Privacy policy

==============


Last updated: May 13, 2023


This Privacy Policy describes Our policies and procedures on the collection,use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions  

==============================

Interpretation  

--------------

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions  

-----------


For the purposes of this Privacy Policy:
 

 * Account means a unique account created for You to access our Service or parts of our Service.

  * Affiliate means an entity that controls, is controlled by or is under  common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote

    for election of directors or other managing authority.


  * Business , for the purpose of CCPA/CPRA, refers to the Company as the

    legal entity that collects Consumers' personal information and determines

    the purposes and means of the processing of Consumers' personal

    information, or on behalf of which such information is collected and that

    alone, or jointly with others, determines the purposes and means of the

    processing of consumers' personal information, that does business in the

    State of California.


  * CCPA and/or CPRA refers to California Consumer Privacy Act (the "CCPA") as

    amended by the California Privacy Rights Act of 2020 (the "CPRA").


  * Company (referred to as either "the Company", "We", "Us" or "Our" in this

    Agreement) refers to CSK Digital Consulting & Design, Rietstrasse 55.


    For the purpose of the GDPR, the Company is the Data Controller.


  * Consumer , for the purpose of the CCPA/CPRA, means a natural person who is

    a California resident. A resident, as defined in the law, includes (1)

    every individual who is in the USA for other than a temporary or

    transitory purpose, and (2) every individual who is domiciled in the USA

    who is outside the USA for a temporary or transitory purpose.


  * Cookies are small files that are placed on Your computer, mobile device or

    any other device by a website, containing the details of Your browsing

    history on that website among its many uses.


  * Country refers to: Switzerland


  * Data Controller , for the purposes of the GDPR (General Data Protection

    Regulation), refers to the Company as the legal person which alone or

    jointly with others determines the purposes and means of the processing of

    Personal Data.


  * Device means any device that can access the Service such as a computer, a

    cellphone or a digital tablet.


  * Do Not Track (DNT) is a concept that has been promoted by US regulatory

    authorities, in particular the U.S. Federal Trade Commission (FTC), for

    the Internet industry to develop and implement a mechanism for allowing

    internet users to control the tracking of their online activities across

    websites.


  * GDPR refers to EU General Data Protection Regulation.


  * Personal Data is any information that relates to an identified or

    identifiable individual.


    For the purposes of GDPR, Personal Data means any information relating to

    You such as a name, an identification number, location data, online

    identifier or to one or more factors specific to the physical,

    physiological, genetic, mental, economic, cultural or social identity.


    For the purposes of the CCPA/CPRA, Personal Data means any information

    that identifies, relates to, describes or is capable of being associated

    with, or could reasonably be linked, directly or indirectly, with You.


  * Service refers to the Website.


  * Service Provider means any natural or legal person who processes the data

    on behalf of the Company. It refers to third-party companies or

    individuals employed by the Company to facilitate the Service, to provide

    the Service on behalf of the Company, to perform services related to the

    Service or to assist the Company in analyzing how the Service is used. For

    the purpose of the GDPR, Service Providers are considered Data Processors.


  * Third-party Social Media Service refers to any website or any social

    network website through which a User can log in or create an account to

    use the Service.


  * Usage Data refers to data collected automatically, either generated by the

    use of the Service or from the Service infrastructure itself (for example,

    the duration of a page visit).


  * Website refers to CSK Digital Consulting & Design, accessible from

    [www.csk-digital.consulting](www.csk-digital.consulting)


  * You means the individual accessing or using the Service, or the company,

    or other legal entity on behalf of which such individual is accessing or

    using the Service, as applicable.


    Under GDPR, You can be referred to as the Data Subject or as the User as

    you are the individual using the Service.


Collecting and Using Your Personal Data  

=======================================


Types of Data Collected  

-----------------------


Personal Data  

~~~~~~~~~~~~~


While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:


  * Email address


  * First name and last name


  * Phone number


  * Usage Data



Usage Data  

~~~~~~~~~~


Usage Data is collected automatically when using the Service.


Usage Data may include information such as Your Device's Internet Protocol

address (e.g. IP address), browser type, browser version, the pages of our

Service that You visit, the time and date of Your visit, the time spent on

those pages, unique device identifiers and other diagnostic data.


When You access the Service by or through a mobile device, We may collect

certain information automatically, including, but not limited to, the type of

mobile device You use, Your mobile device unique ID, the IP address of Your

mobile device, Your mobile operating system, the type of mobile Internet

browser You use, unique device identifiers and other diagnostic data.


We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.


Information from Third-Party Social Media Services  

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~


The Company allows You to create an account and log in to use the Service

through the following Third-party Social Media Services:


  * Google

  * Facebook

  * Twitter

  * LinkedIn


If You decide to register through or otherwise grant us access to a Third-

Party Social Media Service, We may collect Personal data that is already

associated with Your Third-Party Social Media Service's account, such as Your

name, Your email address, Your activities or Your contact list associated with

that account.


You may also have the option of sharing additional information with the

Company through Your Third-Party Social Media Service's account. If You choose

to provide such information and Personal Data, during registration or

otherwise, You are giving the Company permission to use, share, and store it

in a manner consistent with this Privacy Policy.


