Privacy


Privacy Policy of Trueahead

This Application collects some Personal Data from its Users.

Policy summary

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

Analytics

Google Analytics Personal Data: Cookies; Usage Data

Google Analytics for Firebase Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

Facebook Analytics for Apps Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Contacting the User

Contact form Personal Data: email address; first name; last name; phone number; ZIP/Postal code

Content performance and features testing (A/B testing)

Google Website Optimizer Personal Data: Cookies; Usage Data

Firebase Remote Config Personal Data: various types of Data as specified in the privacy policy of the service

Device permissions for Personal Data access

Device permissions for Personal Data access Personal Data: Precise location permission (non-continuous)

Displaying content from external platforms

Google Maps widget Personal Data: Cookies; Usage Data Google Fonts Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Handling payments

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

Hosting and backend infrastructure

Google App Engine and Google Cloud Storage Personal Data: various types of Data as specified in the privacy policy of the service Firebase Cloud Storage, Firebase Cloud Firestore, Firebase Realtime Database and Firebase Cloud Functions Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Infrastructure monitoring

Firebase Crash Reporting, Firebase Performance Monitoring and Rollbar Personal Data: various types of Data as specified in the privacy policy of the service

Interaction with external social networks and platforms

Google+ +1 button and social widgets, Facebook Like button and social widgets and Twitter Tweet button and social widgets Personal Data: Cookies; Usage Data

Location-based interactions

Geolocation and Non-continuous geolocation Personal Data: geographic position

Managing contacts and sending messages

Firebase Cloud Messaging and Firebase Notifications Personal Data: various types of Data as specified in the privacy policy of the service Mailchimp Personal Data: email address

Registration and authentication

Facebook Authentication and Google OAuth Personal Data: various types of Data as specified in the privacy policy of the service Firebase Authentication Personal Data: email address

Remarketing and behavioral targeting

Remarketing with Google Analytics, Twitter Remarketing and Facebook Remarketing Personal Data: Cookies; Usage Data

Twitter Tailored Audiences and Facebook Custom Audience Personal Data: Cookies; email address

Social features

Firebase Dynamic Links and Firebase Invites Personal Data: various types of Data as specified in the privacy policy of the service

Public profile

Personal Data: first name; last name; picture; Inviting and suggesting friends Personal Data: various types of Data Further information about Personal Data

Public Data

Name, Last Name, Profile Picture Push notifications This Application may send push notifications to the User.

Contact information

Owner and Data Controller Fortuna Technology AS Owner contact email: support@trueahead.com

