Privacy and Cookie Policy

Owner and Data Controller

Finalhit Ltd.- 47A Prideaux Road – Eastbourne – East Sussex – BN21 2NB – United Kingdom

Owner contact email: support@finalhit.com

Types of Data collected

Among the types of Personal Data that Finalhit collects, by itself or through third parties, there are:
first name; last name; company name; email address; Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position; various types of Data; Camera permission; Approximate location permission (non-continuous); Storage permission; Social media accounts permission; language.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Finalhit.
Unless specified otherwise, all Data requested by Finalhit is mandatory and failure to provide this Data may make it impossible for Finalhit to provide its services. In cases where Finalhit specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Finalhit or by the owners of third-party services used by Finalhit serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Finalhit and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Finalhit (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Contacting the User, Advertising, Analytics, Traffic optimization and distribution, Infrastructure monitoring, Data transfer outside the EU, Device permissions for Personal Data access, Remarketing and behavioral targeting, Access to third-party accounts, Registration and authentication, Interaction with external social networks and platforms, Managing contacts and sending messages, Location-based interactions, Displaying content from external platforms, Tag Management, Commercial affiliation, SPAM protection, Content commenting and Handling payments.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by Finalhit

Finalhit may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Finalhit to connect with the User’s account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Email

Provides access to the User’s primary email address.

Device permissions for Personal Data access

Depending on the User’s specific device, Finalhit may request certain permissions that allow it to access the User’s device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.

Please note that the revoking of such permissions might impact the proper functioning of Finalhit.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Finalhit.

Approximate location permission (non-continuous)

Used for accessing the User’s approximate device location. Finalhit may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for Finalhit to derive the approximate position of the User on a continuous basis.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Social media accounts permission

Used for accessing the User’s social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

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

• Access to third-party accounts

  This type of service allows Finalhit to access Data from your account on a third-party service and perform actions with it.
  These services are not activated automatically, but require explicit authorization by the User.

  Facebook account access (Facebook, Inc.)

  This service allows Finalhit to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: Email.

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: identifiers.

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Finalhit, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Finalhit. For more information, please check the privacy policies of the relevant services.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

  AdMob

  AdMob is an advertising service provided by AdMob Google Inc.
  In order to understand Google’s use of Data, consult Google’s partner policy.

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

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Ad Manager

  Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
  In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google’s use of data, consult Google’s partner policy.
  This service uses the “DoubleClick” Cookie, which tracks use of Finalhit and User behavior concerning ads, products and services offered.
  Users may decide to disable all the DoubleClick Cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Audience Network (Facebook, Inc.)

  Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook’s use of Data, consult Facebook’s data policy.

  Finalhit may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.

  Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

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

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google AdSense

  Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of Finalhit and User behavior concerning ads, products and services offered.
  Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  IntelliTXT (Vibrant Media, Inc.)

  IntelliTXT is an advertising service provided by Vibrant Media, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Appodeal

  Appodeal is an advertising service provided by Appodeal, Inc.

  Personal Data collected: Cookies and Usage Data.
  Place of processing: United States – Privacy Policy – Partners’ Privacy Policies.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Analytics collected directly (Finalhit)

  Finalhit uses an internal analytics system that does not involve third parties.

  Personal Data processed: Cookies; Usage Data.

  Category of personal data collected according to CCPA: internet information.

  ComScore Analytics (ComScore, Inc.)

  ComScore is an analytics service provided by ComScore, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Display Advertising extension for Google Analytics

  Google Analytics on Finalhit might use Google’s Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Fabric Answers

  Fabric Answers is an analytics service provided by Crashlytics, a business division of Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from.
  In order to understand Google’s use of Data, consult Google’s partner policy.

  This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Fabric Answers privacy policy.
  In particular, Finalhit uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Fabric Answers service.
  Fabric Answers may share Data with other tools provided by Fabric/Crashlytics, such as Crashlytics or Twitter. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
  Users may opt-out of certain Fabric Answers features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Fabric related sections of this privacy policy, if available.

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

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.

  Category of personal data collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

  Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Finalhit. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Analytics for Apps (Facebook, Inc.)

  Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Ads conversion tracking

  Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from, that connects data from the Google Ads advertising network with actions performed on Finalhit.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Analytics

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Finalhit, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Analytics for Firebase

  Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from.
  In order to understand Google’s use of Data, consult Google’s partner policy.

  Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

  Finalhit uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

  Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

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

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Quantcast Measure (Quantcast Corporation)

  Quantcast Measure is an analytics service provided by Quantcast Corporation.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Twitter Ads conversion tracking (Twitter, Inc.)

  Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on Finalhit.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Commercial affiliation

  This type of service allows Finalhit to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
  Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with Finalhit.
  For details of which data are collected, please refer to the privacy policy of each service.

  Amazon Affiliation (Amazon)

  Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Contacting the User

  Contact form (Finalhit)

  By filling in the contact form with their Data, the User authorizes Finalhit to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: company name; email address; first name; last name.

  Category of personal data collected according to CCPA: identifiers; commercial information.

  Mailing list or newsletter (Finalhit)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Finalhit. Your email address might also be added to this list as a result of signing up to Finalhit or after making a purchase.

  Personal Data processed: company name; email address; first name; last name.

  Category of personal data collected according to CCPA: identifiers; commercial information.

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of Finalhit.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (Finalhit)

  Finalhit has its own internal content comment system.

  Personal Data processed: email address; first name; last name.

  Category of personal data collected according to CCPA: identifiers.

  Disqus (Disqus)

  Disqus is a content commenting service provided by Big Heads Labs Inc.

  Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing:
  United States
  –
  Privacy Policy – Opt out.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on standard contractual clauses (Finalhit)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
  This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  Personal Data processed: various types of Data.

  Category of personal data collected according to CCPA: internet information.

  Data transfer to countries that guarantee European standards (Finalhit)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
  The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission’s website.

  Personal Data processed: various types of Data.

  Category of personal data collected according to CCPA: internet information.

  Data transfer abroad based on consent (Finalhit)

  If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
  In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Finalhit.

  Personal Data processed: various types of Data.

  Category of personal data collected according to CCPA: internet information.

• Device permissions for Personal Data access

  Finalhit requests certain permissions from Users that allow it to access the User’s device Data as described below.

  Device permissions for Personal Data access (Finalhit)

  Finalhit requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.

  Personal Data processed: Approximate location permission (non-continuous); Camera permission; Social media accounts permission; Storage permission.

  Category of personal data collected according to CCPA: internet information; geolocation data.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of Finalhit and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts

  Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from, that allows Finalhit to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Site Search

  Google Site Search is a search engine embedding service provided by Google Inc. that allows Finalhit to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Gravatar (Automattic Inc.)

  Gravatar is an image visualization service provided by Automattic Inc. that allows Finalhit to incorporate content of this kind on its pages.
  Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.

  Personal Data processed: email address; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.

  Category of personal data collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  YouTube video widget

  YouTube is a video content visualization service provided by Google Inc. that allows Finalhit to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Vimeo video (Vimeo, LLC)

  Vimeo is a video content visualization service provided by Vimeo, LLC that allows Finalhit to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Handling payments

  Payment processing services enable Finalhit to process payments by credit card, bank transfer or other means. To ensure greater security, Finalhit shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  FastSpring (Bright Market, LLC)

  Personal and financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) is stored by our payment processor FastSpring and you are encouraged to review FastSpring’s privacy policy and contact them directly for responses to your questions.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Infrastructure monitoring

  This type of service allows Finalhit to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Finalhit.

  Crashlytics

  Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from.

  Personal Data processed: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.

  Category of personal data collected according to CCPA: identifiers; internet information; geolocation data.

  Firebase Performance Monitoring

  Firebase Performance Monitoring is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from.

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

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of Finalhit.
  The interaction and information obtained through Finalhit are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services in order to make sure that the processed data on Finalhit isn’t being connected back to the User’s profile.

  Facebook Like button and social widgets (Facebook, Inc.)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  YouTube button and social widgets

  The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Inc.

  Personal Data processed: Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Location-based interactions

  Geolocation (Finalhit)

  Finalhit may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Finalhit.

  Personal Data processed: geographic position.

  Category of personal data collected according to CCPA: geolocation data.

