Last updated: May 2023
Our Commitment to You
Pro Sportority (Israel) Ltd., and its affiliated companies (“Minute Media” or "we") are dedicated to providing its users with transparency and control over the use of their data. In order for us to provide you with our Services we may collect and process certain Personal Data about you and your activity.
We have taken measurable steps to protect the confidentiality, security and integrity of such Personal Data collected and/or processes by us.
(1) Why do We Process your Personal Data?
Your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) will be processed for the purposes described below, based on the corresponding legal bases also described, as necessary for the provision of our services and products (including, without limitation, any content therein), the operation of our brand websites, newsletter and related mobile apps (hereinafter our “Brand Websites”, also listed on the homepage of this website) and the operation of all of our websites (collectively the “Services”, and the “Websites”).
Legal basis (if and when required under applicable laws)
Provision of our Services; support; service announcements; push notifications; analytics, surveys and research; protecting our interests; enforcing of policies; We may use your Personal Data, such as your name and email address, for operational purposes, for example, responding to your inquiries. In other instances we may, for example, use your Personal Data to send you notifications and communications if you opted in and/or accepted to receive them from us, or if they are relevant to your use of our Services (such as service announcements).
The legal bases for processing this data are the performance of our contractual obligations towards you; your consent (for example, when you provide Personal Data); compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.
Payments. We collect from our third-party payment processors certain information about your payment instruments for the purpose of completing any transaction requested by you, and sending to you statements, invoices, or receipts.
The legal bases for processing this data are the performance of our contractual obligations; the protection of our legitimate interests, in this case enforcing our policies and preventing misuse of our Services; and compliance with legal obligations to which we are subject.
Improve our Services. We collect and analyze information about you and your usage of our Services to improve the usability and effectiveness of our Services.
The legal bases for processing this data are our legitimate interests, in this case – providing and improving our Services. Where analytics data containing personal data is collected through cookies and similar Tracking Technologies (as further described below) we rely on your consent, where required.
Marketing and Advertising; We may use Tracking Technologies (which may collect Personal Data) in order to provide you with personalized advertisements when you visit our Services.
The legal bases for processing this data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored Services, content and advertisements that better correspond with your interests.
Third Party Advertising and Data Segmentation; We may share your personal data with third party ad networks and data segmentation solution companies to enrich, segment or optimize your data for marketing and advertising purposes of ourselves and our business partners.
The legal bases for processing this data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored Services, content and advertisements that better correspond with your interests, and assisting our business partners to do the same. As explained below, where applicable, you will have the option to opt-out from such data processing
Integrity. We may process certain information about you and your usage of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies.
The legal bases for processing this data are your consent (where required), compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services and the safety of our end-users.
Compliance with applicable laws, legal and regulatory requirements.
We may be required to collect, retain, or share your Personal Data, under applicable laws.
When you use our Services, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Policy.
(2) How Do We Receive Data About You?
We receive your Personal Data from various sources:
- Registration information - When you voluntarily provide us your personal details to create an account or register to our Services or submit a job application (for example, your name and email address).
- When you communicate with us - For example when you send us a message, or apply to be a content provider/editor, or complete a form for another purpose using our Services, we collect the Personal Data you provided us with.
- When you submit content to or through the Services.
- When you respond to or participate in one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums or by otherwise expressing an opinion.
- When you click on links included in our Services that lead to third party products and/or services offered on third party sites by business partners we are affiliated with (“Affiliate Link/s”).
- When you purchase, return, win, or exchange products offered through the Services.
- Third party information (vendors) – We may receive your data from third party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and user name, when you register or log-in to our Services, or Candidate Data (as defined below) when you submit a job application via a social network such as LinkedIn), traffic analytics vendors, fraud prevention agencies and others.
- Third party information (business partners) - We also receive your data from publishers and advertisers who use our platform and other services, as well as from business partners for data segmentation and optimization purposes.
