Privacy Policy of Marshmallo
Marshmallo collects some Personal Data from its Users.
Users may be subject to different protection standards and broader standards may therefore apply to some. Users can contact the Owner, to learn more about such standards.
This document contains a section dedicated to Users in the European Union and their privacy rights.
This document contains a section dedicated to California consumers and their privacy rights.
This document contains a section dedicated to Virginia consumers and their privacy rights.
This document contains a section dedicated to Colorado consumers and their privacy rights.
This document contains a section dedicated to Connecticut consumers and their privacy rights.
This document contains a section dedicated to Utah consumers and their privacy rights.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
Policy summary
Personal Data processed for the following purposes and using the following services:
Advertising
Taboola, Google Ads Similar audiences and Meta Lookalike Audience
Personal Data: Trackers; Usage Data
Pinterest Ads
Personal Data: device information; email address; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; User ID
Stape
Analytics
Google Analytics
Personal Data: Tracker; Usage Data
Google Analytics Advertising Reporting Features
Personal Data: Tracker; 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
Google Analytics Demographics and Interests reports
Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Pinterest Conversion Tag
Personal Data: device information; Trackers; Usage Data
Google Ads conversion tracking, Google Analytics with anonymized IP, Twitter Ads conversion tracking and MixPanel
Personal Data: Trackers; Usage Data
Google Analytics 4
Personal Data: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage Data
User ID extension for Google Analytics
Personal Data: Trackers
Akamai
TikTok conversion tracking
Personal Data: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
Collection of privacy-related preferences
CookieBot
Contacting the User
Contact form
Personal Data: email address
Data transfer outside of the UK
Other legal basis for Data transfer abroad (UK)
Personal Data: various types of Data
Data transfer outside the EU
Other legal basis for Data transfer abroad
Personal Data: various types of Data
Device permissions for Personal Data access
Device permissions for Personal Data access
Personal Data: Approximate location permission (continuous); Approximate location permission (non-continuous); Biometric Data access permission; Camera permission; Phone permission; Photo Library permission; Social media accounts permission
Displaying content from external platforms
Google Fonts
Personal Data: Tracker; Usage Data
Spotify widget, Instagram widget and Vimeo video
Personal Data: Trackers; Usage Data
Handling payments
Apple Pay
Personal Data: billing address; email address; first name; last name; payment info; phone number; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service
Google Pay
Personal Data: billing address; email address; first name; last name; payment info; phone number; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service
Hosting and backend infrastructure
Amazon Web Services (AWS)
Personal Data: various types of Data as specified in the privacy policy of the service
Infrastructure monitoring
Crashlytics
Personal Data: crash data; device information; Universally unique identifier (UUID)
Managing contacts and sending messages
OneSignal
Personal Data: email address; geographic position; language; Trackers; 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
Platform services and hosting
Squarespace
Personal Data: device information; geography/region; language; scroll-to-page interactions; Trackers; Universally unique identifier (UUID); Usage Data
Registration and authentication
Google OAuth
Personal Data: various types of Data as specified in the privacy policy of the service
Sign in with Apple
Personal Data: city; country; date of birth; email address; first name; geography/region; last name; phone number; profile picture; User ID
Firebase Authentication
Personal Data: email address; first name; last name; phone number; username
Persona
Registration and authentication provided directly by Marshmallo
Direct registration
Personal Data: academic background; city; company name; country; county; date of birth; email address; first name; gender; language; last name; picture; profession; profile picture; state; Tracker; Usage Data; various types of Data; workplace; ZIP/Postal code
Remarketing and behavioral targeting
Google Ads Remarketing, Twitter Remarketing, Facebook Remarketing and TikTok Remarketing
Personal Data: Trackers; Usage Data
Twitter Tailored Audiences and Meta Custom Audience
Personal Data: email address; Trackers
Social features
Public profile
Personal Data: city; company name; country; county; first name; gender; picture; profession; state
PubNub
Tag Management
Google Tag Manager
Personal Data: Trackers; Usage Data
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Marshmallo may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Marshmallo adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:to enable or otherwise improve the decision-making process;
to grant Users fair and unbiased treatment based on consistent and uniform criteria;
to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Marshmallo, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
Equal protection of User Data
Marshmallo shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
Personal Data collected through sources other than the User
The Owner of Marshmallo may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.Push notifications
Marshmallo may send push notifications to the User to achieve the purposes outlined in this privacy policy.
