Privacy Policy

Privacy Policy

Data Management Entity:
Lestas, UAB – 3-14A, Gelezinkelio str., Vilnius, Lithuania, 02100 Contact for inquiries: [email protected]

Data Collection Types

This platform collects personal information either directly from users or through third parties, including but not limited to: names, phone numbers, email addresses, as well as Cookies and data on how the service is utilized. Detailed explanations regarding each type of collected data are available within specific sections of this privacy policy or through explanatory notes presented before data gathering.

Users have the option to provide personal data voluntarily or it might be collected automatically when they engage with the service. The requirement for data submission is mandatory for the most part, without which service provision might be compromised. However, if certain data is not obligatory, users can choose not to provide it without affecting the service’s functionality.

For any uncertainties regarding obligatory personal data, users can reach out to the data controller.

Cookies and similar tracking technologies are used by this platform or by third-party services to enhance user experience and for other purposes outlined in this document and the Cookie Policy. Users must assume responsibility for any third-party personal data shared through this platform.

Data Processing Methods and Locations

Data security measures are rigorously applied to prevent unauthorized access or data breaches. Processing involves the use of electronic or IT-based tools, adhering to operational procedures aligned with the stated purposes. Data may be accessible to certain assigned individuals or external entities (like technical service providers or IT firms), acting under the data controller’s authorization, with an option to request an updated list of these entities at any time.

Data Handling and Storage Locations

Data processing and storage occur at the data controller’s premises and other locations where involved parties operate.

Data may be transferred across borders depending on the user’s location, potentially to countries different from the user’s residence. Users can review the Personal Data processing section for more details on data transfer locations.

Retention Period

Personal data is retained as long as necessary for the purposes collected and may extend beyond due to legal requirements or user consent.

Purpose of Data Collection

User data is collected to enable service provision, legal compliance, response to requests, protection of rights, fraud detection, and for purposes including user communication, analytics, spam prevention, social network interactions, external content display, tag management, database management, and backend infrastructure.

Specific uses of personal data for these purposes are detailed in the “Detailed Information on the Processing of Personal Data” section.

Detailed Data Processing Information

Personal data is utilized in various services for purposes such as analytics, user communication, content display from external platforms, and interaction with social networks, among others. Services like Google Analytics help monitor web traffic and user behavior, with data processing locations and privacy options outlined for each service. Data categories according to legal frameworks like the CCPA are mentioned, including the nature of processing activities like sales or targeted advertising.

For direct user interactions, such as contact forms or phone contacts, personal data like email addresses and phone numbers are used, with specific data categories and processing implications noted under legal standards.

Protection Against SPAM

Services in this category are designed to analyze the application’s traffic, which may include Personal Data of users, aiming to sift through the traffic to identify and filter out SPAM. Google reCAPTCHA, offered by Google Ireland Limited, serves as a SPAM prevention mechanism. Its application is governed by Google’s privacy terms and conditions. Data handled includes Cookies and usage details, with processing in Ireland as per Google’s Privacy Policy. Under the CCPA, this falls under the collection of internet information. The activities involved are considered a sale and targeted advertising under laws like the CPA, CTDPA, and UCPA.

Management of Tags

These services assist the application’s owner in organizing and managing tags or scripts in a unified manner, which could result in the collection and storage of user data. Google Tag Manager by Google Ireland Limited is one such service, streamlining tag management. It processes Usage Data, with Ireland being the processing location, according to Google’s Privacy Policy. As per the CCPA, it is categorized under internet information collection, and its use is deemed a sale and involves targeted advertising per the CPA, CTDPA, and UCPA.

Management of User Databases

These tools enable the application owner to create user profiles from email addresses, names, or other data provided by users, alongside tracking user activity via analytics. This data can be combined with public information (like social media profiles) to craft detailed profiles for display and application enhancement. Certain services may also facilitate timed communication with users, such as emails triggered by specific app interactions. Intercom, by Intercom Inc., offers user database management capabilities and serves as a communication platform within the application or via email. Handled data includes Cookies, email addresses, usage information, and other types as outlined in their privacy policy, processed in the United States. According to the CCPA, this involves the collection of identifiers and internet information, recognized as a sale and targeted advertising under various consumer privacy acts.

