bankruptcy or similar proceedings). For example, if the Company is involved in a merger or transfer of all or a substantial part of its operations, the Company may disclose and transfer your personal data to the party or parties involved in the transaction as part of that transaction,
• Enable social interaction functionality – if you log in or connect a social media service account with the Company’s Services, we may share your username, picture, and likes, as well as your activities and comments, with other users of the Company’s Services and with your friends associated with your social media service. We may also share the same personal data with the social media service provider,
• Send you (via email, SMS, phone, chat, and social media), with your prior consent, offers, promotions, and other commercial communications regarding the Company’s Services,
• Send you, with your prior consent, commercial communications tailored to your interests and needs through the communication methods referred to above.

We may use anonymous or non-identifying data (e.g., statistics) for any purpose or share it with third parties.

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

The processing of your personal data for the purposes: From Section 3, points a) to f) of this Privacy Policy is necessary for providing the requested services and, therefore, is mandatory; otherwise, the services could not be provided. From Section 3, point g) of this Privacy Policy is required by applicable laws and, therefore, is also mandatory. From Section 3, point h) of this Privacy Policy is carried out based on the legitimate interest of the Company and its counterparties to conduct such business activities. This interest is adequately balanced with your own interest, given that data processing is performed strictly within the necessary scope for such activities. This data processing activity is not mandatory, and you may object at any time as described in Section 11 of this Privacy Policy. Conversely, the processing of your personal data for the remaining purposes: From Section 3, point (i) is at your discretion, but without your consent, it is impossible to connect a social media service account with the Company’s Service, meaning you would need to connect using a different method. From Section 3, points (j) and (k) is at your discretion, but without your consent, the Company and/or third parties cannot provide you with general commercial communications from the Company and third-party services/products or communications based on your interests and needs, nor can they offer co-branded services. You may withdraw your consent at any time for the processing of your personal data for the purposes in Section 3, points i) to k), by sending a notice to the email address described in Section 11 below.

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

Your personal data is processed both electronically and manually and is protected by appropriate security measures, taking into account the state of the art, the cost of implementation, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity of the risk to individuals’ rights and freedoms. In particular, the Company uses appropriate administrative, technical, personnel, and physical measures to protect personal data in its possession from loss, theft, and unauthorized use, disclosure, or modification.

6. WHO MAY ACCESS YOUR PERSONAL DATA?

The Company may share your personal data for the purposes set out in Section 3 above with the following categories of recipients, located within or outside the European Union, in accordance with and within the limits of Section 7 below:

• Third-party service providers responsible for processing activities and, where required by applicable laws, duly appointed as processors (e.g., cloud service providers, other group entities, service providers who operate or support the Company’s Service, such as IT service companies, experts, consultants, and law firms – companies arising from possible mergers, demergers, or other transformations),
• Affiliated companies acting as data controllers or data processors,
• Competent authorities for compliance with applicable laws.

Data processors appointed by the Company include IT service providers. You may request a complete list of appointed data processors by contacting the Company at the address indicated in Section 11 of this Privacy Policy.

7. ARE YOUR PERSONAL DATA TRANSFERRED ABROAD?

Your Data may be transferred to countries inside and outside the European Economic Area (EEA), in particular to the United States. The European Commission recognizes that certain non-EEA countries provide an adequate level of data protection according to EEA standards. The full list of these countries is available at: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. For transfers from the EEA to countries not considered safe by the European Commission, we have put in place appropriate safeguards to protect your personal data and transfer it in accordance with applicable data protection laws, such as standard contractual clauses approved by the European Commission pursuant to Articles 45 and 46 of Regulation (EU) 2016/679 on data protection (“General Data Protection Regulation”). You have the right to request a copy of the above measures and further information regarding your personal data by contacting the Company at the address in Section 11 of this Privacy Policy.

8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

You have the right, at any time, to:

• Receive confirmation as to whether or not your personal data exists and be informed of its content and source, verify its accuracy, and request its correction, update, or modification,
• Request the deletion, anonymization, or restriction of the processing of your personal data processed in violation of applicable law,
• Object to the processing, in all cases, of your personal data for legitimate reasons.

You may send your request to the address indicated in Section 11 below. In your request, please include your email address, name, postal address, and telephone number, and clearly specify the information you wish to access, change, update, remove, or delete.