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 change those settings for Marshmallo, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Marshmallo.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 Marshmallo depends on the payment system used.localStorage
localStorage allows Marshmallo to store and access data right in the User's browser with no expiration date.
sessionStorage
sessionStorage allows Marshmallo to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use Marshmallo only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Marshmallo.
Unique device identification
Marshmallo may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
User identification via a universally unique identifier (UUID)
Marshmallo may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
Push notifications based on the User's geographic location
Marshmallo may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
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.
Users must be aware that disabling push notifications may negatively affect the utility of Marshmallo.
Push notifications for direct marketing
Marshmallo may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by Marshmallo).
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 Marshmallo or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Marshmallo.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through Marshmallo to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.We do not collect personal information about California consumers below the age of 16
We do not knowingly collect personal information of consumers who are below the age of 16 nor do we sell or share it.
Preference Cookies
Preference Cookies store the User preferences detected on Marshmallo in the local domain such as, for example, their timezone and region.
Pseudonymous use
When registering for Marshmallo, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on Marshmallo shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on Marshmallo, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.
Rights for registered California Users under the age of 18
California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
If a registered User fits that description and posted content on Marshmallo, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.
In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
Transfer of personal information outside of Brazil based on contracts and other legal means
We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.
To do so, we may use one of the following legal means:
specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.
Contact information
Owner and Data Controller
Marshmallo LLC
30 N Gould Street, Suite 6712
Sheridan, WY 82801Owner contact email: datacontroller@marshmallo.com
Full policy
Owner and Data Controller
Marshmallo LLC
30 N Gould Street, Suite 6712
Sheridan, WY 82801
Owner contact email: datacontroller@marshmallo.com
Types of Data collected
Among the types of Personal Data that Marshmallo collects, by itself or through third parties, there are: email address; Tracker; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Camera permission; Approximate location permission (continuous); Approximate location permission (non-continuous); Phone permission; Social media accounts permission; Biometric Data access permission; Photo Library permission; various types of Data; first name; last name; gender; date of birth; company name; profession; country; state; county; ZIP/Postal code; city; picture; profile picture; workplace; academic background; language; device information; User ID; number of Users; session statistics; latitude (of city); longitude (of city); browser information; phone number; payment info; billing address; geography/region; geographic position; Universally unique identifier (UUID); scroll-to-page interactions; crash data; username; Data communicated while using the service; purchase history.
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 Marshmallo.
Unless specified otherwise, all Data requested by Marshmallo is mandatory and failure to provide this Data may make it impossible for Marshmallo to provide its services. In cases where Marshmallo 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 Marshmallo or by the owners of third-party services used by Marshmallo 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 Marshmallo.
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 Marshmallo (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.
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.
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.
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, Analytics, Device permissions for Personal Data access, Displaying content from external platforms, Hosting and backend infrastructure, Registration and authentication provided directly by Marshmallo, Social features, Advertising, Remarketing and behavioral targeting, Registration and authentication, Handling payments, Managing contacts and sending messages, Platform services and hosting, Infrastructure monitoring, Data transfer outside of the UK, Data transfer outside the EU, Tag Management and Collection of privacy-related preferences.
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”.
Device permissions for Personal Data access
Depending on the User's specific device, Marshmallo 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 Marshmallo.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Marshmallo.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. Marshmallo may collect, use, and share User location Data in order to provide location-based services.
Approximate location permission (non-continuous)
Used for accessing the User's approximate device location. Marshmallo 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 Marshmallo to derive the approximate position of the User on a continuous basis.
Biometric Data access permission
Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Phone permission
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Photo Library permission
Allows access to the User's Photo Library.
Social media accounts permission
Used for accessing the User's social media account profiles, such as Facebook and Twitter.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Marshmallo, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify 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 Marshmallo. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.Taboola (Taboola Inc.)