Basis for Data Processing

The processing of Personal Data concerning users is permissible under certain conditions, including:

• When users have explicitly consented to one or more specific uses of their data.
• If data provision is essential for the execution of a contract with the user or to meet pre-contractual obligations.
• To comply with legal obligations that the Owner must adhere to.
• When processing is carried out in the public interest or under the exercise of official authority vested in the Owner.
• For the fulfillment of legitimate interests pursued by the Owner or a third party.

The Owner is committed to clarifying the specific legal foundation of data processing, especially regarding whether providing Personal Data is a legal or contractual requirement, or necessary to conclude a contract.

Data Retention Clarification

Personal Data is processed and stored for the duration necessary for the purposes for which it was collected, extendable due to legal obligations or with the user’s consent. Thus:

• Data collected for contract performance between the Owner and the user will be retained until the contract is fully executed.
• Data gathered for the Owner’s legitimate interests will be kept as long as necessary to achieve these interests. The Owner provides specific details on these legitimate interests upon request.
• With user consent, data may be kept longer, provided the consent is not withdrawn. Additionally, legal obligations or authority orders may necessitate longer retention periods.

After the expiry of the retention period, Personal Data will be deleted, rendering the rights of access, erasure, rectification, and data portability unenforceable.

GDPR User Rights

Under GDPR, users can exercise certain rights regarding their processed data, including:

• Withdrawing consent at any time for previously consented data processing.
• Objecting to data processing, especially if processing is based on legal grounds other than consent.
• Accessing their data to check if the Owner is processing it, obtain disclosure about specific aspects of processing, and receive a copy of the data.
• Verifying and seeking correction of their data.
• Restricting the processing of their data, wherein the Owner will only store and not further process their data.
• Requesting deletion or removal of their Personal Data.
• Receiving their data in a structured format for transfer to another controller, if technically feasible.
• Lodging a complaint with the appropriate data protection authority.

Users are entitled to be informed of the legal basis for data transfers to countries outside their own or to international organizations and the security measures the Owner takes to protect their data.

Right to Object to Processing

Users may object to data processing when it is for a public interest, official authority, or legitimate interests pursued by the Owner. Users can present reasons specific to their situation to justify their objection. For direct marketing purposes, users can object without justification and at no cost. Upon objection, their data will not be processed for direct marketing.

Exercising User Rights

Requests to exercise user rights can be made to the Owner via provided contact details. These requests are free and will be addressed promptly within one month. The Owner will also communicate any data rectification, erasure, or processing restriction to each recipient of the data, unless this proves impossible or requires disproportionate effort, and inform the user about these recipients upon request.

Additional Information for Users in Brazil

This section complements and expands on the information provided in the rest of this privacy policy. It is presented by the entity managing this Application, including its parent companies, subsidiaries, and affiliates, collectively referred to as “we”, “us”, or “our”.

This section is specifically tailored for all users in Brazil, referred to as “you” or “your”, aligning with the “Lei Geral de Proteção de Dados” (LGPD). It prevails over any conflicting information you may find elsewhere in our privacy policy.

In this segment, “personal information” is utilized as defined by the LGPD.

Basis for Processing Your Personal Information

We process your personal information only when we have a lawful basis, which includes:

• Your consent for specific processing activities.
• Requirement to fulfill contractual or pre-contractual obligations with you.
• Compliance with legal or regulatory obligations.
• Execution of public policies outlined in laws or regulations, or grounded in contracts, agreements, or similar legal mechanisms.
• Conducting studies by research entities, preferably on anonymized data.
• Fulfillment of contracts where you are a party, or preliminary procedures thereof.
• Exercising our rights in judicial, administrative, or arbitration procedures.
• Ensuring the protection or physical safety of yourself or a third party.
• Health protection in operations performed by health entities or professionals.
• Pursuing our legitimate interests, unless your fundamental rights and freedoms override these interests.
• Credit protection.

