Privacy Policy of AMBAYO

Full policy

Owner and Data Controller

Ambayo Limited,
Suite 1404, Tung Wai Commercial Building
109-111 Gloucester Road
Wanchai, 999077 Hong Kong

Owner contact email: support@ambayo.com

Types of Data collected

Among the types of Personal Data that AMBAYO collects, by itself or through third parties, there are: Trackers; Usage Data; device information; number of sessions; session duration; operating systems; first name; last name; email address; payment info; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; password.

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

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

Mode and place of processing the Data

Methods of processing

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

Place

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

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

Retention time

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

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Hosting and backend infrastructure, Registration and authentication, Handling payments, Contacting the User, Remarketing and behavioral targeting, Social features, Analytics, Managing contacts and sending messages, User database management, Handling finance and accounting, Advertising, Spam and bots protection, Traffic optimization and distribution, Displaying content from external platforms, Infrastructure monitoring, Content performance and features testing (A/B testing), Access to third-party accounts and Registration and authentication provided directly by AMBAYO.

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

Facebook permissions asked by AMBAYO

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

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

The permissions asked are the following:

Basic information

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

device information

Email

Provides access to the User's primary email address.

Trackers

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Usage Data

Detailed information on the processing of Personal Data

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

• Access to third-party accounts

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

  Facebook account access (Meta Platforms, Inc.)

  This service allows AMBAYO to connect with the User's account on the Facebook social network, provided by Meta Platforms, Inc.

  Permissions asked: device information; Email; Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on AMBAYO, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside AMBAYO. For more information, please check the privacy policies of the relevant services. Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.

  Google AdSense (Google LLC)

  Google AdSense is an advertising service provided by Google LLC. This service uses the “DoubleClick” Cookie, which tracks use of AMBAYO and User behavior concerning ads, products and services offered. Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  In order to understand Google's use of Data, consult their partner policy and their Business Data page.

  Personal Data processed: Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• Analytics

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

  Google Analytics for Firebase (for apps) (Google LLC)

  Google Analytics for Firebase (for apps) or Firebase Analytics is an analytics service provided by Google LLC. In order to understand Google's use of Data, consult Google's partner policy.

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

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

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

  Personal Data processed: device information; number of sessions; operating systems; session duration; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  QuickBooks

  We use the third-party service QuickBooks to provide us with financial analytics services.
  While you make payment transaction on AMBAYO, our analytics service provider collects and makes us available financial analytics data that allows us to see what products and services AMBAYO users purchase, as well as forecast and improve AMBAYO. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyse, improve, and protect AMBAYO) and ‘your consent’ bases.
  

• Contacting the User

  AMBAYO Enquiries

  When you contact us by email or completing the contact form available on AMBAYO, we collect your first name, last name, email address, and any information that you provide in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to build our client base and promote AMBAYO) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us, unless your data is necessary for further purposes like concluding a service contract, in which case it we will keep it is along as necessary for the intended purposes. If you do not provide the required data, we will not be able to respond to your inquiry.

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of AMBAYO.

  Firebase Remote Config (Google LLC)

  Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of AMBAYO and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Font Awesome (Fonticons, Inc. )

  Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows AMBAYO to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• Handling finance and accounting

  QuickBooks

  We use QuickBooks as our third-party accounting service and software provider. Therefore, our financial records, including your order and payment information, may be processed by QuickBooks. We use QuickBooks in order to process your orders, maintain our business records, and comply with our legal obligations.

• Handling payments

  Unless otherwise specified, AMBAYO processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. AMBAYO isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  Payment Processing on AMBAYO

  When you make or request a payment, our payment service providers collect your personal data that depends on the payment method chosen by you. Such information may include your full name, billing address, digital wallet codes, payment card number, CVV code, expiration month and year. We have access to a limited amount of personal data only that is disclosed to us by the payment processor. Your payment data is used to process payments and maintain our accounting records. The legal bases on which we rely are ‘performing our contractual obligations’ and ‘pursuing our legitimate interests’ (i.e., to administer and protect AMBAYO). We keep a part of your payment data that is provided to us by our payment processor for the time period prescribed by law. Your payment card details will NOT be stored, sold, shared, rented or leased to any third parties.
 If you do not provide the required data, we will not be able to process your payment and, therefore, you will not be able to buy or sell the products on AMBAYO.

  Stripe (Stripe, Inc.)

  Stripe is a payment service provided by Stripe, Inc.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  Coinbase (Coinbase Inc.)

  Coinbase is a payment service provided by Coinbase, Inc.

  Personal Data processed: payment info; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: commercial information; internet or other electronic network activity information.

• Hosting and backend infrastructure

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

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

  Amazon Web Services (AWS) (Amazon Web Services, Inc.)

  Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  Firebase Cloud Storage (Google LLC)

  Firebase Cloud Storage is a hosting service provided by Google LLC.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  Firebase Hosting (Google LLC)

  Firebase Hosting is a hosting service provided by Google LLC.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  SiteGround Hosting (SiteGround Hosting Ltd.)

  SiteGround Hosting is a hosting service provided by SiteGround Hosting Ltd.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United Kingdom – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• Infrastructure monitoring

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

  Firebase Performance Monitoring (Google LLC)

  Firebase Performance Monitoring is a monitoring service provided by Google LLC.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

• Managing contacts and sending messages

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

  Utopia

  When you contact us by using our live chat functionality, we collect your name and any information that you provide in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to support our users) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us, unless your data is necessary for further purposes like concluding a service contract, in which case it we will keep it is along as necessary for the intended purposes. If you do not provide the required data, we will not be able to respond to your inquiry.
  

