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Website Privacy Notice (www.zilo.co.uk)

Privacy Policy of

Introduction

This privacy policy is provided by 91���� Technology Limited (Company number 12564726) and all of its affiliates (referred to throughout this privacy policy as “91����”, “we”, “our” or “us”). The full list of these entities can be found in the section “91���� Entities”. This privacy policy applies to individuals (“You” or “Your”) whose personal data we collect in relation to the purposes as set out in this privacy policy.

For the purposes of the UK Data Protection Act 2018 and the UK General Data Protection Regulation and, where applicable, the EU General Data Protection Regulation (collectively the “European Data Protection Laws”), 91���� Technology Limited is a controller of the personal data processed as set out in this privacy policy.

This privacy policy contains specific information for individuals (including their privacy rights) in the following locations:

• Switzerland
• Brazil
• California
• Virginia
• Colorado
• Connecticut
• Utah

This document can be printed for reference by using the print command in the settings of any browser.

How to Contact Us

For any questions on how we process personal data referred to in this privacy policy, please use the below contact details:

Name: 91���� Technology Limited

Address: 5 Fleet Place, London, England EC4M 7RD

Email: privacy@zilo.co.uk

Changes to this Privacy Policy

We may amend this privacy policy from time to time. Any changes will be posted on this Website and will be notified to You, to the extent required by applicable law.

This policy was last reviewed and updated 28 February 2024.

Types of Personal Data Processed

We collect the following types of personal data directly from You (unless stated otherwise): Usage Data; Enquiries Data; and Sales and Admin Data.

Usage Data

• Categories of Data Subjects – Individuals who use this website - (the “Website”).
• Types of personal data - Information about Your usage of the Website including IP addresses or domain names of the computers utilized by You, URI addresses (Uniform Resource Identifier), the time of the request, the method utilised 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 You, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or Your IT environment.

Enquiries Data

• Categories of Data Subjects – Individuals who send general enquiries to us.
• Types of personal data - Name, organisation, contact details, details of the enquiry

Sales and Admin Data

• Categories of Data Subjects – Individuals who work for our customers, suppliers, partners and advisors
• Types of personal data - Name, organisation, contact Details

Cookies - For more information about the use of cookies in this Website please refer to our /cookie-settings ��.

Purposes and Lawful Bases of Processing

We have set out below the purposes of processing Your personal data and the lawful bases we rely on:

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Legitimate Interest

Where we rely on “legitimate interest” as the lawful basis of processing this means we are permitted to process Your personal data if we have a good, sensible and practical reason for processing Your personal data which is in our interest. To do so, we have considered the impact on Your interests and rights and have placed appropriate safeguards to ensure that the intrusion on Your privacy is reduced as much as possible.

You can object to the processing that we carry out on the grounds of legitimate interests. Please see the section headed “Rights in relation to Your Personal Data” for more information.

Consent

Where we rely on “consent” as the lawful basis of processing please note that You can withdraw Your consent at any time in a way that is entirely optional for You.

Rights in relation to Your Personal Data

Details of Your Rights

As a data subject, You have the following rights under the applicable data protection laws:

• ‍Withdraw Your consent – Where we rely on consent as the lawful basis of processing Your personal data, You have the right to withdraw Your consent at any point. This is a vital and necessary aspect of consent. You can withdraw Your consent in the same way You provided Your consent in the first place.
• ‍Object to processing of Your personal data - You have the right to object to the processing of Your personal data where we rely on “legitimate interest” as the lawful basis of our processing. If You object to us processing Your personal data, we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated such compelling grounds in the section “Purposes and Lawful Bases of Processing”.
• ‍Access Your personal data - You have the right to request access to Your personal data that we process. This is often referred to as a “data subject access request”. This enables You to receive a copy of Your personal data and to check that we are lawfully processing it.
• ‍Verify and seek rectification of Your personal data – You can require us to correct any mistakes in Your personal data which we hold. If You would like us to do this, please let us know the personal data which is incorrect and what it should be replaced with.
• ‍Restrict the processing of Your personal data - You can ask us to suspend the processing of Your personal data in the following circumstances: (a) if You want us to establish the accuracy of Your personal data; (b) where our use of the personal data is unlawful but You do not want us to erase it; (c) where You need us to hold personal data even if we no longer require it as You need it to establish, exercise or defend legal claims; or (d) You have objected to our use of Your personal data but we need to verify whether we have overriding legitimate grounds to use it.
• ‍Deletion of Your personal data – You can ask us to delete or remove Your personal data where there is no good reason for us to process it. You also have the right to ask us to delete or remove Your personal data where You have successfully exercised Your right to object to processing (as explained in this section), where we may have processed Your personal data unlawfully or where we are required to erase Your personal data to comply with local law. Note, however, that we may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.
• ‍Port Your personal data to another controller – You can ask us to provide to You, or a third party You have chosen, Your personal data in a structured, commonly used, machine-readable format. This allows You to manage and reuse Your personal data. Please note that this right only applies to automated information which we process based on Your consent or for the performance of a contract You.
• ‍Not to be subject to solely automated decisions – You have the right to not be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning You or similarly significantly affect You. We do not make any automated decisions about You and so this right does not apply.