  Non-continuous geolocation (Finalhit)

  Finalhit may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Finalhit.
  The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data processed: geographic position.

  Category of personal data collected according to CCPA: geolocation data.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Firebase Cloud Messaging

  Firebase Cloud Messaging is a message sending service provided by Google, Inc. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

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

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Firebase Notifications

  Firebase Notifications is a message sending service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

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

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  OneSignal (Lilomi, Inc.)

  OneSignal is a message sending service provided by Lilomi, Inc.

  OneSignal allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
  Depending on the permissions granted to Finalhit, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User’s device. Finalhit uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.

  The Data collected may be used by the service provider for interest-based advertising, analytics and market research. In order to understand OneSignal’s use of Data, consult OneSignal’s privacy policy.

  Push notifications opt-out
  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

  Interest-based advertising opt-out
  Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones.
  Different device configurations, or updates to devices, may affect or change how these indicated settings work.

  Personal Data processed: Cookies; email address; geographic position; language; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing:
  United States
  –
  Privacy Policy – Opt out.

  Category of personal data collected according to CCPA: identifiers; internet information; geolocation data; inferred information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Registration and authentication

  By registering or authenticating, Users allow Finalhit to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, Finalhit will be able to access some Data, stored by these third-party services, for registration or identification purposes.

  Facebook Authentication (Facebook, Inc.)

  Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.

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

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Direct registration (Finalhit)

  The User registers by filling out the registration form and providing the Personal Data directly to Finalhit.

  Personal Data processed: company name; email address; first name; last name.

  Category of personal data collected according to CCPA: identifiers; commercial information.

  Google OAuth

  Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.

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

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Twitter OAuth (Twitter, Inc.)

  Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.

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

  Place of processing:
  United States
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Remarketing and behavioral targeting

  This type of service allows Finalhit and its partners to inform, optimize and serve advertising based on past use of Finalhit by the User.
  This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

  Google Ad Manager Audience Extension

  Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from, that tracks the visitors of Finalhit and allows selected advertising partners to display targeted ads across the web to them.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Finalhit with the Facebook advertising network.

  Personal Data processed: Cookies; email address.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Remarketing (Facebook, Inc.)

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Finalhit with the Facebook advertising network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy – Opt Out.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• SPAM protection

  This type of service analyzes the traffic of Finalhit, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Google reCAPTCHA

  Google reCAPTCHA is a SPAM protection service provided by Google Inc.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: Cookies; Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on Finalhit in a centralized fashion.
  This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager

  Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location Finalhit is accessed from.

  Personal Data processed: Usage Data.

  Place of processing:
  United States
  –
  Privacy Policy;
  Ireland
  –
  Privacy Policy.
  Privacy Shield participant.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Traffic optimization and distribution

  This type of service allows Finalhit to distribute their content using servers located across different countries and to optimize their performance.
  Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Finalhit and the User’s browser.
  Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

  Cloudflare (Cloudflare)

  Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
  The way Cloudflare is integrated means that it filters all the traffic through Finalhit, i.e., communication between Finalhit and the User’s browser, while also allowing analytical data from Finalhit to be collected.

  Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.

  Place of processing:
  United States
  –
  Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Further information about Personal Data

• Face data

  Finalhit does not collect face data.

• Push notifications

  Finalhit may send push notifications to the User.

• Unique device identification

  Finalhit may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Finalhit depends on the payment system used.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Finalhit or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, Finalhit may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Finalhit and any third-party services may collect files that record interaction with Finalhit (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Finalhit does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Finalhit and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Finalhit and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information, internet information, geolocation data and inferred information.

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

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

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Finalhit.

For example, you directly provide your personal information when you submit requests via any forms on Finalhit. You also provide personal information indirectly when you navigate Finalhit, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of Finalhit and features thereof.

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

We may disclose the personal information we collect about you to a third party for business purposes.
In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

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

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

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by Finalhit, both online and offline, you can contact us for further information using the contact details provided in this document.

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

We may use your personal information to allow the operational functioning of Finalhit and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

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

• the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

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

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

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 Finalhit, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

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

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

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

How and when we are expected to handle your request

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

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

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

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

Information for Users residing in Brazil

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running Finalhit and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

• your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
• credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

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 using the contact details provided in this document, 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.