Taboola is an advertising service provided by Taboola Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Pinterest Ads (Pinterest, Inc.)
Pinterest Ads is an advertising service provided by Pinterest, Inc. that allows the Owner to run advertising campaigns on the Pinterest advertising network.
Users may opt out of behavioral advertising features through their device settings, their Pinterest personalization settings.
Personal Data processed: device information; email address; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; User ID.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Google Ads Similar audiences (Google LLC)
Similar audiences is an advertising and behavioral targeting service provided by Google LLC that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of Marshmallo.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Meta Lookalike Audience (Meta Platforms, Inc.)
Meta Lookalike Audience is an advertising and behavioral targeting service provided by Meta Platforms, Inc. that uses Data collected through Meta's Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the basis of their past use of Marshmallo or engagement with relevant content across Meta's apps and services.
On the basis of these Data, personalized ads will be shown to Users suggested by Meta Lookalike Audience.Users can opt out of Meta's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Stape
Stape facilitates server-side web analytics via Google Tag Manager.
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.
Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Marshmallo, 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: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Google Analytics Advertising Reporting Features (Google LLC)
Google Analytics on Marshmallo has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; 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 – Opt Out.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Google Analytics Demographics and Interests reports (Google LLC)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Marshmallo (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Pinterest Conversion Tag (Pinterest, Inc.)
Pinterest Conversion Tag is an analytics service provided by Pinterest, Inc. that connects data from the Pinterest advertising network with actions performed on Marshmallo.
Users may opt out of behavioral advertising features through their device settings, their Pinterest personalization settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Google Ads conversion tracking (Google LLC)
Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on Marshmallo.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Marshmallo, 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.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.Personal Data processed: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Google Analytics with anonymized IP (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Marshmallo, 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.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Twitter Ads conversion tracking (X Corp.)
Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on Marshmallo.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
MixPanel (MixPanel)
MixPanel is an analytics service provided by Mixpanel Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
User ID extension for Google Analytics (Google LLC)
Google Analytics on Marshmallo makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by Marshmallo.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Akamai
Akamai is used to track usage of the embedded video player.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
TikTok conversion tracking (TikTok Inc.)
TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed on Marshmallo. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of Marshmallo.
Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Collection of privacy-related preferences
This type of service allows Marshmallo to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
CookieBot
CookieBot is a consent management platform.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Contacting the User
Contact form (Marshmallo)
By filling in the contact form with their Data, the User authorizes Marshmallo 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: email address.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the VCDPA
Device permissions for Personal Data access
Marshmallo requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (Marshmallo)
Marshmallo 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 (continuous); Approximate location permission (non-continuous); Biometric Data access permission; Camera permission; Phone permission; Photo Library permission; Social media accounts permission.
Category of personal information collected according to the CCPA: biometric information; internet information; geolocation data.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Marshmallo 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 LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows Marshmallo to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Spotify widget (Spotify AB)
Spotify is an audio content delivery service provided by Spotify AB that allows Marshmallo to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Sweden – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Instagram widget (Meta Platforms, Inc.)
Instagram is an image visualization service provided by Meta Platforms, Inc. that allows Marshmallo to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows Marshmallo to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Handling payments
Unless otherwise specified, Marshmallo processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Marshmallo isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Apple Pay (Apple Inc.)
Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.
Personal Data processed: billing address; email address; first name; last name; payment info; phone number; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; commercial information; internet information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Google Pay (Google LLC)
Google Pay is a payment service provided by Google LLC, which allows users to make online payments using their Google credentials.
Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; commercial information; internet information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Marshmallo to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Marshmallo.
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.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Infrastructure monitoring
This type of service allows Marshmallo 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 Marshmallo.Crashlytics (Google LLC)
Crashlytics is a monitoring service provided by Google LLC.
Personal Data processed: crash data; device information; Universally unique identifier (UUID).
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
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.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 Marshmallo, 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. Marshmallo 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: email address; geographic position; language; Trackers; 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 information collected according to the CCPA: identifiers; internet information; geolocation data; inferred information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Platform services and hosting
These services have the purpose of hosting and running key components of Marshmallo, therefore allowing the provision of Marshmallo from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.Squarespace (Squarespace, Inc)
Squarespace is a platform provided by Squarespace, Inc. that allows the Owner to build, run and host Marshmallo. Squarespace is highly customizable and can host websites from simple blogs to complex e-commerce platforms.