Exercising Your Rights

We will respond to any rights that You exercise within one calendar month of receiving Your request, unless the request is particularly complex, in which case we will respond within three calendar months.

You will not have to pay a fee to access Your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with Your request in these circumstances.

Please be note that these rights may not apply in all cases and we will apply exemptions to Your rights only in accordance with the applicable data protection laws.

Right to Make a Complaint

If You have any comments, concerns or complaints about the use of Your personal data by us, please contact us using the details in the section “How to Contact Us”.

You may be entitled to compensation for damage caused by our breach of the European Data Protection Laws.

You can also raise any concerns or complaints about how we process Your personal data to Your local supervisory authority. In the UK, this is the Information Commissioner’s Office (the “ICO”) and You can contact them by calling 0303 123 1113 or via the ICO’s live chat function available here .

Security

We have put in place appropriate security measures to prevent unauthorized access, disclosure, modification, unauthorized destruction or accidental loss or use of the personal data.

The personal data is processed under strict organisational procedures and modes specifically related to the relevant purposes. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to manage any suspected personal data breach and will notify the regulator and data subjects (as applicable) of a breach where we are legally required to do so.

Retention of Your Personal Data

We will only retain Your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your personal data, the purposes for which we process Your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

The retention period for the personal data we process is as below:

• Usage Data – 1 year from date of collection
• Enquiries Data – 6 months from resolution of enquiry
• Sales and Admin Data – For the term of the relevant agreement and 7 years after its termination

Once the retention period expires, the personal data shall be deleted.

Sharing Personal Data

Internal Parties

91���� Technology Limited (“91���� UK”) shares Usage Data, General Enquiries and Sales and Admin Data with its affiliates listed in the section “91���� Entities” for their business activities and to provide support to 91���� UK. Where an affiliate processes personal data for its business activities, it acts as a separate controller and where an affiliate provides support to another affiliate, the affiliate providing the supports acts as the processor of the affiliate receiving the support.

External Parties

We appoint third party providers that act as our processors for the operation of the Website as set out below. Please note that these providers can also act as separate controllers where they engage in processing of personal data for their own purposes. Please refer to their privacy policy for more information.

Webflow, Inc. (“Webflow”)

Webflow provides platform services and hosting for the operation of the Website.

Webflow’s place of processing is in USA. Its privacy policy can be accessed here .

For CCPA purposes, the category of personal information collected include internet or other electronic network activity information. This processing constitutes a sale according to the CPA, CTDPA and UCPA.

Google Ireland Limited (“Google”)

Google provides Google Analytics, a web analysis service. Google utilizes the Data collected to examine the use of this Website, to prepare reports on its activities and share them with other Google services.

Google uses the personal data collected to contextualize and personalize the ads of its own advertising network.

Google’s place of processing is in Republic of Ireland. Its privacy policy can be accessed here and its Google Analytics opt-out browser add-on can be accessed here .

For CCPA purposes, the category of personal information collected include internet or other electronic network activity information. This processing constitutes a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.

Microsoft Corporation (“Microsoft”)

Microsoft provides heat mapping services which provides information on how You are using the Website.

