Minute Media Privacy Policy

Last updated: March 2024

Our Commitment to You

Pro Sportority (Israel) Ltd., and its affiliated companies ("Minute Media" or "we") are dedicated to providing you with transparency and control over the use of your data, ensuring that your privacy is protected and complying with applicable data protection rules in the jurisdictions in which we operate, including (but not limited to) the European Economic Area, United Kingdom, United States and Canada (collectively, the “Data Protection Laws”). In order for us to provide you with our Services we may collect and process certain Personal Data about you and your activity.
We have taken measurable steps to protect the confidentiality, security and integrity of such Personal Data collected and/or processes by us.
We strongly urge you to read this Privacy Policy (“Policy”) and make sure that you fully understand and agree to its terms. By using any of our Websites or Services or any other product (including any mobile application or other digital platform) that link to this Policy, you consent to the Processing of your Personal Data in accordance with this Policy. For the purposes of this Policy, “Process”, “Processed” and “Processing” includes the collection, storage, use, disclosure and processing, as applicable, of your Personal Data. If you do not agree to this Policy, please discontinue and avoid using our Services. You may cease using our Services at any time, pursuant to this Policy and our Terms and Conditions. You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the best experience of using our Services.

With respect to processing of personal data on residents of the EU, we participate in the IAB Europe Transparency & Consent Framework, and comply with the Policies and Specifications and with the Transparency & Consent Framework provided by IAB Europe. Our IAB Europe vendor ID is 918.

(1) Why do We Process your Personal Data?

Your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means, or can otherwise reasonably be used to identify a person, directly or indirectly, but does not include anonymous information or information that relates to a group of people rather than individuals where the information does not otherwise contain identifying information), will be Processed with your consent and/or for the purposes and the corresponding legal bases as described in more detail below, as applicable, as necessary for the provision of our services and products (including, without limitation, any content therein), the operation of our brand websites, newsletter and related mobile apps (hereinafter our “Brand Websites”, also listed on the homepage of this website) and the operation of all of our websites (collectively the “Services”, and the “Websites”).

(2) How Do We Receive Data About You?

We receive your Personal Data from various sources:

1. Registration information - When you voluntarily provide us your personal details to create an account or register to our Services or submit a job application (for example, your name and email address).
2. When you communicate with us - For example when you send us a message, or apply to be a content provider/editor, or complete a form for another purpose using our Services, we collect the Personal Data you provided us with.
3. When you submit content to or through the Services.
4. When you respond to or participate in one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums or by otherwise expressing an opinion.
5. When you click on links included in our Services that lead to third party products and/or services offered on third party sites by business partners we are affiliated with (“Affiliate Link/s”).
6. When you purchase, return, win, or exchange products offered through the Services.
7. Technical information - When operating our Services, we use various technological tracking tools to collect information regarding your use of the Services. Along with our partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage, which are used to store content information and preferences. You can learn more about the tracking tools we use by visiting our Cookie Policy. Additionally, residents of the EEA or other applicable jurisdictions may use our Cookie Settings tool to learn more and to change their preferences.
8. Third party information (vendors) – We may receive your data from third party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and username, when you register or log-in to our Services, or Candidate Data (as defined below) when you submit a job application via a social network such as LinkedIn), traffic analytics vendors, fraud prevention agencies and others.
9. Third party information (business partners) - We also receive your data from publishers and advertisers who use our platform and other services, as well as from business partners for data segmentation and optimization purposes.

(3) What Type of Data We Collect?

a. Personal Data

In the course of using the Services, we may ask you to provide us with certain Personal Data to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Websites, and as otherwise indicated in this Policy. We may collect the following Personal Data about you:

• When you sign up to an event or receive our newsletter, when you send us a message (or submit a support ticket), or otherwise communicate with us in relation to the Services, we may receive certain data, such as: your name, email address or other information included in such communications.
• If you create an account or register to our Services, or connect your account and log-in to our Services via to a social network (for example: if you log in via Facebook), we may also collect certain data, such as your associated credentials, profile name, email address, profile photo, age and country/state of residence.
• If applicable, payment data such as your payment instrument number (such as a credit card number) and billing information, collected in order to process your payments for purchases, fulfill your requests for refunds, returns, or exchanges, and process the redemption of discounts. This data is usually processed by our relevant service providers, and not retained by us.
• In the framework of one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums, content publishing ("Activity") and when you choose to provide it, we may also collect information about your personal or professional interests, lifestyle, favorites and opinions about various topics, products, programs and services. The type of information collected may be influenced by the nature of our Website conducting the Activity (e.g. a home decor website may ask for information on the type of home you live in, and whether you are a renting or a home owner). Such information may include your full name, information regarding your marital/relationship status and number of children, gender, year of birth, your state and city of residency, employment status, your astrological sign, and any additional information you choose to provide in connection to such Activity.
• Internet or other electronic network activity information - our Services may use your IP- address and UDID and other information regarding your interaction with our Services and/or with advertisements displayed on our Services on the Brand Websites.
• Geolocation data – our Services may use information regarding your general location.
• Information from third parties – this includes information we receive from our business partners. This may include pseudonymous advertiser identifiers that some advertisers or other third party ad platforms choose to share with us, as well as other segmentation data. This information is also used to enhance data points about a particular unique browser or device, to segment and enrich data for the purposes set forth above. While we strive to keep such data in a non-identifiable manner, in some jurisdictions, such data may qualify as personal data.

b. Technical Data

We also collect data about the use of our Services and the characteristics and activities of users, in order to operate it and improve it. We may collect the following “Technical Data”:

1. Device information – this includes data such as website visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), and non-identifiable cookie information.

c. Voice Processing Technologies

If you choose to use Amazon Alexa Skills or Google Assistant in connection with the Services, Amazon and Google will process your personal data via their voice processing technologies, by which they collect audio through the microphone on your device(s) to effectuate an instruction or request by you using Amazon Alexa Skills or Google Assistant. Please be aware that your use of Amazon Alexa Skills or Google Assistant may provide Amazon and Google with access to and use of information associated with your use of their device, including the audio you provide, and you should carefully review their privacy policy and terms of use (to learn more about their data processing, please visit Google's policies, here and here ; and Amazon's policies: here and here). we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

d. Job Candidates from the EU and Canada

• Personal Data of Job candidates who apply for any of our and our affiliated companies’ open jobs in the EU or Canada (“Candidates”), is also subject to this Policy, and in addition, to the terms specifically provided in this section, which shall prevail over the rest of the terms of this Policy in case of inconsistency. Within an application of a Candidate, we may collect certain Personal Data about the Candidate, as provided by the Candidate, such as: resume, contact details, occupation data and other related information (“Candidate Data”).
• Our main management and retention platform provider for Candidate Data is Comeet Technologies Inc. (“Comeet”). Candidates are welcome to review Comeet’s privacy notice at: https://help.comeet.com/en/articles/3134994-privacy-notice.. Candidates should not apply for a job and provide us with their Personal Data, unless they have read and agreed to this Policy and Comeet’s privacy notice.
• A Candidate may also apply for a position via third parties (such as: LinkedIn, Glassdoor, placement companies, etc.), who may provide us with Candidate’s Personal Data on Candidate’s behalf. Any Personal Data that we receive via from such third parties may be subject to this Policy, but each Candidate is requested to review the privacy policies of such third parties (of which we do not assume any liability for) prior to providing us with any Personal Data via their services.
• We aim to protect the privacy of Candidate Data and use such data solely for our and our affiliated companies’ internal recruitment purposes (inter alia, for contacting the Candidates, evaluating them for a specific position, etc.). In case a Candidate provides a reference, certain necessary relevant Candidate Data may be inevitably revealed to such reference in the process of a reference check (e.g., the fact that Candidate is searching for a new job, and any other relevant information included in Candidate’s resume, etc.), and thus a Candidate should not provide a reference in case Candidate does not wish such information to be disclosed.
• We retain Candidate Data within Comeet for no longer than thirty six (36) months after the last activity was made in relation to a Candidate on Comeet, unless the Candidate has provided consent for a longer period of retention. Resumes, and Candidate Data provided to us via other means, may be retained in other systems for longer periods, subject to the general retention framework specified in this Policy under the “Retention” section below. The purpose of retaining Candidate Data is to enable us to contact a Candidate who we find suitable in order to inform the Candidate of a new job vacancy, and in order to use such data in case the Candidate contacts us again and applies for the same or a different position.
• If you wish to exercise any of your “European Users Rights” specified below in this Policy or receive more information regarding Candidate Data, please contact our Data Protection Officer (“DPO”) using the details provided below. Kindly specify that your request is related to your Candidate Data. Email: [email protected].

e. Tracking Technologies

When you visit or access our Services we use (and authorize third parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Websites’ performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data. To learn more about our Tracking Technologies please visit our Cookie Policy page

(4) How do we use the data we collect?