Personal Data processed: device information; geography/region; language; scroll-to-page interactions; Trackers; Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet information; geolocation data; inferred information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Registration and authentication
By registering or authenticating, Users allow Marshmallo 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, Marshmallo will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.Google OAuth (Google LLC)
Google OAuth is a registration and authentication service provided by Google LLC 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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
Sign in with Apple (Apple Inc.)
Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.
Personal Data processed: city; country; date of birth; email address; first name; geography/region; last name; phone number; profile picture; User ID.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; geolocation data; sensorial information.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Firebase Authentication (Google LLC)
Firebase Authentication is a registration and authentication service provided by Google LLC. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; first name; last name; phone number; username.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Persona
Persona is an identity verification platform. Your biometric information will be stored for no more than 3 years with Persona.
Personal Data processed: date of birth; first name; last name; picture; gender; height.
Place of processing: United States - Privacy Policy.
Personal data that is NOT retained:
Document number eg. passport number or driver's license number
Address
Photo of the entire ID
Specific purpose:
Verify identity
Exclude registered sex offenders
Prevent catfishing
Enforce suspensions and expulsions for violating the Terms and Conditions or Guidelines.This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Registration and authentication provided directly by Marshmallo
By registering or authenticating, Users allow Marshmallo to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (Marshmallo)
The User registers by filling out the registration form and providing the Personal Data directly to Marshmallo.
Personal Data processed: academic background; city; company name; country; county; date of birth; email address; first name; gender; language; last name; picture; profession; profile picture; state; Tracker; Usage Data; various types of Data; workplace; ZIP/Postal code.
Category of personal information collected according to the CCPA: identifiers; commercial information; biometric information; internet information; sensorial information; employment related information; inferred information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Remarketing and behavioral targeting
This type of service allows Marshmallo and its partners to inform, optimize and serve advertising based on past use of Marshmallo by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of Marshmallo with the Google Ads advertising network and the DoubleClick Cookie.
In order to understand Google's use of Data, consult Google's partner policy.
Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Twitter Remarketing (X Corp.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of Marshmallo with the Twitter advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Twitter Tailored Audiences (X Corp.)
Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of Marshmallo with the Twitter advertising network.
Users can opt out from interest-based ads by going to: Personalization and Data.
Personal Data processed: email address; Trackers.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Facebook Remarketing (Meta Platforms, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of Marshmallo with the Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Meta Custom Audience (Meta Platforms, Inc.)
Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of Marshmallo with the Meta Audience Network.
Users can opt out of Meta's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Trackers.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: identifiers; internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
TikTok Remarketing ( TikTok Information Technologies UK Limited )
TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited that connects the activity of Marshmallo with the TikTok advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United Kingdom – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Social features
Public profile (Marshmallo)
Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with Marshmallo.
Personal Data processed: city; company name; country; county; first name; gender; picture; profession; state.
Category of personal information collected according to the CCPA: identifiers; commercial information; biometric information; sensorial information; employment related information.
This processing constitutes:
a sale according to the VCDPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
PubNub
PubNub is an in-app messaging platform.
Personal Data processed: user generated text messages.
Place of processing: United States - Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet information.This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Marshmallo 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 LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Marshmallo may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Marshmallo adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:to enable or otherwise improve the decision-making process;
to grant Users fair and unbiased treatment based on consistent and uniform criteria;
to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Marshmallo, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
Equal protection of User Data
Marshmallo shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
Personal Data collected through sources other than the User
The Owner of Marshmallo may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.Push notifications
Marshmallo may send push notifications to the User to achieve the purposes outlined in this privacy policy.
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 change those settings for Marshmallo, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Marshmallo.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 Marshmallo depends on the payment system used.localStorage
localStorage allows Marshmallo to store and access data right in the User's browser with no expiration date.
sessionStorage
sessionStorage allows Marshmallo to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use Marshmallo only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Marshmallo.