Microsoft uses the personal data collected in accordance with the Microsoft Privacy Statement (which can be accessed here ) including improving and providing Microsoft Advertising.

Microsoft’s place of processing is USA.

For CCPA purposes, the category of personal information collected include internet or other electronic network activity information. This processing constitutes a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.

We have contracts in place with these third party providers. To the extent they act as our processors, they cannot do anything with the personal data unless we have instructed them to do it and they will hold it securely and retain it for the period based on our instructions. When it is necessary for us to transfer Your personal data outside of the UK this will only be done in accordance with the applicable laws, including the European Data Protection Laws.

You can request an updated list of these parties at any time using the contact details in the section “How to Contact Us”.

International Transfer of Personal Data

Internal and external parties with whom we share personal data are based outside the UK and European Economic Area (“EEA”) so their processing of Your personal data will involve a transfer of data outside the UK and EEA.

Whenever we transfer Your personal data out of the UK and EEA, we will take reasonable steps to ensure that Your personal data is kept secure, including where relevant, by entering into appropriate contractual terms with the receiving party outside the UK and EEA, such as the standard contractual clauses approved by the EU Commission or issued by the UK Information Commissioner’s Office (as applicable) or any other approved mechanisms that may become available to us in the future. We will also carry out a risk assessment of the laws and practices of the destination country to identify any technical and organisational measures that need to be put in place to ensure that Your personal information is fully protected when in that country.

Further information for Individuals in Switzerland

This section applies to You if You are in Switzerland. The processing of Your personal information will be governed by the Swiss Federal Act on Data Protection. In the event of conflict between this section and the other sections of this privacy policy, this section applies.

For information about the processing of Your personal data, please refer to the sections indicated below:

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Your Rights according to the Swiss Federal Act on Data Protection

You may exercise certain rights regarding their personal data within the limits of law, including the following:

• right of access to personal data;
• right to object to the processing of their personal data (which also allows You to demand that processing of personal data be restricted, personal data be deleted or destroyed, specific disclosures of personal data to third parties be prohibited);
• right to receive their personal data and have it transferred to another controller (data portability);
• right to ask for incorrect personal data to be corrected.

How to exercise these rights

Any requests to exercise Your rights can be directed to us using the contact details in the section “How to Contact Us”. Such requests are free of charge and will be answered by us as early as possible, providing You with the information required by law.

Further information for Individuals in Brazil

This section applies to You if You are in Brazil. The processing of Your personal information will be governed by the "Lei Geral de Proteção de Dados" (the "LGPD"). In the event of conflict between this section and the other sections of this privacy policy, this section applies. Reference to “personal information” is as defined in the LGPD.

Grounds on which we process Your personal information

We can process Your personal information 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;
• 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 You 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 in the section “How to Contact Us”.

Categories of personal information processed

To find out what categories of Your personal information are processed, please refer to the section “Types of Personal Data Processed” within this privacy policy.

Why we process Your personal information

To find out why we process Your personal information, You can refer to the section “Purposes and Lawful Bases of Processing”.

Your Brazilian privacy rights

You have the right to:

• obtain confirmation of the existence of processing activities on Your personal information;
• access to Your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of Your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny Your consent and the consequences thereof;
• obtain information about the third parties with whom we share Your personal information;
• obtain, upon Your express request, the portability of Your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of Your personal information being processed if the processing was based upon Your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke Your consent at any time;
• lodge a complaint related to Your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of Your personal information, which affect Your interests. These include decisions to define Your personal, professional, consumer and credit profile, or aspects of Your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if You exercise Your rights.

How to file Your request

You can file Your express request to exercise Your rights free from any charge, at any time, by the contact details in the section “How to Contact Us”, or via Your legal representative.

How and when we will respond to Your request

We will strive to promptly respond to Your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to You the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with Your requests. In cases where we are not processing Your personal information, we will indicate to You the physical or legal person to whom You should address Your requests, if we are in the position to do so.

In the event that You file an access or personal information processing confirmation request, please make sure that You specify whether You’d like Your personal information to be delivered in electronic or printed form.