For more details on these legal bases, feel free to contact us using the provided contact information.

Categories of Personal Information Processed

For specifics on which categories of your personal information we process, refer to the “Detailed information on the processing of Personal Data” section within this document.

Purposes for Processing Your Personal Information To understand why we process your personal information, you can consult the “Detailed information on the processing of Personal Data” and “The purposes of processing” sections of this document.

Your Privacy Rights in Brazil and How to Exercise Them As a Brazilian user, you have the right to:

• Confirm the existence of data processing activities on your personal information.
• Access your personal information.
• Correct incomplete, inaccurate, or outdated personal information.
• Anonymize, block, or delete unnecessary, excessive, or non-compliant personal information.
• Be informed about the possibility of denying consent and its consequences.
• Know about the third parties with whom we share your personal information.
• Request portability of your personal information to another service or product provider, safeguarding our trade secrets.
• Delete personal information processed with your consent, except under certain conditions outlined in the LGPD.
• Revoke your consent at any time.
• File a complaint regarding your personal information with the National Data Protection Authority (ANPD) or consumer protection bodies.
• Oppose processing activities that do not comply with legal standards.
• Seek clarification on the criteria and procedures for automated decision-making.
• Request review of decisions made solely on automated processing that affects your interests, including decisions about your personal, professional, consumer, and credit profile or aspects of your personality.

Exercising your rights will not result in any form of discrimination or detriment to you.

Filing a Request You may submit a request to exercise your rights at no cost, at any time, using the contact details provided in this document or through a legal representative.

Response to Your Request We are committed to responding to your requests promptly. If we cannot fulfill your request immediately, we will inform you of the factual or legal reasons for the delay or inability to fulfill your request. If we are not processing your personal information, we will direct you to the responsible party, if possible.

Transfer of Personal Information Outside Brazil The law permits us to transfer your personal information outside Brazil in specific cases, such as for international legal cooperation, to protect life or physical safety, upon authorization by the ANPD, for public policy or legal service execution, among others.

Further Information for California Consumers This section is designed for users residing in California, under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), and supplements the information in the privacy policy. It defines “personal information” as per CCPA/CPRA standards and outlines the categories of personal information collected, used, sold, or shared, along with your rights under the CCPA/CPRA, including the right to opt-out of the sale or sharing of your personal information, and how to exercise these rights.

Additional Information for Consumers in Virginia This portion of the document enhances and builds upon the privacy policy by including details specific to the operation of this Application and its affiliates, collectively referred to here as “we”, “us”, or “our”. This information is aimed at users residing in the Commonwealth of Virginia, hereinafter referred to as “you” or “your”, in line with the “Virginia Consumer Data Protection Act” (VCDPA). For such users, this section overrides any conflicting or divergent information found elsewhere in the privacy policy.

In this context, “personal data” is used as it is defined under the VCDPA.

Types of Personal Data We Process This segment outlines the categories of personal data we process and the reasons for doing so. For an in-depth explanation, refer to the “Detailed information on the processing of Personal Data” within this document.

Categories of Personal Data We Collect We collect the following types of personal data: identifiers and internet information. We do not collect sensitive data. Should there be any new categories of personal data collected, you will be notified accordingly.

Purpose Behind Processing Your Personal Data The reasons for processing your personal data are detailed in the “Detailed information on the processing of Personal Data” and “The purposes of processing” sections of this document. We ensure not to process your information for unexpected purposes or in a manner incompatible with the initially disclosed purposes without your consent. You have the full freedom to provide, withhold, or withdraw your consent at any time by contacting us using the details provided in this document.

Usage and Sharing of the Collected Data We share your personal data with third parties as detailed in the “Detailed information on the processing of Personal Data” section. These third parties are categorized according to the processing purposes. The term “third party” refers to entities other than you, us, our processors, or our affiliates, as defined by the VCDPA.