(3) What Type of Data We Collect?
a. Personal Data
In the course of using the Services, we may ask you to provide us with certain Personal Data to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Websites, and as otherwise indicated in this Policy. We may collect the following Personal Data about you:
- When you sign up to an event or receive our newsletter, when you send us a message (or submit a support ticket), or otherwise communicate with us in relation to the Services, we may receive certain data, such as: your name, email address or other information included in such communications.
- If you create an account or register to our Services, or connect your account and log-in to our Services via to a social network (for example: if you log in via Facebook), we may also collect certain data, such as your associated credentials, profile name, email address, profile photo, age and country/state of residence.
- If applicable, payment data such as your payment instrument number (such as a credit card number) and billing information, collected in order to process your payments for purchases, fulfill your requests for refunds, returns, or exchanges, and process the redemption of discounts. This data is usually processed by our relevant service providers, and not retained by us.
- In the framework of one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums, content publishing ("Activity") and when you choose to provide it, we may also collect information about your personal or professional interests, lifestyle, favorites and opinions about various topics, products, programs and services. The type of information collected may be influenced by the nature of our Website conducting the Activity (e.g. a home decor website may ask for information on the type of home you live in, and whether you are a renting or a home owner). Such information may include your full name, information regarding your marital/relationship status and number of children, gender, year of birth, your state and city of residency, employment status, your astrological sign, and any additional information you choose to provide in connection to such Activity.
- Internet or other electronic network activity information - our Services may use your IP-address and UDID and other information regarding your interaction with our Services and/or with advertisements displayed on our Services on the Brand Websites.
- Geolocation data – our Services may use information regarding your general location.
- Information from third parties – this includes information we receive from our business partners. This may include pseudonymous advertiser identifiers that some advertisers or other third party ad platforms choose to share with us, as well as other segmentation data. This information is also used to enhance data points about a particular unique browser or device, to segment and enrich data for the purposes set forth above. While we strive to keep such data in a non-identifiable manner, in some jurisdictions, such data may qualify as personal data.
b. Non-Personal Data
We also collect data about the use of our Services and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:
- Technical information – this includes data such as website visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), and non-identifiable cookie information.
c. Voice Processing Technologies
d. Job Candidates from the EU
- Personal Data of Job candidates who apply for any of our and our affiliated companies’ open jobs in the EU (“Candidates”), is also subject to this Policy, and in addition, to the terms specifically provided in this section, which shall prevail over the rest of the terms of this Policy in case of inconsistency. Within an application of a Candidate, we may collect certain Personal Data about the Candidate, as provided by the Candidate, such as: resume, contact details, occupation data and other related information (“Candidate Data”).
- Our main management and retention platform provider for Candidate Data is Comeet Technologies Inc. (“Comeet”). Candidates are welcome to review Comeet’s privacy notice at:https://help.comeet.com/en/articles/3134994-privacy-notice.Candidates should not apply for a job and provide us with their Personal Data, unless they have read and agreed to this Policy and Comeet’s privacy notice.
- A Candidate may also apply for a position via third parties (such as: LinkedIn, Glassdoor, placement companies, etc.), who may provide us with Candidate’s Personal Data on Candidate’s behalf. Any Personal Data that we receive via from such third parties may be subject to this Policy, but each Candidate is requested to review the privacy policies of such third parties (of which we do not assume any liability for) prior to providing us with any Personal Data via their services.
- We aim to protect the privacy of Candidate Data and use such data solely for our and our affiliated companies’ internal recruitment purposes (inter alia, for contacting the Candidates, evaluating them for a specific position, etc.). In case a Candidate provides a reference, certain necessary relevant Candidate Data may be inevitably revealed to such reference in the process of a reference check (e.g., the fact that Candidate is searching for a new job, and any other relevant information included in Candidate’s resume, etc.), and thus a Candidate should not provide a reference in case Candidate does not wish such information to be disclosed.