Tracking Technologies and Cookies  

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~


We use Cookies and similar tracking technologies to track the activity on Our

Service and store certain information. Tracking technologies used are beacons,

tags, and scripts to collect and track information and to improve and analyze

Our Service. The technologies We use may include:


  * Cookies or Browser Cookies. A cookie is a small file placed on Your

    Device. You can instruct Your browser to refuse all Cookies or to indicate

    when a Cookie is being sent. However, if You do not accept Cookies, You

    may not be able to use some parts of our Service. Unless you have adjusted

    Your browser setting so that it will refuse Cookies, our Service may use

    Cookies.

  * Web Beacons. Certain sections of our Service and our emails may contain

    small electronic files known as web beacons (also referred to as clear

    gifs, pixel tags, and single-pixel gifs) that permit the Company, for

    example, to count users who have visited those pages or opened an email

    and for other related website statistics (for example, recording the

    popularity of a certain section and verifying system and server

    integrity).


Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on

Your personal computer or mobile device when You go offline, while Session

Cookies are deleted as soon as You close Your web browser. Learn more about

cookies on the [Free Privacy Policy

website](https://www.freeprivacypolicy.com/blog/sample-privacy-policy-

template/#Use_Of_Cookies_And_Tracking) article.


We use both Session and Persistent Cookies for the purposes set out below:


  * Necessary / Essential Cookies


    Type: Session Cookies


    Administered by: Us


    Purpose: These Cookies are essential to provide You with services

    available through the Website and to enable You to use some of its

    features. They help to authenticate users and prevent fraudulent use of

    user accounts. Without these Cookies, the services that You have asked for

    cannot be provided, and We only use these Cookies to provide You with

    those services.


  * Cookies Policy / Notice Acceptance Cookies


    Type: Persistent Cookies


    Administered by: Us


    Purpose: These Cookies identify if users have accepted the use of cookies

    on the Website.


  * Functionality Cookies


    Type: Persistent Cookies


    Administered by: Us


    Purpose: These Cookies allow us to remember choices You make when You use

    the Website, such as remembering your login details or language

    preference. The purpose of these Cookies is to provide You with a more

    personal experience and to avoid You having to re-enter your preferences

    every time You use the Website.


  * Tracking and Performance Cookies


    Type: Persistent Cookies


    Administered by: Third-Parties


    Purpose: These Cookies are used to track information about traffic to the

    Website and how users use the Website. The information gathered via these

    Cookies may directly or indirectly identify you as an individual visitor.

    This is because the information collected is typically linked to a

    pseudonymous identifier associated with the device you use to access the

    Website. We may also use these Cookies to test new pages, features or new

    functionality of the Website to see how our users react to them.


For more information about the cookies we use and your choices regarding

cookies, please visit our Cookies Policy or the Cookies section of our Privacy

Policy.


Use of Your Personal Data  

-------------------------


The Company may use Personal Data for the following purposes:


  * To provide and maintain our Service , including to monitor the usage of

    our Service.

  * To manage Your Account: to manage Your registration as a user of the

    Service. The Personal Data You provide can give You access to different

    functionalities of the Service that are available to You as a registered

    user.

  * For the performance of a contract: the development, compliance and

    undertaking of the purchase contract for the products, items or services

    You have purchased or of any other contract with Us through the Service.

  * To contact You: To contact You by email, telephone calls, SMS, or other

    equivalent forms of electronic communication, such as a mobile

    application's push notifications regarding updates or informative

    communications related to the functionalities, products or contracted

    services, including the security updates, when necessary or reasonable for

    their implementation.

  * To provide You with news, special offers and general information about

    other goods, services and events which we offer that are similar to those

    that you have already purchased or enquired about unless You have opted

    not to receive such information.

  * To manage Your requests: To attend and manage Your requests to Us.

  * To deliver targeted advertising to You : We may use Your information to

    develop and display content and advertising (and work with third-party

    vendors who do so) tailored to Your interests and/or location and to

    measure its effectiveness.

  * For business transfers: We may use Your information to evaluate or conduct

    a merger, divestiture, restructuring, reorganization, dissolution, or

    other sale or transfer of some or all of Our assets, whether as a going

    concern or as part of bankruptcy, liquidation, or similar proceeding, in

    which Personal Data held by Us about our Service users is among the assets

    transferred.

  * For other purposes : We may use Your information for other purposes, such

    as data analysis, identifying usage trends, determining the effectiveness

    of our promotional campaigns and to evaluate and improve our Service,

    products, services, marketing and your experience.


We may share Your personal information in the following situations:


  * With Service Providers: We may share Your personal information with

    Service Providers to monitor and analyze the use of our Service, to

    advertise on third party websites to You after You visited our Service,

    for payment processing, to contact You.

  * For business transfers: We may share or transfer Your personal information

    in connection with, or during negotiations of, any merger, sale of Company

    assets, financing, or acquisition of all or a portion of Our business to

    another company.

  * With Affiliates: We may share Your information with Our affiliates, in

    which case we will require those affiliates to honor this Privacy Policy.

    Affiliates include Our parent company and any other subsidiaries, joint

    venture partners or other companies that We control or that are under

    common control with Us.

  * With business partners: We may share Your information with Our business

    partners to offer You certain products, services or promotions.