Unique device identification
Marshmallo may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
User identification via a universally unique identifier (UUID)
Marshmallo may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
Push notifications based on the User's geographic location
Marshmallo may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
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.
Users must be aware that disabling push notifications may negatively affect the utility of Marshmallo.
Push notifications for direct marketing
Marshmallo may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by Marshmallo).
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 Marshmallo or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Marshmallo.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through Marshmallo to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.Preference Cookies
Preference Cookies store the User preferences detected on Marshmallo in the local domain such as, for example, their timezone and region.
Pseudonymous use
When registering for Marshmallo, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on Marshmallo shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on Marshmallo, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.
Rights for registered California Users under the age of 18
California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
If a registered User fits that description and posted content on Marshmallo, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.
In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
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. 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 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 General Data Protection Regulation (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.
Transfer of Personal Data outside of the European Union
Other legal basis for Data transfer abroad
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
the data transferred is sourced from a public register created under the law of the country that the data originates from;
subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via Marshmallo.
Transfer of Personal Data outside of the United Kingdom
Other legal basis for Data transfer abroad (UK)
If no other legal basis applies, Personal Data shall be transferred from the UK to third countries only if at least one of the following conditions is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
the data transferred is sourced from a public register created under UK law;
subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via Marshmallo.
Further information for Users in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running Marshmallo and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the 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.
Additional information for Users in Brazil
Transfer of personal information outside of Brazil based on contracts and other legal means
We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.
To do so, we may use one of the following legal means:
specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.
Futher information for California consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Marshmallo and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA).
Notice at collection
Categories of personal information collected, used, sold, or shared
In this section we summarize the categories of personal information that we've collected, used, sold, or shared 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, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information.
We have collected the following categories of sensitive personal information: Biometric Data access permission, payment info, username and payment info
We will not collect additional categories of personal information without notifying you.
Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it
You have the right to request that we limit the use or disclosure of your sensitive personal information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer.
We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.
Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and we will instruct our service providers and contractors to do the same.
To fully exercise your right to limit the use or disclosure of your sensitive personal information you can contact us at any time, using the contact details provided in this document.
For a simplified method you can also use the privacy choices link provided on Marshmallo.
We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request.
Once you have exercised this right, we are required to wait at least 12 months before asking whether you have changed your mind.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of Marshmallo 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 won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
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 Marshmallo.
For example, you directly provide your personal information when you submit requests via any forms on Marshmallo. You also provide personal information indirectly when you navigate Marshmallo, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application 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.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Marshmallo.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Marshmallo, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us 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.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Additional information about California privacy
We do not collect personal information about California consumers below the age of 16
We do not knowingly collect personal information of consumers who are below the age of 16 nor do we sell or share it.
Further information for Virginia consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the VCDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on Marshmallo.
Please note that certain exceptions set forth in the VCDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Further information for Colorado consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running Marshmallo and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act" (the "CPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the CPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on Marshmallo.
Please note that certain exceptions set forth in the CPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Marshmallo.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Marshmallo.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running Marshmallo and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the CTDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on Marshmallo. In the event of withdrawal, we will stop processing the relevant data as soon as possible, but no later than 15 days after receiving your withdrawal request.
Please note that certain exceptions set forth in the CTDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Marshmallo.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Marshmallo.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
Further information for Utah consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running Marshmallo and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the UCPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on Marshmallo.
Please note that certain exceptions set forth in the UCPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the UCPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.
Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Marshmallo.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Marshmallo.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to your request.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.
We do not charge a fee to respond to your request, for up to one request per year.
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 Marshmallo 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, Marshmallo 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, Marshmallo and any third-party services may collect files that record interaction with Marshmallo (System logs) or 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.
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 Marshmallo 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.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Marshmallo (or third-party services employed in Marshmallo), which can include: the IP addresses or domain names of the computers utilized by the Users who use Marshmallo, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Marshmallo who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Marshmallo. The Data Controller, unless otherwise specified, is the Owner of Marshmallo.
Marshmallo (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Marshmallo as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to Marshmallo, if not stated otherwise within this document.