• Provision of service - for the provision and improvement of our Services, including for support, responding to your queries, and processing of payments as stated in Section 3 above.
• Service announcements - we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
• Marketing and advertising purposes - by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also use your Personal Data in the following ways: we may send you promotional material concerning our Services, or our partners' services, which we believe might interest you; we may also display certain ads on our Services or on our Brand Websites, which we believe will be relevant for you. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data.
• Collaborating with third parties – we may partner with third party businesses to receive or share your Personal Data for data segmentation, enrichment and optimization purposes, which allow us or our partners to personalize and optimize the services, advertisements and marketing activities we or they offer you. In some jurisdictions, this is subject to opt-out options set forth in this Policy.
• Opt-out of retargeted advertising - you may object to the use of your Personal Data for advertising purposes by disabling your cookies, as described in our Cookie Policy.
• Opt-out of sale and sharing of your data – in some jurisdictions, you may opt-out from the sale or sharing of your Personal Data to third parties by using our designated tools (such as opt-out banners, cookie preference banners, Do-Not-Sell buttons, etc.), as well as by contacting us in the manner set forth below.
• Opt-out of receiving marketing materials - if you do not want us to use or share your Personal Data for marketing purposes, you may opt-out in accordance with this "Opt-out" section. You may choose not to receive our promotional or marketing emails by clicking on the “unsubscribe” link in the emails that you receive from us, or contact our data privacy officer “DPO” at [email protected] (kindly specify the name of the relevant product from which you wish to unsubscribe from). Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us. Also note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services. If you subscribed to any of our partners' service, please note we will have no control over our partners' communications, and in order to unsubscribe from it please contact the relevant partner or use the "unsubscribe" link in its emails.
• Push Notifications - if you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our relevant app.
• Analytics, surveys and research - from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and think of new and exciting features for our users.
• Protecting our interests - we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and protect the rights and property of Minute Media, its users and/or partners.
• Enforcing of policies - we may use your Personal Data in order to enforce our policies and relevant terms of use of our Brand Websites.
• Compliance with legal and regulatory requirements - we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

(5) With whom do we share your Personal Data?

• Internal concerned parties - we share your information with companies in our group, as well as our employees, in order to provide you with our Services.
• Vendors and service providers - we share your information with business partners, such as SaaS, storage, advertising, and analytics providers who help us provide you with our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with contractual privacy obligations.
• Business partners - we may partner with third party businesses to share your Personal Data for data segmentation, enrichment and optimization purposes, which allow us or our partners to personalize and optimize the Services, advertisements and marketing activities we or they offer you. In some jurisdictions, this is subject to opt-out options set forth in this Policy.
• User Profiles and Submissions – certain user profile information, including your name, location, and any related video or image content you uploaded to the Services for publication, may be displayed to other users as part of the Services, to facilitate user interaction within the Services or address your request for our Services. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (e.g., on your published content, forums, discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your name/username may also be displayed to other users if and when you send messages or comments or upload images, content or videos through the Services.
• Compliance with laws and law enforcement entities - we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
• Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, divestiture, acquisition, restructuring, reorganization, dissolution, bankruptcy, or other sale or transfer or business transaction involving all or part of our company or assets, including for the purposes of determining whether to proceed with such transaction. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.

(6) How we protect your information

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.