  * With other users: when You share personal information or otherwise

    interact in the public areas with other users, such information may be

    viewed by all users and may be publicly distributed outside. If You

    interact with other users or register through a Third-Party Social Media

    Service, Your contacts on the Third-Party Social Media Service may see

    Your name, profile, pictures and description of Your activity. Similarly,

    other users will be able to view descriptions of Your activity,

    communicate with You and view Your profile.

  * With Your consent : We may disclose Your personal information for any

    other purpose with Your consent.


Retention of Your Personal Data  

-------------------------------


The Company will retain Your Personal Data only for as long as is necessary

for the purposes set out in this Privacy Policy. We will retain and use Your

Personal Data to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your data to comply with applicable

laws), resolve disputes, and enforce our legal agreements and policies.


The Company will also retain Usage Data for internal analysis purposes. Usage

Data is generally retained for a shorter period of time, except when this data

is used to strengthen the security or to improve the functionality of Our

Service, or We are legally obligated to retain this data for longer time

periods.


Transfer of Your Personal Data  

------------------------------


Your information, including Personal Data, is processed at the Company's

operating offices and in any other places where the parties involved in the

processing are located. It means that this information may be transferred to —

and maintained on — computers located outside of Your state, province, country

or other governmental jurisdiction where the data protection laws may differ

than those from Your jurisdiction.


Your consent to this Privacy Policy followed by Your submission of such

information represents Your agreement to that transfer.


The Company will take all steps reasonably necessary to ensure that Your data

is treated securely and in accordance with this Privacy Policy and no transfer

of Your Personal Data will take place to an organization or a country unless

there are adequate controls in place including the security of Your data and

other personal information.


Delete Your Personal Data  

-------------------------


You have the right to delete or request that We assist in deleting the

Personal Data that We have collected about You.


Our Service may give You the ability to delete certain information about You

from within the Service.


You may update, amend, or delete Your information at any time by signing in to

Your Account, if you have one, and visiting the account settings section that

allows you to manage Your personal information. You may also contact Us to

request access to, correct, or delete any personal information that You have

provided to Us.


Please note, however, that We may need to retain certain information when we

have a legal obligation or lawful basis to do so.


Disclosure of Your Personal Data  

--------------------------------


Business Transactions  

~~~~~~~~~~~~~~~~~~~~~


If the Company is involved in a merger, acquisition or asset sale, Your

Personal Data may be transferred. We will provide notice before Your Personal

Data is transferred and becomes subject to a different Privacy Policy.


Law enforcement  

~~~~~~~~~~~~~~~


Under certain circumstances, the Company may be required to disclose Your

Personal Data if required to do so by law or in response to valid requests by

public authorities (e.g. a court or a government agency).