Sale of Personal Data The term “sale” refers to the exchange of personal data for monetary consideration to a third party, as defined by the VCDPA. It’s important to note that disclosures to processors for data processing on our behalf do not constitute a sale. Certain exceptions as defined by the VCDPA may apply. Our handling of your personal information as detailed may be considered a sale under the VCDPA.

Your Rights Regarding the Sale of Personal Data You have the right to opt-out of the sale of your personal data. Upon your request to cease the sale of your data, we will comply accordingly. You can exercise this right at any time using the contact information provided in this document.

Processing Personal Data for Targeted Advertising Targeted advertising refers to the practice of displaying ads based on personal data obtained from your activities over time and across nonaffiliated sites to predict preferences or interests, as defined by the VCDPA. Exclusions to what constitutes targeted advertising are detailed within the VCDPA.

Your Right to Opt-Out of Targeted Advertising You have the right to opt-out of the processing of your personal data for targeted advertising purposes. Should you decide to exercise this right, we are committed to honoring your request. Contact us at any time using the information provided to opt-out.

Exercising Your Privacy Rights Under the VCDPA You hold specific rights regarding the processing of your personal data, including accessing, correcting, deleting your data, or obtaining a copy of your personal data in a portable format. We commit to non-discrimination for exercising your rights under the VCDPA. Transactions necessary for the provision of goods or services may be affected if you withhold or request deletion of your personal data.

How to Exercise Your Rights To exercise your VCDPA rights, please reach out to us through the contact information provided. Verification of your identity is required to process your request. We aim to respond promptly and within the timeframe specified by the VCDPA, explaining any delays or reasons for denial of your request where applicable. No fee will be charged for responding to up to two requests per annum, with certain conditions allowing for a reasonable fee or refusal to act on manifestly unfounded or excessive requests.

Additional Guidance for Connecticut Consumers This part of the document provides supplementary information to the overarching privacy policy, specifically addressing the concerns and rights of users residing in Connecticut, as outlined under “An Act Concerning Personal Data Privacy and Online Monitoring” or the “Connecticut Data Privacy Act” (CTDPA). Herein, “we”, “us”, and “our” collectively refer to the entity managing this Application and its affiliates.

This guidance is directed towards all users identified as Connecticut residents, hereafter referred to as “you” or “your”, and it takes precedence over any conflicting or inconsistent information found elsewhere in our privacy policy.

Definition of Personal Data In accordance with the CTDPA, this document refers to “personal data” following its legal definition.

Personal Data Handling Summarized below are the categories of personal data we handle and the rationale behind their processing. For a comprehensive account, please refer to the “Detailed information on the processing of Personal Data” section within this document.

Categories of Personal Data Collected We collect identifiers and internet information among other categories of personal data. We abstain from gathering sensitive data. Should there be any new categories of data collection, you will be duly notified.

Reasons for Processing Your Personal Data The purposes behind processing your personal data are detailed in the “Detailed information on the processing of Personal Data” and “The purposes of processing” sections of this document. We guarantee not to use your information for unforeseen reasons or in ways that are incompatible with the originally stated purposes without obtaining your consent. You have the autonomy to grant, withhold, or retract your consent at any moment by reaching out to us using the provided contact details.

Data Usage and Third-party Sharing Your personal data is shared with third parties as elaborated in the “Detailed information on the processing of Personal Data” section, categorized based on processing purposes. The term “third party” denotes any entity apart from you, the data controller, processors, or our affiliates, as per the CTDPA definition.

Sale of Personal Data Our handling of your personal data could be perceived as a sale under the CTDPA, where “sale” involves the exchange of personal data for monetary or other valuable consideration to a third party. It’s important to note that disclosures to processors acting on our behalf do not qualify as sales. Certain exemptions within the CTDPA may be applicable.

Your Right to Opt Out of Data Sale You hold the right to opt out of the sale of your personal data. Upon such a request, we will comply accordingly. You can exercise this right through the contact options provided or by utilizing the simplified opt-out link on this Application.

