Last Update: Sep 19th 2023
This is the Privacy Policy of PDF Reader: Edit, Sign, Fill and its various & next versions (hereinafter collectively referred to as "us", "we" or "our"). In this Privacy Policy, we refer to our products and services as the "Service". Please read below to learn more about our privacy practices. Your use of the Service signifies your agreement to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Service.
Interpretation
Types of Data Collected
Type and place of data processing
The purposes of the processing
Detailed information about the processing of personal data
Information on opting out of interest-based advertising
The rights of You
Cookie Policy
Children's Privacy
More information about data collection and processing
Information for Californian consumers
Information for Users residing in Brazil
1.1PDF reader for all(hereinafter referred to as "We" or "us" or "our") takes user privacy very seriously, and We are committed to protecting and respecting user privacy. This value drives all of the decisions We make, including how We collect, use, share, store and respect Users' personal information.
1.2 We are both the data controller and the data processor who determines the purposes and methods of the data processing in relation to your personal data collected by us and is responsible for the data processing in relation to your use of our services. If you have any questions, you can contact us at the following flyfish202301@gmail.com
2.1 The types of personal data collected by this Application, either directly or through third parties, include the following Tracking Data:
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device, below list can provide a non-exclusive list of the contents of Usage Data:
Hardware model;
Information about operating system and its version;
Screen size and density;
Language and country;
Unique device identifiers (e.g. IDFA);
Time zone;
Device mute status (related to reminder function)
In order to provide a better user experience, we have integrated data statistics tools in the App, they won't collect users’ health data or privacy data and are only used for CRASH targeting and AB-testing for new features and design， The details are as follows:
Device information
Screen Size
OEM Name
Model
Device system information
OS Name
OS Version
OS Build
Time Zone
System Language
Carrier Country
Carrier Name
Location information
Locale
Country Area
Application information
App Name
App Build
APP Version Number
SDK Name
SDK Version
In order to provide a better user experience, when it's failed to read files, we may upload your file to our cloud server to locate and fix the issue. Please rest assured that we will never share your information with any third parties without your consent, as described in this Privacy Policy, or in connection with the provision of document reading services.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.
Your Consent and Our Use of Your Personal Data
By creating a profile or registering to use our apps, you expressly agree to:
We may process the account data you provide by using the app and create it through your account only for the purposes of login or registration, third-party services, such as Apple ID, Google account and Facebook account.
Except as provided in this privacy policy, we will not transfer any of your personal data to third parties.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to advertise on third party websites to You after You visited our Service, for payment processing, to contact You.
Third-Party Advertisers - We may use third-party advertising companies to serve ads when you visit the Application. These companies may use information about your visits to the app that are contained in cookies in order to optimize the performance of the marketing campaigns and provide ads about goods and services of interest to you. We NEVER shares any data you are tracking in the app (e.g. when you get your Personal Data) with third-Party Advertisers.
Analytics - We use third party analytics tools, Google Analytics, to help us measure traffic and usage trends for the Service. Google Analytics collects information such as device, location and app usage information. We may use the information get from Google Analytics only to customize and personalize your App experience for statistical purposes and analytics.
For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
Security of Your Personal Data
We use administrative, technical, and physical security measures to help protect your personal information. We use the following information security measures to protect your personal data:
Encrypt your personal data during transport and rest;
System vulnerability scanning and penetration testing;
Protect data integrity;
Organizational and legal measures.
Perform regular data protection impact assessments.
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Media Library for setting ringtones or wallpapers (user permission options);
Unique Device Identifiers for advertising (e.g. Google Advertiser ID or IDFA);
Application Updates.
2.2 Full details of each type of personal information collected are provided in the relevant sections of this Privacy Policy or through specific explanatory text displayed prior to data collection.
2.3 Users may provide Personal Data free of charge, and in some cases the Application will collect this data only after the User has agreed to open permissions or automatically collect usage data when using the Application.
2.4 Unless otherwise specified, all data requested by this Application is mandatory and failure to provide such 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, you are free not to provide this data without consequences for the availability or functioning of the Service.
2.5 If you are not sure which personal data is mandatory, you are welcome to contact us.
2.6 Any use of cookies - or other tracking devices - by this Application or by us in third party services used by this Application is for the purpose of providing the Service requested by the User, in addition to any other purposes described in this Policy and in the Cookie Policy, if any.
2.7 You are responsible for any third party personal data that you obtain, publish or share through this Application and confirm that you have the consent of the third party to provide the data to us.
3.1 Processing Methods
We take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. The processing of the data is carried out with the help of computers and/or IT-supported tools, according to organizational procedures and modes that are strictly related to the stated purposes. In addition to us, in some cases the data may be accessible to certain types of persons involved in the operation of this application (administration, sales, marketing, legal, system administration) or to external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies), which we may designate as data processors. An updated list of these parties may be requested from us at any time.
3.2 Legal basis for processing
We may process Personal Data relating to You if one of the following applies:
You have given their consent for one or more specific purposes. Note: Under some legislations We 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 We are subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
In any case, We 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.
3.3 Location
The data will be processed in our offices and in any other place where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve the transfer of the User's data to a country other than his or her own. To find out more about the place of processing of such transferred data, you may consult the section containing details about the processing of personal data.