Other legal requirements  

~~~~~~~~~~~~~~~~~~~~~~~~


The Company may disclose Your Personal Data in the good faith belief that such

action is necessary to:


  * Comply with a legal obligation

  * Protect and defend the rights or property of the Company

  * Prevent or investigate possible wrongdoing in connection with the Service

  * Protect the personal safety of Users of the Service or the public

  * Protect against legal liability


Security of Your Personal Data  

------------------------------


The security of Your Personal Data is important to Us, but remember that no

method of transmission over the Internet, or method of electronic storage is

100% secure. While We strive to use commercially acceptable means to protect

Your Personal Data, We cannot guarantee its absolute security.


Detailed Information on the Processing of Your Personal Data  

============================================================


The Service Providers We use may have access to Your Personal Data. These

third-party vendors collect, store, use, process and transfer information

about Your activity on Our Service in accordance with their Privacy Policies.


Analytics  

---------


We may use third-party Service providers to monitor and analyze the use of our

Service.


  * Google Analytics


    Google Analytics is a web analytics service offered by Google that tracks

    and reports website traffic. Google uses the data collected to track and

    monitor the use of our Service. This data is shared with other Google

    services. Google may use the collected data to contextualize and

    personalize the ads of its own advertising network.


    You can opt-out of having made your activity on the Service available to

    Google Analytics by installing the Google Analytics opt-out browser add-

    on. The add-on prevents the Google Analytics JavaScript (ga.js,

    analytics.js and dc.js) from sharing information with Google Analytics

    about visits activity.


    For more information on the privacy practices of Google, please visit the

    Google Privacy & Terms web page: <https://policies.google.com/privacy>


  * Google Tag Manager


    Their Privacy Policy can be viewed at

    <https://policies.google.com/privacy?hl=en>


Payments  

--------


We may provide paid products and/or services within the Service. In that case,

we may use third-party services for payment processing (e.g. payment

processors).


We will not store or collect Your payment card details. That information is

provided directly to Our third-party payment processors whose use of Your

personal information is governed by their Privacy Policy. These payment

processors adhere to the standards set by PCI-DSS as managed by the PCI

Security Standards Council, which is a joint effort of brands like Visa,

Mastercard, American Express and Discover. PCI-DSS requirements help ensure

the secure handling of payment information.


  * Stripe


    Their Privacy Policy can be viewed at <https://stripe.com/us/privacy>


  * Shopify


    Their Privacy Policy can be viewed at

    <https://www.shopify.com/legal/privacy>


  * PayPal


    Their Privacy Policy can be viewed at

    <https://www.paypal.com/webapps/mpp/ua/privacy-full>


Behavioral Remarketing  

----------------------


The Company uses remarketing services to advertise to You after You accessed

or visited our Service. We and Our third-party vendors use cookies and non-

cookie technologies to help Us recognize Your Device and understand how You

use our Service so that We can improve our Service to reflect Your interests

and serve You advertisements that are likely to be of more interest to You.


These third-party vendors collect, store, use, process and transfer

information about Your activity on Our Service in accordance with their

Privacy Policies and to enable Us to:


  * Measure and analyze traffic and browsing activity on Our Service

  * Show advertisements for our products and/or services to You on third-party

    websites or apps

  * Measure and analyze the performance of Our advertising campaigns


Some of these third-party vendors may use non-cookie technologies that may not

be impacted by browser settings that block cookies. Your browser may not

permit You to block such technologies. You can use the following third-party

tools to decline the collection and use of information for the purpose of

serving You interest-based advertising:


  * The NAI's opt-out platform: <http://www.networkadvertising.org/choices/>

  * The EDAA's opt-out platform <http://www.youronlinechoices.com/>

  * The DAA's opt-out platform:

    [http://optout.aboutads.info/?c=2&lang=EN](http://optout.aboutads.info/?c=2&lang=EN)


You may opt-out of all personalized advertising by enabling privacy features

on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads

Personalization (Android). See Your mobile device Help system for more

information.


We may share information, such as hashed email addresses (if available) or

other online identifiers collected on Our Service with these third-party

vendors. This allows Our third-party vendors to recognize and deliver You ads

across devices and browsers. To read more about the technologies used by these

third-party vendors and their cross-device capabilities please refer to the

Privacy Policy of each vendor listed below.


The third-party vendors We use are:


  * Google Ads (AdWords)


    Google Ads (AdWords) remarketing service is provided by Google Inc.


    You can opt-out of Google Analytics for Display Advertising and customise

    the Google Display Network ads by visiting the Google Ads Settings page:

    <http://www.google.com/settings/ads>


    Google also recommends installing the Google Analytics Opt-out Browser

    Add-on - <https://tools.google.com/dlpage/gaoptout> \- for your web

    browser. Google Analytics Opt-out Browser Add-on provides visitors with

    the ability to prevent their data from being collected and used by Google

    Analytics.


    For more information on the privacy practices of Google, please visit the

    Google Privacy & Terms web page: <https://policies.google.com/privacy>


  * Facebook


    Facebook remarketing service is provided by Facebook Inc.


    You can learn more about interest-based advertising from Facebook by

    visiting this page: <https://www.facebook.com/help/516147308587266>


    To opt-out from Facebook's interest-based ads, follow these instructions

    from Facebook: <https://www.facebook.com/help/568137493302217>


    Facebook adheres to the Self-Regulatory Principles for Online Behavioural

    Advertising established by the Digital Advertising Alliance. You can also

    opt-out from Facebook and other participating companies through the

    Digital Advertising Alliance in the USA

    <http://www.aboutads.info/choices/>, the Digital Advertising Alliance of

    Canada in Canada <http://youradchoices.ca/> or the European Interactive

    Digital Advertising Alliance in Europe <http://www.youronlinechoices.eu/>,

    or opt-out using your mobile device settings.


    For more information on the privacy practices of Facebook, please visit

    Facebook's Data Policy: <https://www.facebook.com/privacy/explanation>


  * Pinterest


    Pinterest remarketing service is provided by Pinterest Inc.


    You can opt-out from Pinterest's interest-based ads by enabling the "Do

    Not Track" functionality of your web browser or by following Pinterest

    instructions: <http://help.pinterest.com/en/articles/personalization-and-

    data>


    You can learn more about the privacy practices and policies of Pinterest

    by visiting their Privacy Policy page:

    <https://about.pinterest.com/en/privacy-policy>


  * Instagram


    Their Privacy Policy can be viewed at

    <https://help.instagram.com/519522125107875/?helpref=uf_share>


GDPR Privacy  

============


Legal Basis for Processing Personal Data under GDPR  

---------------------------------------------------


We may process Personal Data under the following conditions:


  * Consent: You have given Your consent for processing Personal Data for one

    or more specific purposes.

  * Performance of a contract: Provision of Personal Data is necessary for the

    performance of an agreement with You and/or for any pre-contractual

    obligations thereof.

  * Legal obligations: Processing Personal Data is necessary for compliance

    with a legal obligation to which the Company is subject.

  * Vital interests: Processing Personal Data is necessary in order to protect

    Your vital interests or of another natural person.

  * Public interests: Processing Personal Data is related to a task that is

    carried out in the public interest or in the exercise of official

    authority vested in the Company.

  * Legitimate interests: Processing Personal Data is necessary for the

    purposes of the legitimate interests pursued by the Company.


In any case, the Company 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.


Your Rights under the GDPR  

--------------------------


The Company undertakes to respect the confidentiality of Your Personal Data

and to guarantee You can exercise Your rights.


You have the right under this Privacy Policy, and by law if You are within the

EU, to:


  * Request access to Your Personal Data. The right to access, update or

    delete the information We have on You. Whenever made possible, you can

    access, update or request deletion of Your Personal Data directly within

    Your account settings section. If you are unable to perform these actions

    yourself, please contact Us to assist You. This also enables You to

    receive a copy of the Personal Data We hold about You.

  * Request correction of the Personal Data that We hold about You. You have

    the right to have any incomplete or inaccurate information We hold about

    You corrected.

  * Object to processing of Your Personal Data. This right exists where We are

    relying on a legitimate interest as the legal basis for Our processing and

    there is something about Your particular situation, which makes You want

    to object to our processing of Your Personal Data on this ground. You also

    have the right to object where We are processing Your Personal Data for

    direct marketing purposes.

  * Request erasure of Your Personal Data. You have the right to ask Us to

    delete or remove Personal Data when there is no good reason for Us to

    continue processing it.

  * Request the transfer of Your Personal Data. We will provide to You, or to

    a third-party You have chosen, Your Personal Data in a structured,

    commonly used, machine-readable format. Please note that this right only

    applies to automated information which You initially provided consent for

    Us to use or where We used the information to perform a contract with You.

  * Withdraw Your consent. You have the right to withdraw Your consent on

    using your Personal Data. If You withdraw Your consent, We may not be able

    to provide You with access to certain specific functionalities of the

    Service.


Exercising of Your GDPR Data Protection Rights  

----------------------------------------------


You may exercise Your rights of access, rectification, cancellation and

opposition by contacting Us. Please note that we may ask You to verify Your

identity before responding to such requests. If You make a request, We will

try our best to respond to You as soon as possible.


You have the right to complain to a Data Protection Authority about Our

collection and use of Your Personal Data. For more information, if You are in

the European Economic Area (EEA), please contact Your local data protection

authority in the EEA.


CCPA/CPRA Privacy Notice  

========================


This privacy notice section for California residents supplements the

information contained in Our Privacy Policy and it applies solely to all

visitors, users, and others who reside in the State of California.


Categories of Personal Information Collected  

--------------------------------------------


We collect information that identifies, relates to, describes, references, is

capable of being associated with, or could reasonably be linked, directly or

indirectly, with a particular Consumer or Device. The following is a list of

categories of personal information which we may collect or may have been

collected from California residents within the last twelve (12) months.


Please note that the categories and examples provided in the list below are

those defined in the CCPA/CPRA. This does not mean that all examples of that

category of personal information were in fact collected by Us, but reflects

our good faith belief to the best of Our knowledge that some of that

information from the applicable category may be and may have been collected.

For example, certain categories of personal information would only be

collected if You provided such personal information directly to Us.


  * Category A: Identifiers.


    Examples: A real name, alias, postal address, unique personal identifier,

    online identifier, Internet Protocol address, email address, account name,

    driver's license number, passport number, or other similar identifiers.


    Collected: Yes.


  * Category B: Personal information categories listed in the California

    Customer Records statute (Cal. Civ. Code § 1798.80(e)).


    Examples: A name, signature, Social Security number, physical

    characteristics or description, address, telephone number, passport

    number, driver's license or state identification card number, insurance

    policy number, education, employment, employment history, bank account

    number, credit card number, debit card number, or any other financial

    information, medical information, or health insurance information. Some

    personal information included in this category may overlap with other

    categories.


    Collected: Yes.


  * Category C: Protected classification characteristics under California or

    federal law.


    Examples: Age (40 years or older), race, color, ancestry, national origin,

    citizenship, religion or creed, marital status, medical condition,

    physical or mental disability, sex (including gender, gender identity,

    gender expression, pregnancy or childbirth and related medical

    conditions), sexual orientation, veteran or military status, genetic

    information (including familial genetic information).


    Collected: No.


  * Category D: Commercial information.


    Examples: Records and history of products or services purchased or

    considered.


    Collected: Yes.


  * Category E: Biometric information.


    Examples: Genetic, physiological, behavioral, and biological

    characteristics, or activity patterns used to extract a template or other

    identifier or identifying information, such as, fingerprints, faceprints,

    and voiceprints, iris or retina scans, keystroke, gait, or other physical

    patterns, and sleep, health, or exercise data.


    Collected: No.


  * Category F: Internet or other similar network activity.


    Examples: Interaction with our Service or advertisement.


    Collected: Yes.


  * Category G: Geolocation data.


    Examples: Approximate physical location.


    Collected: No.


  * Category H: Sensory data.


    Examples: Audio, electronic, visual, thermal, olfactory, or similar

    information.


    Collected: No.


  * Category I: Professional or employment-related information.


    Examples: Current or past job history or performance evaluations.


    Collected: No.


  * Category J: Non-public education information (per the Family Educational

    Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).


    Examples: Education records directly related to a student maintained by an

    educational institution or party acting on its behalf, such as grades,

    transcripts, class lists, student schedules, student identification codes,

    student financial information, or student disciplinary records.