You will also need to let us know whether You want us to answer Your request immediately, in which case we will answer in a simplified fashion, or if You need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of Your request, providing You with all the information on the origin of Your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that You file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate Your request to other parties with whom we have shared Your personal information in order to enable such third parties to also comply with Your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer Your personal information outside of the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect Your life or physical security or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Further information for California consumers

This section applies to You if You are in the state of California, USA. The processing of Your personal information will be governed by the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. In the event of conflict between this section and the other sections of this privacy policy, this section applies.

For the purposes of this section, the term “personal information“ is as defined in the California Consumer Privacy Act (CCPA/CPRA).

Information we collect: the categories of personal information we collect

For information about the types of personal information we collect, please refer to the section “Types of Personal Data Processed”.

We do not collect sensitive personal information.

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

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

We may use Your personal information for the purposes set out in the section “Purposes and Lawful Bases of Processing”. Where we use Your personal information it will be processed in a manner necessary and proportionate to the 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 complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

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

How long do we keep Your personal information?

Please refer to the section “Retention of Your Personal Data” for information about how long we process Your personal information.

How we collect information: what are the sources of the personal information we collect?

We collect your personal information directly from You when You use this Website or send personal information to us (unless stated otherwise).

For example, You directly provide Your personal information when You submit requests to us. You also provide personal information indirectly when You navigate this Website, as personal information about You is automatically observed and collected.

We may collect Your personal information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.

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

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

We disclose Your personal information with the third parties as set out in the section “Sharing Personal Data”.  These third parties are grouped and categorized in accordance with the different purposes of processing.

Sale or sharing of Your personal information

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

This means that, for example, a sale can happen whenever an application makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.

Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of Your personal information.

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

We sell or share Your personal information with the third parties listed in detail in the section titled “Sharing Personal Data”. These third parties are grouped and categorized in accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of Your personal information. This means that whenever You request us to stop selling or sharing Your personal information, we will abide by Your request.

Such requests can be made freely, at any time, without submitting any verifiable request.

To fully exercise Your right to opt out, You can contact us at any time using the contact details provided in the section “How to Contact Us”.

For a simplified opt-out method You can also use the privacy choices link provided on this Website.

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

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

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

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

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

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

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

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

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

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

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

The right to request the deletion of Your personal information

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

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

The right to correct inaccurate personal information

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

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

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

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

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

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

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

How to exercise Your rights

To exercise the rights described above, You need to submit Your verifiable request to us by contacting us using the contact details in the section “How to Contact Us”.

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; and
• describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

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

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

If You are an adult, You can make a verifiable request on behalf of a child under Your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle Your request

We will confirm receipt of Your verifiable request within 10 days and provide information about how we will process Your request.

We will respond to Your request within 45 days of its receipt. Should we need more time, we will explain to You the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill Your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, You have the right to request that we disclose information beyond the 12-month period, and we will provide them to You unless doing so proves impossible or would involve a disproportionate effort.

Should we deny Your request, we will explain You the reasons behind our denial.

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

Further information for Virginia consumers

This section applies to You if You are in the Commonwealth of Virginia, USA. The processing of Your personal information will be governed by the “Virginia Consumer Data Protection Act" (the "VCDPA"). In the event of conflict between this section and the other sections of this privacy policy, this section applies.

This part of the document uses the term “personal data” as defined in the VCDPA.

Categories of personal data processed

To find out what categories of Your personal data are processed, please refer to the section “Types of Personal Data Processed” within this privacy policy.

We do not collect sensitive data.

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

Why we process Your personal data

To find out why we process Your personal data, You can refer to the section “Purposes and Lawful Bases of Processing”.

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

You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

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

We disclose Your personal data with the third parties as set out in the section “Sharing Personal Data”.  These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

Sale of Your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party” as defined by the VCDPA.

Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by You.

As specified in the section “Sharing Personal Data” our use of Your personal data may be considered a sale under VCDPA.

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

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

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

Processing of Your personal data for targeted advertising

We do not process Your personal data for targeted advertising. If we decide to do so, we will inform You beforehand and will grant Your right to opt out of the processing of Your personal data for targeted advertising.

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

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

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

How to exercise Your rights

To exercise the rights described above, You need to submit Your request to us by contacting us via the contact details provided in the section “How to Contact Us”.

For us to respond to Your request, we need to know who You are.