- We retain Candidate Data within Comeet for no longer than thirty six (36) months after the last activity was made in relation to a Candidate on Comeet, unless the Candidate has provided consent for a longer period of retention. Resumes, and Candidate Data provided to us via other means, may be retained in other systems for longer periods, subject to the general retention framework specified in this Policy under the “Retention” section below. The purpose of retaining Candidate Data is to enable us to contact a Candidate who we find suitable in order to inform the Candidate of a new job vacancy, and in order to use such data in case the Candidate contacts us again and applies for the same or a different position.
- If you wish to exercise any of your “European Users' Rights” specified below in this Policy or receive more information regarding Candidate Data, please contact our Data Protection Officer (“DPO”) using the details provided below. Kindly specify that your request is related to your Candidate Data. Email: email@example.com.
e. Tracking Technologies
When you visit or access our Services we use (and authorize third parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Websites’ performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.
(4) How Do We Use the Data We Collect?
- Provision of service - for the provision and improvement of our Services, including for support, responding to your queries, and processing of payments as stated in Section 3 above.
- Service announcements - we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
- Marketing and advertising purposes - by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also use your Personal Data in the following ways: we may send you promotional material concerning our Services, or our partners' services, which we believe might interest you; we may also display certain ads on our Services or on our Brand Websites, which we believe will be relevant for you. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data.
- Collaborating with third parties – we may partner with third party businesses to receive or share your Personal Data for data segmentation, enrichment and optimization purposes, which allow us or our partners to personalize and optimize the services, advertisements and marketing activities we or they offer you. In some jurisdictions, this is subject to opt-out options set forth in this Policy.
- Opt-out of sale and sharing of your data – in some jurisdictions, you may opt-out from the sale or sharing of your Personal Data to third parties by using our designated tools (such as opt-out banners, cookie preference banners, Do-Not-Sell buttons, etc.), as well as by contacting us in the manner set forth below.
- Opt-out of receiving marketing materials - if you do not want us to use or share your Personal Data for marketing purposes, you may opt-out in accordance with this "Opt-out" section. You may choose not to receive our promotional or marketing emails by clicking on the “unsubscribe” link in the emails that you receive from us, or contact our DPO at firstname.lastname@example.org (kindly specify the name of the relevant product from which you wish to unsubscribe from). Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us. Also note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services. If you subscribed to any of our partners' service, please note we will have no control over our partners' communications, and in order to unsubscribe from it please contact the relevant partner or use the "unsubscribe" link in its emails.
- Push Notifications - if you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our relevant app.
- Analytics, surveys and research - from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and think of new and exciting features for our users.
- Protecting our interests - we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and protect the rights and property of Minute Media, its users and/or partners.
- Compliance with legal and regulatory requirements - we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
(5) With Whom Do We Share Your Personal Data?
- Internal concerned parties - we share your information with companies in our group, as well as our employees, in order to provide you with our Services.
- Vendors and service providers - we share your information with business partners, such as SaaS, storage, advertising, and analytics providers who help us provide you with our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with contractual privacy obligations.
- Business partners - we may partner with third party businesses to share your Personal Data for data segmentation, enrichment and optimization purposes, which allow us or our partners to personalize and optimize the Services, advertisements and marketing activities we or they offer you. In some jurisdictions, this is subject to opt-out options set forth in this Policy.
- User Profiles and Submissions – certain user profile information, including your name, location, and any related video or image content you uploaded to the Services for publication, may be displayed to other users as part of the Services, to facilitate user interaction within the Services or address your request for our Services. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (e.g., on your published content, forums, discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your name/username may also be displayed to other users if and when you send messages or comments or upload images, content or videos through the Services.
- Compliance with laws and law enforcement entities - we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
- Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.
(6) How We Protect Your Information
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.
(8) Transfer of data outside the EEA or UK
We operate globally, thus any information that we collect, disclose or share, including your Personal Data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy.
EU users, please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:
- located in the EEA or in the UK;
- located in non-EEA countries or non-UK which have been approved as providing adequate level of data protection; or
- who have entered into legal agreements and performed assessments ensuring an adequate level of data protection by the recipient.
(9) Rights and Information for Residents of Specific Jurisdictions
A. European or UK Users' Rights
If you reside within the European Union or the UK, you may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
- Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.