    Collected: No.


  * Category K: Inferences drawn from other personal information.


    Examples: Profile reflecting a person's preferences, characteristics,

    psychological trends, predispositions, behavior, attitudes, intelligence,

    abilities, and aptitudes.


    Collected: No.


  * Category L: Sensitive personal information.


    Examples: Account login and password information, geolocation data.


    Collected: Yes.


Under CCPA/CPRA, personal information does not include:


  * Publicly available information from government records

  * Deidentified or aggregated consumer information

  * Information excluded from the CCPA/CPRA's scope, such as:

    * Health or medical information covered by the Health Insurance

      Portability and Accountability Act of 1996 (HIPAA) and the California

      Confidentiality of Medical Information Act (CMIA) or clinical trial data

    * Personal Information covered by certain sector-specific privacy laws,

      including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley

      Act (GLBA) or California Financial Information Privacy Act (FIPA), and

      the Driver's Privacy Protection Act of 1994


Sources of Personal Information  

-------------------------------


We obtain the categories of personal information listed above from the

following categories of sources:


  * Directly from You. For example, from the forms You complete on our

    Service, preferences You express or provide through our Service, or from

    Your purchases on our Service.

  * Indirectly from You. For example, from observing Your activity on our

    Service.

  * Automatically from You. For example, through cookies We or our Service

    Providers set on Your Device as You navigate through our Service.

  * From Service Providers. For example, third-party vendors to monitor and

    analyze the use of our Service, third-party vendors to deliver targeted

    advertising to You, third-party vendors for payment processing, or other

    third-party vendors that We use to provide the Service to You.


Use of Personal Information  

---------------------------


We may use or disclose personal information We collect for "business purposes"

or "commercial purposes" (as defined under the CCPA/CPRA), which may include

the following examples:


  * To operate our Service and provide You with Our Service.

  * To provide You with support and to respond to Your inquiries, including to

    investigate and address Your concerns and monitor and improve our Service.

  * To fulfill or meet the reason You provided the information. For example,

    if You share Your contact information to ask a question about our Service,

    We will use that personal information to respond to Your inquiry. If You

    provide Your personal information to purchase a product or service, We

    will use that information to process Your payment and facilitate delivery.

  * To respond to law enforcement requests and as required by applicable law,

    court order, or governmental regulations.

  * As described to You when collecting Your personal information or as

    otherwise set forth in the CCPA/CPRA.

  * For internal administrative and auditing purposes.

  * To detect security incidents and protect against malicious, deceptive,

    fraudulent or illegal activity, including, when necessary, to prosecute

    those responsible for such activities.

  * Other one-time uses.


Please note that the examples provided above are illustrative and not intended

to be exhaustive. For more details on how we use this information, please

refer to the "Use of Your Personal Data" section.


If We decide to collect additional categories of personal information or use

the personal information We collected for materially different, unrelated, or

incompatible purposes We will update this Privacy Policy.


Disclosure of Personal Information  

----------------------------------


We may use or disclose and may have used or disclosed in the last twelve (12)

months the following categories of personal information for business or

commercial purposes:


  * Category A: Identifiers

  * Category B: Personal information categories listed in the California

    Customer Records statute (Cal. Civ. Code § 1798.80(e))

  * Category D: Commercial information

  * Category F: Internet or other similar network activity


Please note that the categories listed above are those defined in the

CCPA/CPRA. This does not mean that all examples of that category of personal

information were in fact disclosed, but reflects our good faith belief to the

best of our knowledge that some of that information from the applicable

category may be and may have been disclosed.


When We disclose personal information for a business purpose or a commercial

purpose, We enter a contract that describes the purpose and requires the

recipient to both keep that personal information confidential and not use it

for any purpose except performing the contract.


Share of Personal Information  

-----------------------------


We may share, and have shared in the last twelve (12) months, Your personal

information identified in the above categories with the following categories

of third parties:


  * Service Providers

  * Payment processors

  * Our affiliates

  * Our business partners

  * Third party vendors to whom You or Your agents authorize Us to disclose

    Your personal information in connection with products or services We

    provide to You


Sale of Personal Information  

----------------------------


As defined in the CCPA/CPRA, "sell" and "sale" mean selling, 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 valuable

consideration. This means that We may have received some kind of benefit in

return for sharing personal information, but not necessarily a monetary

benefit.


We do not sell personal information as the term sell is commonly understood.

We do allow Service Providers to use Your personal information for the

business purposes described in Our Privacy Policy, for activities such as

advertising, marketing, and analytics, and these may be deemed a sale under

CCPA/CPRA.


We may sell and may have sold in the last twelve (12) months the following

categories of personal information:


  * Category A: Identifiers

  * Category B: Personal information categories listed in the California

    Customer Records statute (Cal. Civ. Code § 1798.80(e))

  * Category D: Commercial information

  * Category F: Internet or other similar network activity


Please note that the categories listed above are those defined in the

CCPA/CPRA. This does not mean that all examples of that category of personal

information were in fact sold, but reflects our good faith belief to the best

of Our knowledge that some of that information from the applicable category

may be and may have been shared for value in return.


Sale of Personal Information of Minors Under 16 Years of Age  

------------------------------------------------------------


We do not knowingly collect personal information from minors under the age of

16 through our Service, although certain third party websites that we link to

may do so. These third-party websites have their own terms of use and privacy

policies and We encourage parents and legal guardians to monitor their

children's Internet usage and instruct their children to never provide

information on other websites without their permission.


We do not sell the personal information of Consumers We actually know are less

than 16 years of age, unless We receive affirmative authorization (the "right

to opt-in") from either the Consumer who is between 13 and 16 years of age, or

the parent or guardian of a Consumer less than 13 years of age. Consumers who

opt-in to the sale of personal information may opt-out of future sales at any

time. To exercise the right to opt-out, You (or Your authorized

representative) may submit a request to Us by contacting Us.


If You have reason to believe that a child under the age of 13 (or 16) has

provided Us with personal information, please contact Us with sufficient