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

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

If You are an adult, You can make a request on behalf of a child under Your parental authority.

How and when we are expected to handle Your request

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

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

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

Further information for Colorado consumers

This section applies to You if You are in the state of Colorado, USA. The processing of Your personal information will be governed by the “Colorado Privacy Act" (the "CPA"). In the event of conflict between this section and the other sections of this privacy policy, this section applies.

This part of the document uses the term “personal data” as defined in the CPA.

Categories of personal data we collect and process

For information about the types of personal data we collect, please refer to the section “Types of Personal Data Processed”.

We do not collect sensitive data.

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

Why we process Your personal data

To find out why we process Your personal data, please refer to the section “Purposes and Lawful Bases of Processing”.

We will not process Your personal data for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without Your consent.

You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

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

We disclose Your personal data with the third parties as set out in the section “Sharing Personal Data”. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.

Sale of Your personal data

As specified in the section “Sharing Personal Data” our use of Your personal data may be considered a sale under the CPA.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CPA.

Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by You.

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

You have the right to opt out of the sale of Your personal data. This means that whenever You request us to stop selling Your data, we will abide by Your request.

To fully exercise Your right to opt out You can contact us at any time, using the contact details provided in the section “How to Contact Us”.

For a simplified opt-out method You can also use the privacy choices link provided on this Website.

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

Processing of Your personal data for targeted advertising

We do not use your personal data for targeted advertising purposes.

For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non-affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CPA.

Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.

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

You have the right to opt out of the processing of Your personal data for targeted advertising if applicable. This means that whenever You ask us to stop processing Your data for targeted advertising (if applicable), we will abide by Your request.

To fully exercise Your right to opt out You can contact us at any time, using the contact details provided in the section “How to Contact Us”.

For a simplified opt-out method You can also use the privacy choices link provided on this Website.

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

Universal opt-out mechanism: Global privacy control

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

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

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

• opt out of the processing of Your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.
• access personal data. You have the right to request that we confirm whether or not we are processing Your personal data. You also have the right to access such personal data.
• correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about You, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• request the deletion of Your personal data. You have the right to request that we delete any of Your personal data.
• obtain a copy of Your personal data. We will provide Your personal data in a portable and usable format that allows You to transfer data easily to another entity – provided that this is technically feasible.

In any case, the exercise of any of Your rights does not affect Your use of the Website or our services to You. To the extent permitted by the law, we may offer, to the extent applicable, a different price, rate, level, quality, or selection of goods or services to You, including offering goods or services for no fee, if our offer is related to Your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise Your rights

To exercise the rights described above, You need to submit Your request to us by contacting us using the details in the section “How to Contact Us”.

For us to respond to Your request, we need to know who You are and which right You wish to exercise.

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

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

If You are an adult, You can make a request on behalf of a child under Your parental authority.

How and when we are expected to handle Your request

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

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

We do not charge a fee to respond to Your request, for up to two requests per year.

Further information for Connecticut consumers

This section applies to You if You are in the State of Connecticut, USA. The processing of Your personal data will be governed by “An Act Concerning personal data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"). In the event of conflict between this section and the other sections of this privacy policy, this section applies.

This part of the document uses the term “personal data” as defined in the CTDPA.

Categories of personal data we collect

For information about the categories of personal data we collect and process, You can refer to the section “Types of Personal Data Processed”.

We do not collect sensitive data.

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

Why we process Your personal data

For information about the purposes of our processing of Your personal data, You can refer to the section “Purposes and Lawful Bases of Processing”.

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

You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

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

We share Your personal data with the third parties listed in the section “Sharing Personal Data”. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.

Sale of Your personal data

As specified in the section the section “Sharing Personal Data”, our use of Your personal data may be considered a sale under the CTDPA.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.

Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by You.

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

You have the right to opt out of the sale of Your personal data. This means that whenever You request us to stop selling Your data, we will abide by Your request.

To fully exercise Your right to opt out You can contact us at any time, using the contact details provided in the section “How to Contact Us”.

For a simplified opt-out method You can also use the privacy choices link provided on this Website.

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

Processing of Your personal data for targeted advertising

We do not use your personal data for targeted advertising purposes.

For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CTDPA.

Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.