- Request erasure of your Personal Data.
- Lodge a complaint with a supervisory authority.
However, please note that these rights pertain to EU and UK residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. If you, as EU of UK resident, would like to exercise any of the rights mentioned in this section, please refer to the section 9B below.
B. EEA or UK Residents
If you reside in the EEA or UK, we will be the controller of your Personal Data provided to, collected by or for, or processed by us in connection with our Services.
All requests, complaints and queries should be addressed to us by submitting a verifiable consumer request to our email address: email@example.com (please provide the required details as per Section 15 below).
We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
Our representative in the European Union is Lionheart Squared (Europe) Ltd., 2 Pembroke House, Upper Pembroke Street 28-32, Dublin, D02 EK84 Ireland, and their email address is: MinuteMedia@lionheartsquared.eu.
Our representative in the United Kingdom is 385-389 Oxford St. London W1C 2NB and their email address is: firstname.lastname@example.org.
In addition, you can exercise your rights via email@example.com, where you can submit a verifiable user request.
Only you or a person legally authorized to act on your behalf may make a consumer request related to your Personal Data (“Request”).
The Request must:
- Provide sufficient information allowing us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative.
- Describe your Request with sufficient details to allow us to properly understand, evaluate, and respond to it.
- We cannot respond to your Request or provide you with Personal Data if we cannot verify your identity or authority to make the Request and confirm the Personal Data relates to you. Making a verifiable Request does not require you to create an account with us. We will only use Personal Data provided in a verifiable Request to verify the requestor's identity or authority to make the Request. If you have any general questions about the Personal Data that we collect about you or how we use it, please contact us at firstname.lastname@example.org.
C. California Residents
For the purposes of this section, the "CCPA" shall mean the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act of 2020, and the regulations promogulated thereunder.
In the preceding 12 months, we have collected, disclosed, and/or sold the following categories of Personal Data:
Category of Personal Data Collected
Personal Data Collected
Categories of service providers and third parties to whom Personal Data may have been disclosed (in whole or in part)
Full name, email address, postal address, social media identifiers, photos, IP address, UDID, Advertising Ids
Affiliated Companies Payment Processors Advertising Networks Data Analytics Providers Payment Processors ID Companies Data Segmentation Providers
Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
Full name, billing information, credit card number (collected directly by our payment processors)
Affiliated Companies Payment Processors Cloud Services
Internet or Other Electronic Network Activity Information
Information on a consumer’s interaction with a website, application, or advertisement
Affiliated Companies Advertising Networks Data Analytics Providers Cloud Service ID Companies Data Segmentation Providers
Physical location (non-precise)
Affiliated Companies Advertising Networks Data Analytics Providers Cloud Service ID Companies Data Segmentation Providers
We may share or transfer Personal Data to third parties as assets that are part of a
merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of Minute Media. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Data under the CCPA.
In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from either of the following categories of sources:
- Consumer directly;
- Social media;
- Fraud prevention service providers;
- Analytics providers;
- Ad networks;
- ID companies;
- Data segmentation providers.
C1. California Consumers' Rights
The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.
a. Access to Personal Data
You may request, up to two times in a 12 months period, that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Data, if applicable.
b. Right of Data Portability
You have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability.
c. Right of rectification
You have the right to request us to rectify your Personal Data place in our control in the event that you believe your Personal Data is inaccurate, incomplete or outdated.
d. Right of Deletion/Erasure
You have the right to request that we delete any Personal Data collected from you and retained by us, unless an exception applies. Once we receive and confirm your verifiable consumer request, we will delete (and where necessary and relevant, direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.
e. Right to restriction or objection to processing
You have the right to request that we will restrict or cease to conduct certain Personal Data processes at any time.
f. Right to withdraw your consent
To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.
g. Right to limit use and disclosure of your sensitive Personal Data
You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services.
h. Right not to be subject to automated decision making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.
i. Right to Opt-Out of the Sale of Personal Data
If we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.