Full policy

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: phone number; Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position; Precise location permission (non-continuous); username; first name; last name; email address; ZIP/Postal code; country; state; province; picture; city; various types of Data. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application 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 this Application or by the owners of third-party services used by this Application 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 this Application 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 this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time. 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 to 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 Services, as well as for the following purposes: Managing contacts and sending messages, Displaying content from external platforms, Analytics, Hosting and backend infrastructure, Registration and authentication, SPAM protection, Content performance and features testing (A/B testing), Remarketing and behavioral targeting, Interaction with external social networks and platforms, Location-based interactions, Device permissions for Personal Data access, Infrastructure monitoring, Social features, Handling payments, Contacting the User and User database management. Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document. Device permissions for Personal Data access Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below. By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document. The exact procedure for controlling app permissions may be dependent on the User's device and software. Please note that the revoking of such permissions might impact the proper functioning of this Application. If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application. Precise location permission (non-continuous) Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services. The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis. Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services: Analytics The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior. Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy – Opt Out. Google Analytics for Firebase (Google Inc.) Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google's use of Data, consult Google's partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data collected: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data. Place of processing: USA – Privacy Policy. Privacy Shield participant. Facebook Analytics for Apps (Facebook, Inc.) Facebook Analytics for Apps is an analytics service provided by Facebook, Inc. Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. 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: Cookies; Usage Data. Place of processing: Malta – Privacy Policy – Opt Out. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Quora Conversion Pixel (Quora, Inc.) Quora Conversion Pixel is an analytics service provided by Quora, Inc. that connects data from the Quora Platform with actions performed on MindsDB. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt out. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Contacting the User Contact form (This Application) By filling in the contact form with their Data, the User authorizes this Application 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 collected: email address; first name; last name; phone number; ZIP/Postal code. Content performance and features testing (A/B testing) The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application. Google Website Optimizer (Google Inc.) Google Website Optimizer is an A/B testing service provided by Google Inc. Google may use Personal Data to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy. Firebase Remote Config (Google Inc.) Firebase Remote Config is an A/B testing and configuration service provided by Google Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Device permissions for Personal Data access This Application requests certain permissions from Users that allow it to access the User's device Data as described below. Device permissions for Personal Data access (This Application) This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document. Personal Data collected: Precise location permission (non-continuous). Displaying content from external platforms This type of service allows you to view content hosted on external platforms directly from the pages of this Application 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 Maps widget (Google Inc.) Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy. Google Fonts (Google Inc.) Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Privacy Shield participant. Handling payments Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment. Stripe (Stripe Inc) Stripe is a payment service provided by Stripe Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Hosting and backend infrastructure This type of service has the purpose of hosting data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored. Google App Engine (Google Inc.) Google App Engine is a hosting service provided by Google Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Privacy Shield participant. Google Cloud Storage (Google Inc.) Google Cloud Storage is a hosting service provided by Google Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Firebase Cloud Storage (Google Inc.) Firebase Cloud Storage is a hosting service provided by Google Inc. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Firebase Cloud Firestore (Google Inc.) Firebase Cloud Firestore is a hosting and backend service provided by Google Inc. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Firebase Realtime Database (Google Inc.) Firebase Realtime Database is a hosting and backend service provided by Google Inc. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Firebase Cloud Functions (Google Inc.) Firebase Cloud Functions is a hosting and backend service provided by Google Inc. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Infrastructure monitoring This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application. Firebase Crash Reporting (Google Inc.) Firebase Crash Reporting is a monitoring service provided by Google, Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Firebase Performance Monitoring (Google Inc.) Firebase Performance Monitoring is a monitoring service provided by Google Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Rollbar (Rollbar, Inc.) Rollbar is a monitoring service provided by Rollbar, Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Interaction with external social networks and platforms This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile. Google+ +1 button and social widgets (Google Inc.) The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy. Facebook Like button and social widgets (Facebook, Inc.) The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy. Twitter Tweet button and social widgets (Twitter, Inc.) The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy. Location-based interactions Geolocation (This Application) This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application. Personal Data collected: geographic position. Non-continuous geolocation (This Application) This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application. The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically. Personal Data collected: geographic position. 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. Firebase Cloud Messaging (Google Inc.) Firebase Cloud Messaging is a message sending service provided by Google, Inc. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Firebase Notifications (Google Inc.) Firebase Notifications is a message sending service provided by Google Inc. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Mailchimp (The Rocket Science Group, LLC.) Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC. Personal Data collected: email address. Place of processing: US – Privacy Policy. Privacy Shield participant. Registration and authentication By registering or authenticating, Users allow this Application 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, this Application will be able to access some Data, stored by these third party services, for registration or identification purposes. Google OAuth (Google Inc.) Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Firebase Authentication (Google Inc.) Firebase Authentication is a registration and authentication service provided by Google Inc. 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 collected: username. Place of processing: USA – Privacy Policy. Facebook Authentication (Facebook, Inc.) Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Information and content you provide voluntary which are not required to use the app. We collect the content, communications and other information you provide when you use our Products, including when you create or share content or communicate with others, quit smoking date, number of cigarettes smoked per day, number of packs, pack price number of cigarettes per pack, feelings, situations of your life and your thoughts around it. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. Our systems automatically process content and communications you and others provide to analyze context and what's in them for moderation. Remarketing and behavioral targeting This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page. Remarketing with Google Analytics (Google Inc.) Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy – Opt Out. Privacy Shield participant. Twitter Remarketing (Twitter, Inc.) Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy – Opt Out. Twitter Tailored Audiences (Twitter, Inc.) Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network. Personal Data collected: Cookies; email address. Place of processing: US – Privacy Policy – Opt Out. Facebook Custom Audience (Facebook, Inc.) Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data collected: Cookies; email address. Place of processing: US – Privacy Policy – Opt Out. Facebook Remarketing (Facebook, Inc.) Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy – Opt Out. Social features Firebase Dynamic Links (Google Inc.) Firebase Dynamic Links is a social feature provided by Google Inc. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Firebase Invites (Google Inc.) Firebase Invites is a social feature provided by Google Inc. that enables Users to share this Application. The sharing may contain referral codes, or content from within this Application and may be done via email or SMS. Sharing is tracked with Google Analytics for Firebase, which informs the Owner that the User has opened or installed this Application via invite. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy. Privacy Shield participant. Public profile (This Application) Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users’ interactions with this Application. Personal Data collected: city; country; first name; last name; picture; province; state; username. Inviting and suggesting friends (This Application) This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it. Personal Data collected: various types of Data. SPAM protection This type of service analyzes the traffic of this Application, 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 Inc.) Google reCAPTCHA is a SPAM protection service provided by Google Inc. The use of reCAPTCHA is subject to the Google privacy policy and terms of use. Personal Data collected: Cookies; Usage Data. Place of processing: US – Privacy Policy. 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 this Application, 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 this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application. Salesforce Marketing Cloud (salesforce.com, inc.) Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Salesforce Sales Cloud (salesforce.com, inc.) Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy. Further information about Personal Data Public Data Name, Last Name, Picture, content you create and share Push notifications This Application may send push notifications to the User. 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. Additional information about Data collection and processing Legal action The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities. Additional information about User's Personal Data In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. System logs and maintenance For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) 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 This Application 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 giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required. Definitions and legal references Personal Data (or Data) 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 this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment. User The individual using this Application who, unless otherwise specified, coincides with the Data Subject. Data Subject The natural person to whom the Personal Data refers. Data Processor (or 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 this Application. The Data Controller, unless otherwise specified, is the Owner of this Application. This Application The means by which the Personal Data of the User is collected and processed. Service The service provided by this Application as described in the relative terms (if available) and on this site/application. 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. Cookies Small piece of data stored in the User's device.

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 this Application, if not stated otherwise within this document.

Information and content you provide. We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. It can also include what you see through features we provide, such as our camera, so we can do things like suggest masks and filters that you might like, or give you tips on using portrait mode. Our systems automatically process content and communications you and others provide to analyze context and what's in them for the purposes described below. Learn more about how you can control who can see the things you share.