detail to enable Us to delete that information.


Your Rights under the CCPA/CPRA  

-------------------------------


The CCPA/CPRA provides California residents with specific rights regarding

their personal information. If You are a resident of California, You have the

following rights:


  * The right to notice. You have the right to be notified which categories of

    Personal Data are being collected and the purposes for which the Personal

    Data is being used.

  * The right to know/access. Under CCPA/CPRA, You have the right to request

    that We disclose information to You about Our collection, use, sale,

    disclosure for business purposes and share of personal information. Once

    We receive and confirm Your request, We will disclose to You:

    * The categories of personal information We collected about You

    * The categories of sources for the personal information We collected

      about You

    * Our business or commercial purposes for collecting or selling that

      personal information

    * The categories of third parties with whom We share that personal

      information

    * The specific pieces of personal information We collected about You

    * If we sold Your personal information or disclosed Your personal

      information for a business purpose, We will disclose to You:

      * The categories of personal information categories sold

      * The categories of personal information categories disclosed

  * The right to say no to the sale or sharing of Personal Data (opt-out). You

    have the right to direct Us to not sell Your personal information. To

    submit an opt-out request, please see the "Do Not Sell My Personal

    Information" section or contact Us.

  * The right to correct Personal Data. You have the right to correct or

    rectify any any inaccurate personal information about You that We

    collected. Once We receive and confirm Your request, We will use

    commercially reasonable efforts to correct (and direct our Service

    Providers to correct) Your personal information, unless an exception

    applies.

  * The right to limit use and disclosure of sensitive Personal Data. You have

    the right to request to limit the use or disclosure of certain sensitive

    personal information We collected about You, unless an exception applies.

    To submit, please see the "Limit the Use or Disclosure of My Sensitive

    Personal Information" section or contact Us.

  * The right to delete Personal Data. You have the right to request the

    deletion of Your Personal Data under certain circumstances, subject to

    certain exceptions. Once We receive and confirm Your request, We will

    delete (and direct Our Service Providers to delete) Your personal

    information from our records, unless an exception applies. We may deny

    Your deletion request if retaining the information is necessary for Us or

    Our Service Providers to:

    * Complete the transaction for which We collected the personal

      information, provide a good or service that You requested, take actions

      reasonably anticipated within the context of our ongoing business

      relationship with You, or otherwise perform our contract with You.

    * Detect security incidents, protect against malicious, deceptive,

      fraudulent, or illegal activity, or prosecute those responsible for such

      activities.

    * Debug products to identify and repair errors that impair existing

      intended functionality.

    * Exercise free speech, ensure the right of another consumer to exercise

      their free speech rights, or exercise another right provided for by law.

    * Comply with the California Electronic Communications Privacy Act (Cal.

      Penal Code § 1546 et. seq.).

    * Engage in public or peer-reviewed scientific, historical, or statistical

      research in the public interest that adheres to all other applicable

      ethics and privacy laws, when the information's deletion may likely

      render impossible or seriously impair the research's achievement, if You

      previously provided informed consent.

    * Enable solely internal uses that are reasonably aligned with consumer

      expectations based on Your relationship with Us.

    * Comply with a legal obligation.

    * Make other internal and lawful uses of that information that are

      compatible with the context in which You provided it.

  * The right not to be discriminated against. You have the right not to be

    discriminated against for exercising any of Your consumer's rights,

    including by:

    * Denying goods or services to You

    * Charging different prices or rates for goods or services, including the

      use of discounts or other benefits or imposing penalties

    * Providing a different level or quality of goods or services to You

    * Suggesting that You will receive a different price or rate for goods or

      services or a different level or quality of goods or services


Exercising Your CCPA/CPRA Data Protection Rights  

------------------------------------------------


Please see the "Do Not Sell My Personal Information" section and "Limit the

Use or Disclosure of My Sensitive Personal Information" section for more

information on how to opt out and limit the use of sensitive information

collected.


Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and

if You are a California resident, You can contact Us:


  * By email: csilla.kovacs@csk-digital.consulting


Only You, or a person registered with the California Secretary of State that

You authorize to act on Your behalf, may make a verifiable request related to

Your personal information.


Your request to Us 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 cannot respond to Your request or provide You with the required information

if We cannot:


  * Verify Your identity or authority to make the request

  * And confirm that the personal information relates to You


We will disclose and deliver the required information free of charge within 45

days of receiving Your verifiable request. The time period to provide the

required information may be extended once by an additional 45 days when

reasonably necessary and with prior notice.


Any disclosures We provide will only cover the 12-month period preceding the

verifiable request's receipt.


For data portability requests, We will select a format to provide Your

personal information that is readily usable and should allow You to transmit

the information from one entity to another entity without hindrance.


Do Not Sell My Personal Information  

-----------------------------------


As defined in the CCPA/CPRA, "sell" and "sale" mean selling, 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 valuable

consideration. This means that We may have received some kind of benefit in

return for sharing personal information, but not necessarily a monetary

benefit.


We do not sell personal information as the term sell is commonly understood.

We do allow Service Providers to use Your personal information for the

business purposes described in Our Privacy Policy, for activities such as

advertising, marketing, and analytics, and these may be deemed a sale under

CCPA/CPRA.


You have the right to opt-out of the sale of Your personal information. Once

We receive and confirm a verifiable consumer request from You, we will stop

selling Your personal information. To exercise Your right to opt-out, please

contact Us.


The Service Providers we partner with (for example, our analytics or

advertising partners) may use technology on the Service that sells personal

information as defined by the CCPA/CPRA law. If you wish to opt out of the use

of Your personal information for interest-based advertising purposes and these

potential sales as defined under CCPA/CPRA law, you may do so by following the

instructions below.


Please note that any opt out is specific to the browser You use. You may need

to opt out on every browser that You use.


Website  