If you do not want us to sell your Personal Data to third parties, please click on the “Do Not Sell My Personal Information” link located on the homepages of our Brand Websites for residents located in California.
After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site (or app) from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Data collected when you use those devices or browsers.
Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/.
You may also download the AppChoices app at http://www.aboutads.info/appchoices to opt-out in connection with mobile apps, or use the platform controls on your mobile device to opt-out.
j. Right to non-discrimination
You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.
Unless permitted by the CCPA, in connection with you exercising your aforementioned rights, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
l. Requests Metrics
We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between July 1st of the previous year to April 20th of the following year):
Mean Number of Days to Substantive Response
Requests to Delete
Up to 72 hours from the day of applicable request
Requests to Know
Up to 72 hours from the day of applicable request
Requests to Opt Out of Sale
m. Authorized Agents (CCPA)
If you reside in California, you can use an authorized agent to make a Request to exercise your right under applicable laws on your behalf if:
- The authorized agent is a natural person or a business entity; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
The Request must:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your Request or provide you with Personal Data if we cannot verify your identity or authority to make the Request and confirm the Personal Data relates to you; and
- Describe your Request with sufficient details to allow us to properly understand, evaluate, and respond to it.
- We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Making a verifiable Request does not require you to create an account with us.
D. Brazilian Residents
The following part of this Policy complements the general part of the Policy and addresses the specific disclosure requirements under the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, "LGPD").
a. Processing of Personal Data
The processing of your Personal Data is not a condition for the use our Services. However, parts of our Services may not be available without registration and/or payment, which involve the processing of Personal Data.
b. Brazilian Users' Rights:
If you reside in Brazil, you have the following rights under LGPD:
- Receive confirmation as to whether or not Personal Data concerning you is being processed;
- Access your Personal Data;
- Correct incomplete, inaccurate or outdated Personal Data;
- Request anonymization, blocking or deletion of unnecessary, excessive Personal Data;
- Request data portability to another service provider or product, upon express request, as may be provided by the appropriate law;
- Request deletion of Personal Data processed with your consent;
- Obtain information about the public or private entities with which we share your Personal Data;
- Request information on the possibility of you not providing consent, as well as being informed about the consequences should consent not be given;
- Revoke your consent.
If you would like to exercise any of any of the rights mentioned in this section, please contact the email address mentioned below: email@example.com (please provide the required details as per Section 15 below).
(10) Response Timing and Format
Our goal is to respond to a verifiable consumer request within 45 days (for US residents), or 30 days (for UK and EU residents) of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the initial response period. We will deliver our written response, electronically. If reasonably possible, we will provide your Personal Data in a format that is readily useable and should allow you to transmit the information without hindrance.
We do not charge a fee to process or respond to your verifiable Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your Request.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your Request.
(11) Other Jurisdictions
Under certain jurisdictions, some of the aforementioned rights may apply as well. Please contact us using the contact details provided below and we would make our best efforts to assist with any questions or requests.
(12) Our Policy toward Children
We do not knowingly collect or solicit Personal Data from Minors (as determined under the applicable laws where the individual resides; “Minors”). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. If we have collected Personal Data from a Minor without verification of parental or legal guardianship consent, we will delete that information upon discovery.
If you believe that we might have any information from or about a Minor, then please contact us through the contact details available below.
(13) Updates to this Policy
This Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Websites (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. In the event of material changes, we may also provide you with a notice. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
(14) Controlling Version
This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.
(15) How to contact us?
If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below.
Kindly specify: (a) the nature of your request, (b) your country of residence, and (c) the name of the Services (website/product/application) subject of your request.
Please be advised that firstname.lastname@example.org is designated solely for privacy related inquiries of our users, and we reserve the right not respond to any non-privacy inquiries that are sent via the DPO email address. For any non-privacy inquiries, please see send an email to email@example.com.
Upon receiving your request, and according to legal obligations to which we are subject, we will first need to verify your request and therefore we may ask you to provide us with additional verification details, as needed. Following our verification process, we will respond to your request within the timeframe required under applicable laws.