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

You have the right to opt out of the processing of Your personal data for targeted advertising. This means that whenever You ask us to stop processing Your data for targeted advertising (if applicable), we will abide by Your request.

To fully exercise Your right to opt out You can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method You can also use the privacy choices link provided on this Website.

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

Universal opt-out mechanism: Global privacy control

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

Your privacy rights under the Connecticut Data Privacy Act and how to exercise them

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

• access personal data. You have the right to request that we confirm whether or not we are processing Your personal data. You also have the right to access such personal data.
• correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about You, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• request the deletion of Your personal data. You have the right to request that we delete any of Your personal data.
• obtain a copy of Your personal data. We will provide Your personal data in a portable and usable format that allows You to transfer data easily to another entity – provided that this is technically feasible.
• opt out of the processing of Your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

In any case, the exercise of any of Your rights does not affect Your use of the Website or our services to You. To the extent permitted by the law, we may offer, to the extent applicable, a different price, rate, level, quality, or selection of goods or services to You, including offering goods or services for no fee, if our offer is related to Your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise Your rights

To exercise the rights described above, You need to submit Your request to us by contacting us using the details in the section “How to Contact Us”.

For us to respond to Your request, we need to know who You are and which right You wish to exercise.

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

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

If You are an adult, You can make a request on behalf of a child under Your parental authority.

How and when we are expected to handle Your request

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

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

We do not charge a fee to respond to Your request, for up to one request per year.

Further information for Utah consumers

This section applies to You if You are in the State of Utah, USA. The processing of Your personal information will be governed by the “Consumer Privacy Act" (the “UCPA"). In the event of conflict between this section and the other sections of this privacy policy, this section applies.

This part of the document uses the term “personal data” as defined in the UCPA.

Categories of personal data we collect

For information about the types of personal data we collect, please refer to the section “Types of Personal Data Processed”.

We do not collect sensitive data.

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

Why we process Your personal data

To find out why we process Your personal data, please refer to the section “Purposes and Lawful Bases of Processing”.

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

We disclose Your personal data with the third parties as set out in the section “Sharing Personal Data”. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.

Sale of Your personal data

As specified in the section “Sharing Personal Data”, our use of Your personal data may be considered a sale under the UCPA.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.

Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by You.

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

You have the right to opt out of the sale of Your personal data. This means that whenever You request us to stop selling Your data, we will abide by Your request.

To fully exercise Your right to opt out You can contact us at any time, using the contact details provided in the section “How to Contact Us”.

For a simplified opt-out method You can also use the privacy choices link provided on this Website.

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

Processing of Your personal data for targeted advertising

We do not use your personal data for targeted advertising purposes.

For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non-affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by UCPA.

Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”

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

You have the right to opt out of the processing of Your personal data for targeted advertising if applicable. This means that whenever You ask us to stop processing Your data for targeted advertising (if applicable), we will abide by Your request.

To fully exercise Your right to opt out You can contact us at any time, using the contact details provided in the section “How to Contact Us”.

For a simplified opt-out method You can also use the privacy choices link provided on this Website.

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

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

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

• access personal data. You have the right to request that we confirm whether or not we are processing Your personal data. You also have the right to access such personal data.
• request the deletion of Your personal data. You have the right to request that we delete any of Your personal data.
• obtain a copy of Your personal data. We will provide Your personal data in a portable and usable format that allows You to transfer data easily to another entity – provided that this is technically feasible.
• opt out of the processing of Your personal data for the purposes of targeted advertising or the sale of personal data.

In any case, the exercise of any of Your rights does not affect Your use of the Website or our services to You. To the extent permitted by the law, we may offer, to the extent applicable, a different price, rate, level, quality, or selection of goods or services to You, including offering goods or services for no fee, if our offer is related to Your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise Your rights

To exercise the rights described above, You need to submit Your request to us by contacting us using the details in the section “How to Contact Us”.

For us to respond to Your request, we need to know who You are and which right You wish to exercise.

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

If You are an adult, You can make a request on behalf of a child under Your parental authority.

How and when we are expected to handle Your request

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

Should we deny Your request, we will explain to You the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.

We do not charge a fee to respond to Your request, for up to one request per year.

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