You also have the right to learn about the legal basis of data transfers to a country outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the United Nations, and about the security measures we take to protect your data.
If such a transfer takes place, you can find out more by reviewing the relevant sections of this Policy or by contacting us using the information provided in the Contact Us section.
3.4 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 You and us shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests pursued by us within the relevant sections of this Policy or by contacting us.
We 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, We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
4.1 Information about the User is collected to enable us to provide the Service, comply with our legal obligations, respond to law enforcement requests, protect our rights and interests (or those of our users or third parties), detect malicious or fraudulent activity, and for the following purposes Advertising, Analytics, Platform Services and Hosting, and Hosting and Backend Infrastructure.
4.2 For specific information on the Personal Data used for each purpose, the User may refer to the section "Detailed information on the processing of Personal Data".
Personal information is collected for the following purposes and services:
5.1 Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify You or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, You may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this Policy.
AdMob (Google LLC)
AdMob is an advertising service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy (https://policies.google.com/technologies/partner-sites).
PERSONAL DATA PROCESSED: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Meta（Facebook）
Meta is an advertising service provided by Facebook.
In order to understand Facebook's use of Data, consult Facebook's partner policy (https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0).
PERSONAL DATA PROCESSED: Tracker; unique device identifiers for advertising ; Usage Data.
5.2 Analytisc
The services contained in this section enable us to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics for Firebase (Google LLC)
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy (https://policies.google.com/technologies/partner-sites).
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 us.
This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
You 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 PROCESSED: Application updates; Usage Data.
5.3 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 services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google BigQuery (Google LLC)
Google BigQuery is a hosting and backend service provided by Google LLC.
PERSONAL DATA PROCESSED: various types of Data as specified in the privacy policy of the service.
5.4 Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to us – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google Play Store (Google LLC)
This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with us. Much of this information is processed on an opt-in basis.
You may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
PERSONAL DATA PROCESSED: Usage Data.
5.5 About the porcessing mentioned above
Place of all of this processing: United States:
Privacy Policy (https://policies.google.com/privacy)
Category of personal information collected according to CCPA: identifiers; internet information.
All of 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.
In addition to any opt-out feature provided by any of the services listed in this Policy, You may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
8.1 You may exercise certain rights regarding their Data processed by us.
8.2 In particular, You have the right to do the following:
Withdraw your consent at any time. You have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of your Data. You 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 your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. You have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of their Data. In this case, We will not process their Data for any purpose other than storing it.
Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Data from us.
Receive your Data and have it transferred to another controller. You have the right to receive your 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. You have the right to bring a claim before your competent data protection authority.
8.3 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 us or for the purposes of the legitimate interests pursued by us, You may object to such processing by providing a ground related to your particular situation to justify the objection.
You 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 We are processing Personal Data for direct marketing purposes, You may refer to the relevant sections of this Policy.
8.4 How to exercise these rights
Any requests to exercise User rights can be directed to us through the contact details provided in this Policy. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.
We may use cookies, or similar technologies on our Apps to store information locally on your device(s) (hereinafter referred to as “Cookies”). Cookies may be used to track the browsing activities of visitors on our Apps, count the number of unique visitors, and facilitate better use of our Apps and/or services. Please refer to our Cookies Policy for further information. Cookies will be saved to your device(s) after You have accepted our Cookies Policy which will be presented to You when You required to log in to your account on a social platform. Such Cookies will be deleted when You log out. PLEASE NOTE THAT You may become unable to use our services or functions that rely on Cookies if You decline such Cookies.
Our Service does not address anyone under the age of 3. We do not knowingly collect personally identifiable information from anyone under the age of 3. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 3 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
11.1 Legal action
The User's Personal Data may be used for legal purposes by us 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 We may be required to reveal personal data upon request of public authorities.
11.2 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.
11.3. 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.
11.4 Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this Policy.
11.5 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.
11.6 Changes to this privacy policy
We reserve the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to You via any contact information available to us. 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, We shall collect new consent from the User, where required.
12.1 This part of the Policy integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates.
12.2 The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018", and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in this privacy policy.
12.3 This part of the Policy uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).
12.4 Categories of personal information collected, disclosed or sold
In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this Policy.
12.5 Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, commercial information and internet information.
We will not collect additional categories of personal information without notifying you.
12.6 How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
12.7 How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.
To find out more about the purposes of processing, please refer to the relevant section of this Policy.
12.8 Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
12.9 Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.
12.10 Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this Policy.
12.11 What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this Policy), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
12.12 Your California privacy rights and how to exercise them
The right to know and to portability
You have the right to request that we disclose to you:
the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose: for sales, the personal information categories purchased by each category of recipient; and for disclosures for a business purpose, the personal information categories obtained by each category of recipient. The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
12.13 The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.
12.14How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this Policy.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
12.15 How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12 month period.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
13.1 This part of the Policy integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates.
13.2 The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados". For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in this privacy policy.
13.3 This part of the Policy uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).
13.4 The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party; the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this Policy.
13.5 Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this Policy.
13.6 Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this Policy.
13.7 Your Brazilian privacy rights, how to file a request and our response to your requests
You have the right to:
obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified; obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
13.8 How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this Policy, or via your legal representative.
13.9 How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an ACCESS or PERSONAL INFORMATION processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
13.10 How and when we will respond to your request
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.