~~~~~~~


If applicable, click "Privacy Preferences", "Update Privacy Preferences" or

"Do Not Sell My Personal Information" buttons listed on the Service to review

your privacy preferences and opt out of cookies and other technologies that We

may use. Please note that You will need to opt out from each browser that You

use to access the Service.


Additionally, You can opt out of receiving ads that are personalized as served

by our Service Providers by following our instructions presented on the

Service:


  * The NAI's opt-out platform: <http://www.networkadvertising.org/choices/>

  * The EDAA's opt-out platform <http://www.youronlinechoices.com/>

  * The DAA's opt-out platform:

    [http://optout.aboutads.info/?c=2&lang=EN](http://optout.aboutads.info/?c=2&lang=EN)


The opt out will place a cookie on Your computer that is unique to the browser

You use to opt out. If you change browsers or delete the cookies saved by your

browser, You will need to opt out again.


Mobile Devices  

~~~~~~~~~~~~~~


Your mobile device may give You the ability to opt out of the use of

information about the apps You use in order to serve You ads that are targeted

to Your interests:


  * "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on

    Android devices

  * "Limit Ad Tracking" on iOS devices


You can also stop the collection of location information from Your mobile

device by changing the preferences on Your mobile device.


Limit the Use or Disclosure of My Sensitive Personal Information  

----------------------------------------------------------------


If You are a California resident, You have the right to limit the use and

disclosure of Your sensitive personal information to that use which is

necessary to perform the services or provide the goods reasonably expected by

an average Consumer who requests such services or goods.


We collect, use and disclose sensitive personal information in ways that are

necessary to provide the Service. For more information on how We use Your

personal information, please see the "Use of Your Personal Data" section or

contact us.


"Do Not Track" Policy as Required by California Online Privacy Protection Act

(CalOPPA)  

========================================================================


Our Service does not respond to Do Not Track signals.


However, some third party websites do keep track of Your browsing activities.

If You are visiting such websites, You can set Your preferences in Your web

browser to inform websites that You do not want to be tracked. You can enable

or disable DNT by visiting the preferences or settings page of Your web

browser.


Your California Privacy Rights (California's Shine the Light law)  

=================================================================


Under California Civil Code Section 1798 (California's Shine the Light law),

California residents with an established business relationship with us can

request information once a year about sharing their Personal Data with third

parties for the third parties' direct marketing purposes.


If you'd like to request more information under the California Shine the Light

law, and if You are a California resident, You can contact Us using the

contact information provided below.


California Privacy Rights for Minor Users (California Business and Professions

Code Section 22581)  

==================================================================================================


California Business and Professions Code Section 22581 allows California

residents under the age of 18 who are registered users of online sites,

services or applications to request and obtain removal of content or

information they have publicly posted.


To request removal of such data, and if You are a California resident, You can

contact Us using the contact information provided below, and include the email

address associated with Your account.


Be aware that Your request does not guarantee complete or comprehensive

removal of content or information posted online and that the law may not

permit or require removal in certain circumstances.


Children's Privacy  

==================


Our Service does not address anyone under the age of 13. We do not knowingly

collect personally identifiable information from anyone under the age of 13.

If You are a parent or guardian and You are aware that Your child has provided

Us with Personal Data, please contact Us. If We become aware that We have

collected Personal Data from anyone under the age of 13 without verification

of parental consent, We take steps to remove that information from Our

servers.


If We need to rely on consent as a legal basis for processing Your information

and Your country requires consent from a parent, We may require Your parent's

consent before We collect and use that information.


Links to Other Websites  

=======================


Our Service may contain links to other websites that are not operated by Us.

If You click on a third party link, You will be directed to that third party's

site. We strongly advise You to review the Privacy Policy of every site You

visit.


We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.


Changes to this Privacy Policy  

==============================


We may update Our Privacy Policy from time to time. We will notify You of any

changes by posting the new Privacy Policy on this page.


We will let You know via email and/or a prominent notice on Our Service, prior

to the change becoming effective and update the "Last updated" date at the top

of this Privacy Policy.


You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this

page.

Contact Us  

==========

If you have any questions about this Privacy Policy, You can contact us:

  * By email: csilla.kovacs@csk-digital.consulting