Privacy Policy of figuringoutpolito.com

Data we collect automatically

“We automatically collect data from you for example when you visit figuringoutpolito.com.”

Data you give to us

“We collect the data you give to us for example when you sign up for our newsletter.”

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Trackers; email address; Usage Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Displaying Content from External Platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction. 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 is a typeface visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

Hosting and Backend Infrastructure

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Supabase is a hosting and backend service provided by Supabase, Inc.

Vercel is a hosting and backend service provided by Vercel Inc.

User Authentication and Session Management

This type of service is used to provide secure user registration, sign-in, and session management functionality on this Application. When a User creates an account or signs in, their identity data is processed by the authentication provider on behalf of the Owner.

Clerk is an authentication and user management service provided by Clerk, Inc. Clerk, Inc. participates in and complies with the EU-U.S. Data Privacy Framework. Data transfers to the United States are governed by Standard Contractual Clauses.

Retention period: For as long as the User's account remains active, plus 30 days following account deletion.

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.

Brevo email is an email address management and message-sending service provided by SendinBlue SAS.

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.
• ·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.

Further Information About Retention Time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

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.

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 fulfil a legal obligation or upon order of an authority.

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

The Rights of Users Based on the GDPR

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law:

• ·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.
• ·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 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 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.
• ·Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including 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.

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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes.

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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law.

Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users' request, the Owner will inform them about those recipients.

The Rights of Users According to the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of law, including the following:

• ·Right of access to Personal Data
• ·Right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited)
• ·Right to receive their Personal Data and have it transferred to another controller (data portability)
• ·Right to ask for incorrect Personal Data to be corrected

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

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
• ·Credit protection

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
• ·Request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests

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 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.

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.

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
• ·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

Notice at Collection

Your Privacy Rights Under US State Laws

To the extent permitted by applicable law, you have:

• ·The right to access Personal Information / the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information.
• ·The right to correct inaccurate Personal Information.
• ·The right to request the deletion of your Personal Information.
• ·The right to obtain a copy of your Personal Information in a portable and usable format.
• ·The right to opt out from the Sale of your Personal Information.
• ·The right to non-discrimination. We will not discriminate against you for exercising your privacy rights.

Additional Rights for California Residents

• ·The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising
• ·The right to request to limit our use or disclosure of your Sensitive Personal Information

Additional Rights for Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana Residents

• ·The right to opt out of the processing of your personal information for Targeted Advertising or profiling
• ·The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information

How to Exercise Your Privacy Rights Under US State Laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document. We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law.

Legal Action

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

System Logs and Maintenance

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

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 this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.