Personal Data Use for Targeted Advertising We may utilize your personal data for targeted advertising purposes, defined under the CTDPA as using data obtained from your online activities to present tailored advertisements. Exceptions to this definition are provided within the CTDPA.

Opting Out of Targeted Advertising You possess the right to opt out of your personal data being used for targeted advertising. To exercise this right, please contact us at any time. A simplified opt-out option is also available on this Application.

Global Privacy Control Requests to opt out of data sale or targeted advertising through Global Privacy Control (GPC) are honored. GPC is an initiative allowing users to communicate their privacy preferences across the internet.

Exercising Your Rights under the CTDPA You are entitled to certain rights regarding the processing of your personal data, including accessing, correcting, deleting your data, obtaining a portable copy, and opting out of data sale or targeted advertising. We are committed to non-discrimination in response to exercising your rights.

How to Exercise Your Rights To exercise your rights, contact us directly. Verification of your identity is necessary to process your request. We aim to respond promptly and within the specified timeframe, providing explanations for any delays or denials.

Handling Your Requests We commit to addressing your requests without undue delay, typically within 45 days. Extensions and reasons for request denial will be communicated clearly. Appeals to denied requests can be made, with further instructions provided upon appeal receipt. One free request per year is permitted without charge.

Additional Information for Utah Residents This section enhances the privacy policy with specifics for users residing in Utah, as dictated by the “Consumer Privacy Act” (UCPA). Herein, “we”, “us”, and “our” refer to the entity overseeing this Application and its related entities.

Aimed at users in Utah (“you” or “your”), this section overrides any conflicting information in the privacy policy.

Understanding of Personal Data As defined in the UCPA, “personal data” refers to information related to an identified or identifiable individual.

Collection and Use of Personal Data We detail the types of personal data we’ve collected and their usage purposes. For comprehensive insights, refer to the “Detailed information on the processing of Personal Data” section.

Types of Personal Data Collected The personal data categories we gather include identifiers and internet information, excluding sensitive data. Should we decide to collect new data types, we’ll inform you accordingly.

Purpose Behind Personal Data Processing For the rationale behind processing your personal data, consult the “Detailed information on the processing of Personal Data” and “The purposes of processing” sections.

Data Sharing Practices Your personal data may be shared with third parties as outlined in the “Detailed information on the processing of Personal Data” section, sorted by processing objectives.

Third-Party Definitions A “third party” is anyone other than the consumer, controller, processor, or an affiliate or contractor of the controller or processor, as per the UCPA.

Personal Data Sales Our actions with your personal data could be viewed as a sale under the UCPA, meaning the exchange of personal data for monetary or other valuable consideration to a third party.

Opting Out of Data Sales You have the right to opt out of your personal data’s sale. Upon such a request, we will comply. You can exercise this right using the contact details or the simplified opt-out link on this Application.

Targeted Advertising and Personal Data We might use your personal data for targeted advertising, defined by the UCPA as advertisements based on data from your activities across various services to predict preferences or interests.

Opting Out of Targeted Advertising You can opt out of personal data processing for targeted advertising by contacting us anytime or using the provided opt-out link on this Application.

Rights Under the Utah Consumer Privacy Act You are entitled to access, request deletion of your personal data, obtain a portable copy, and opt out of personal data processing for targeted advertising or sales.

Exercising Your Rights To exercise your rights, contact us with your request. We need to verify your identity to process your request, and we may ask for additional information for verification purposes.

Handling Your Requests We aim to address your requests promptly, within 45 days of receipt, explaining any delays or denials. One free request per year is allowed without charge.

Updates and Inquiries For legal purposes, your personal data may be used in court or during legal proceedings. You acknowledge that we may have to disclose personal data upon governmental requests.

Further Assistance For additional details on services or personal data processing, you can contact us. We may update this privacy policy, notifying users via this Application or through contact information provided.

Policy Changes We reserve the right to amend this privacy policy, with changes communicated through this page or directly to users. Changes requiring new consent will be addressed directly with the user.
Lestas, UAB
3-14A, Gelezinkelio str., Vilnius, Lithuania, 02100