(7) Retention

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

(8) Transfer of data outside the EEA or UK

We operate globally, thus any information that we collect, disclose or share, including your Personal Data, can be stored and processed in various other jurisdictions around the world (“Other Jurisdictions”), including (but not limited to) the European Economic Area, United Kingdom, United States and Canada, for the purposes detailed in this Policy. As a result, your Personal Data may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement, and national security authorities of that jurisdiction. EU users, please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection. To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:

• located in the EEA or in the UK;
• located in non-EEA countries or non-UK which have been approved as providing adequate level of data protection; or
• who have entered into legal agreements and performed assessments ensuring an adequate level of data protection by the recipient.

You can obtain more information about our policies and practices with respect to the use of service providers located in Other Jurisdictions by contacting us as described below under the “How to Contact Us” heading.

(9) Rights and Information for Residents of Specific Jurisdictions

A. European or UK Users' Rights

If you reside within the European Union or the UK, you may request to:

1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your Personal Data that is in our control.
4. Object to the processing of Personal Data by us.
5. Request to restrict processing of your Personal Data by us.
6. Request erasure of your Personal Data.
7. Lodge a complaint with a supervisory authority.

However, please note that these rights pertain to EU and UK residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. ​If you, as EU of UK resident, would like to exercise any of the rights mentioned in this section, please refer to the section 9B below.

B. EEA or UK Residents

If you reside in the EEA or UK, we will be the controller of your Personal Data provided to, collected by or for, or processed by us in connection with our Services. All requests, complaints and queries should be addressed to us by submitting a verifiable consumer request to our email address: [email protected] (please provide the required details as per Section 15 below).

We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Our representative in the United Kingdom is 385-389 Oxford St. London W1C 2NB and their email address is: [email protected]. In addition, you can exercise your rights via [email protected], where you can submit a verifiable user request.

Only you or a person legally authorized to act on your behalf may make a consumer request related to your Personal Data (“Request”).

The Request must:

• Provide sufficient information allowing us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative.
• Describe your Request with sufficient details to allow us to properly understand, evaluate, and respond to it.
• We cannot respond to your Request or provide you with Personal Data if we cannot verify your identity or authority to make the Request and confirm the Personal Data relates to you. Making a verifiable Request does not require you to create an account with us. We will only use Personal Data provided in a verifiable Request to verify the requestor's identity or authority to make the Request. If you have any general questions about the Personal Data that we collect about you or how we use it, please contact us at [email protected].

C. California Residents

For the purposes of this section, the "CCPA" shall mean the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act of 2020, and the regulations promulgated thereunder.

In the preceding 12 months, we have collected, disclosed, and/or sold the following categories of Personal Data:



We may share or transfer Personal Data to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of Minute Media. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Data under the CCPA.

In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from either of the following categories of sources:

* Consumer directly;
* Social media;
* Fraud prevention service providers;
* Analytics Providers;
* Ad networks.
* ID companies;
* Data segmentation providers.

C1. California Consumers' Rights

The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

a. Access to Personal Data

You may request, up to two times in a 12 months period, that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Data, if applicable.

b. Right of Data Portability

You have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability.

c. Right of rectification

You have the right to request us to rectify your Personal Data place in our control in the event that you believe your Personal Data is inaccurate, incomplete or outdated.

d. Right of Deletion/Erasure

You have the right to request that we delete any Personal Data collected from you and retained by us, unless an exception applies. Once we receive and confirm your verifiable consumer request, we will delete (and where necessary and relevant, direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.

e. Right to restriction or objection to processing

You have the right to request that we will restrict or cease to conduct certain Personal Data processes at any time.

f. Right to withdraw your consent

To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.

g. Right to limit use and disclosure of your sensitive Personal Data

You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services.

h. Right not to be subject to automated decision making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

i. Right to Opt-Out of the Sale of Personal Data

If we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.

If you do not want us to sell your Personal Data to third parties, please click on the “Do Not Sell My Personal Information” link located on the homepages of our Brand Websites for residents located in California.

After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site (or app) from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Data collected when you use those devices or browsers.

Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/.