Please note that even after you cancel your account, or request the deletion of your personal data, copies of certain information from your account may remain visible in some circumstances — for example, if you have shared information on social media or other services, or where the retention of such copies is necessary for compliance with legal obligations or for legal defense purposes. Due to the nature of caching technology, your account may not be immediately inaccessible to others. We may also retain backup information related to your account on our servers for a period after cancellation or your request for deletion, for compliance with applicable law.

We also provide you with many choices regarding the use and disclosure of your personal data for marketing purposes. You may withdraw your consent for:

• Receiving electronic communications from us. If you no longer wish to receive marketing-related emails from us, you may opt out by following the unsubscribe instructions in our communications or by changing your preferences in your user profile settings if you are a registered user, or through the consent management tool available on our website if you are not registered. You may also send a request to the address indicated in Section 11 of this Privacy Policy. In any case, the Company may still send you administrative messages regarding the provision of the Company’s Services.
• Sharing your personal information with the Company’s affiliates or business partners for their direct marketing purposes. If you prefer that we do not continue to share your personal information with our affiliates and/or business partners for their direct marketing purposes, you may opt out by changing your preferences in your user profile settings if you are a registered user, or via the consent management tool available on our website if you are not registered, or by sending a request to the address in Section 11 of this Privacy Policy.

In all the above cases, we may contact you to request additional information necessary to properly process your request. Additional rights described in Section 9 below have been applicable since May 25, 2018.

9. WHAT APPLIES AS OF MAY 25, 2018?

As of May 25, 2018, the General Data Protection Regulation (GDPR) is in effect, and the following provisions apply:

1. Retention periods for your personal data

   We will retain your data only for the period necessary to fulfill the purposes for which the data was collected, as described in this Privacy Policy. In any case, the following retention periods apply:

   • Data collected for the purposes set out in Section 3, points a) to h) of this Privacy Policy are retained for the duration of the Company’s Service provision plus the limitation period in accordance with applicable law, after the end of the Service. Data collected for the purposes of Section 3, point i) of this Privacy Policy are retained for the time required for you to connect to the Company’s Service through a social network.
   • Data collected for the purposes of Section 3, point j) are retained in a form that permits identification of data subjects only for the period necessary for processing; personal data may be stored for longer periods if processed solely for archiving in the public interest, scientific or historical research purposes, or statistical purposes, in accordance with Article 89(1) of the GDPR and subject to the implementation of appropriate technical and organizational measures required by the GDPR (“storage limitation”).
   • Data collected for the purposes of Section 3, point k) are retained under the same conditions as above.

   At the end of the retention period, your personal data will be deleted, anonymized, or aggregated.

2. Additional rights

   In addition to the rights referred to in Section 8 of this Privacy Policy, and as a result of the GDPR’s application, you will also have the right, at any time, to:

   • Request that the Company restrict the processing of your Personal Data in the following cases:
   • You contest the accuracy of the personal data until we take the necessary steps to correct or verify its accuracy,
   • The processing is unlawful, but you do not want us to delete your personal data,
   • We no longer need your personal data for processing purposes, but you require it for the establishment, exercise, or defense of legal claims, or
   • You have objected to processing for legitimate interest reasons, pending verification of whether the Company has compelling legitimate grounds to continue processing.
   • Object to the processing of your personal data,
   • Request the deletion of your personal data without undue delay,
   • Receive an electronic copy of your personal data if you wish to transfer it to yourself or another provider (“data portability”), when the personal data is processed by automated means and the processing is either (i) based on your consent or (ii) necessary for the performance of the Company’s Service, and
   • Lodge a complaint with the competent data protection supervisory authority.

10. UPDATES TO THIS PRIVACY POLICY

The Company may amend or update this Privacy Policy for any reason (including, without limitation, changes in applicable law and interpretations, decisions, opinions, and orders relating to such applicable law).

Please refer to the Effective Date at the top of this Privacy Policy to see when it was last revised. Any changes to this Privacy Policy will be notified in advance by posting the revised Privacy Policy on the Company’s Services. If we make material changes to this Privacy Policy that change the nature of processing or expand our rights regarding the use of personal data we have already collected from you, we will notify you and provide you with an option regarding the future use of such personal data, as may be required by applicable law.