You may also download the AppChoices app at https://www.aboutads.info/appchoices to opt-out in connection with mobile apps, or use the platform controls on your mobile device to opt-out.

j. Right to non-discrimination

You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

k. Non-Discrimination

Unless permitted by the CCPA, in connection with you exercising your aforementioned rights, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

l. Requests Metrics

We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between July 1 st of the previous year to April 20 th of the following year):

m. Authorized Agents (CCPA)

If you reside in California, you can use an authorized agent to make a Request to exercise your right under applicable laws on your behalf if:

• The authorized agent is a natural person or a business entity; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

The request must:

• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your Request or provide you with Personal Data if we cannot verify your identity or authority to make the Request and confirm the Personal Data relates to you; and
• Describe your Request with sufficient details to allow us to properly understand, evaluate, and respond to it.
• We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Making a verifiable Request does not require you to create an account with us.

D. Brazilian Residents

The following part of this Policy complements the general part of the Policy and addresses the specific disclosure requirements under the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, "LGPD").

a. Processing of Personal Data

The processing of your Personal Data is not a condition for the use our Services. However, parts of our Services may not be available without registration and/or payment, which involve the processing of Personal Data.

b. Brazilian Users' Rights:

If you reside in Brazil, you have the following rights under LGPD:

• Receive confirmation as to whether or not Personal Data concerning you is being processed;
• Access your Personal Data;
• Correct incomplete, inaccurate or outdated Personal Data;
• Request anonymization, blocking or deletion of unnecessary, excessive Personal Data;
• Request data portability to another service provider or product, upon express request, as may be provided by the appropriate law;
• Request deletion of Personal Data processed with your consent;
• Obtain information about the public or private entities with which we share your Personal Data;
• Request information on the possibility of you not providing consent, as well as being informed about the consequences should consent not be given;
• Revoke your consent.

If you would like to exercise any of any of the rights mentioned in this section, please contact the email address mentioned below: [email protected] (please provide the required details as per Section 15 below).

E. Canadian Residents

If you are resident in Canada, you may have certain rights (including those described below) with respect to your Personal Data that we Process. To exercise any of your privacy rights, please contact us as set out below under the “How to Contact Us” heading.

• Updating your Personal Data – We want to make sure that the Personal Data that we have collected about you is accurate, complete, and current. However, we may not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Data. Since we generally rely on you to inform us if there have been any changes to the Personal Data that we have collected about you, please let us know if any of this information has changed.
• Access to and Correction of Personal Data – If you have any questions about the accuracy of the Personal Data that we have collected about you, you can have access to that Personal Data in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Data.
• Withdrawal of Consent – Where you have provided your consent to the Processing of your Personal Data, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
• Unsubscribe from Marketing and Promotional Communications – If you are receiving our marketing and promotional electronic communications, you may unsubscribe at any time by clicking on the “unsubscribe” option in any electronic marketing communication (e.g. email) you receive or by contacting us as set out below under the “How to Contact Us” heading. Please note that if you unsubscribe from marketing communications, we may still send you transaction emails or emails about your account and use of our Websites.

(10) Response Timing and Format

Our goal is to respond to a verifiable consumer request within 45 days (for US residents), or 30 days (for UK and EU residents) of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the initial response period. We will deliver our written response, electronically. If reasonably possible, we will provide your Personal Data in a format that is readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.

(11) Other Jurisdictions

Under certain jurisdictions, some of the aforementioned rights may apply as well. Please contact us using the contact details provided below and we would make our best efforts to assist with any questions or requests.

(12) Our Policy toward Children

We do not knowingly collect or solicit Personal Data from Minors (as determined under the applicable laws where the individual resides; “Minors”). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. If we have collected Personal Data from a Minor without verification of parental or legal guardianship consent, we will delete that information upon discovery.

If you believe that we might have any information from or about a Minor, then please contact us through the contact details available below.

(13) Updates to this Policy

This Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Websites (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. In the event of material changes, we may also provide you with a notice. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

(14) Controlling Version

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

(15) How to contact us?

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below.

Kindly specify: (a) the nature of your request, (b) your country of residence, and (c) the name of the Services (website/product/application) subject of your request.​

Email: [email protected]

Please be advised that [email protected] is designated solely for privacy related inquiries of our users, and we reserve the right not respond to any non-privacy inquiries that are sent via the DPO email address. For any non-privacy inquiries, please send an email to [email protected].

Upon receiving your request, and according to legal obligations to which we are subject, we will first need to verify your request and therefore we may ask you to provide us with additional verification details, as needed. Following our verification process, we will respond to your request within the timeframe required under applicable laws.