  Firebase Cloud Messaging (Google LLC)

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

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  Firebase Notifications (Google LLC)

  Firebase Notifications is a message sending service provided by Google LLC. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

• Registration and authentication

  By registering or authenticating, Users allow AMBAYO to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, AMBAYO will be able to access some Data, stored by these third-party services, for registration or identification purposes. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  AMBAYO Account Registration

  When you register your user account by using your email address, we collect your name, email address, and phone number. When you register your user account by using your social media account (subject to availability), we have access to the personal data that your social media provider discloses to us (usually, your name, photo, and email address). We use this information to register and maintain your user account, contact you, if necessary, process your orders, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyse, grow, protect, and administer AMBAYO). We will store your account information until you delete your account. If you do not provide the required data, we will not be able to register your account and, therefore, you will not be able to use the full functionality of AMBAYO.
  

  AMBAYO Account Verification

  After the registration of your user account, we may ask you to provide (i) a copy of your ID, in which case we will have access to your image, name, surname, date of birth, identification number, and any other information made available on your ID, (ii) a selfie with a clearly visible image of your face, and (iii) a proof of address, where we will see your address. We will use such data to verify your account for the purpose of ensuring the security of AMBAYO and its users. The legal basis on which we rely is ’pursuing our legitimate interests’ (i.e., operate, protect, and administer AMBAYO). We will store account verification data for no longer than 30 days after the date of the verification. After the expiration of the said 30-day period, your verification data will be securely deleted. Your account verification details will NOT be stored longer than necessary, sold, shared, rented or leased to any third parties.


  Facebook Authentication (Meta Platforms, Inc.)

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

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

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

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

• Registration and authentication provided directly by AMBAYO

  By registering or authenticating, Users allow AMBAYO to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

  Direct registration (AMBAYO)

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

  Personal Data processed: email address; password; Trackers; Usage Data.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

• Remarketing and behavioral targeting

  This type of service allows AMBAYO and its partners to inform, optimize and serve advertising based on past use of AMBAYO by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.

  Analytics

  While you are browsing on AMBAYO, our analytics service provider collects and makes us available analytics data that allows us to see what kind of users access and use AMBAYO, which parts of AMBAYO you find interesting, improve our content, develop new products and services, and investigate and prevent security issues and abuse. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyse, improve, and protect our Website) and ‘your consent’ bases. The analytics data that we collect includes:
  1. Your activity on AMBAYO (time of visit, pages visited, time spent on each page, clicks, scroll depth, interaction with widgets);
  2. URL addresses from which you access AMBAYO;
  3. Your browser type and version;
  4. Your operating system;
  5. Your device details;
  6. Your IP address; and
  7. Your other online behaviour.
  

• Social features

  Social Media Widgets

  AMBAYO may include social media features, such as “Like” or “Share” buttons or other interactive mini-programs. These features may collect your IP address, which pages you are visiting on AMBAYO and the Internet, and may set a cookie to enable the feature to function properly. Social media features and widgets are provided by third-party social media providers and, therefore, your interactions with these features are governed by the privacy statement of those providers.

  Firebase Dynamic Links (Google LLC)

  Firebase Dynamic Links is a social feature provided by Google LLC. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within AMBAYO.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

• Spam and bots protection

  This type of service analyzes the traffic of AMBAYO, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.

  Google reCAPTCHA (Google LLC)

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

  In order to understand Google's use of Data, consult their partner policy and their Business Data page.

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.

• Traffic optimization and distribution

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

  Cloudflare (Cloudflare, Inc.)

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

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  jsDelivr CDN (Prospect One Sp. z o.o. sp. k.)

  jsDelivr CDN is a traffic optimization and distribution service provided by Prospect One Sp. z o.o. sp. k.

  Personal Data processed: Usage Data.

  Place of processing: Poland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• User database management

  This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to AMBAYO, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving AMBAYO. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on AMBAYO.

  MySQL

  MySQL provides third-party database management services. Therefore, the personal data that we may need to store can be stored by MySQL for the time period specified by us. Your personal data will be stored only for pre-defined purposes, as specified in other sections of this privacy policy (e.g., registering and maintaining your account, processing your orders, maintaining our business records, complying with our legal obligations, and contacting you). MySQL does not have the right to access your personal data stored by MySQL.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Cookie Policy

AMBAYO uses Trackers. To learn more, Users may consult the Cookie Policy.

Further information for Users in Switzerland

This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

The rights of Users according to the Swiss Federal Act on Data Protection

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

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

How to exercise these rights

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

Further information for Users in Brazil

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

The grounds on which we process your personal information

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

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

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

Categories of personal information processed

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

Why we process your personal information

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

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

Your Brazilian privacy rights

You have the right to:

• obtain confirmation of the existence of processing activities on your personal information;
• access to your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny your consent and the consequences thereof;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke your consent at any time;
• lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect your life or physical security or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Further information for Users in the United States

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

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use AMBAYO.

For example, you directly provide your Personal Information when you submit requests via any forms on AMBAYO. You also provide Personal Information indirectly when you navigate AMBAYO, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of AMBAYO and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
• the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
• the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
• the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
• the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota and Montana you have

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

In Minnesota Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer’s personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

• The right to question the results of the profiling;
  
• The right to be informed of the reason that the profiling resulted in the decision; if feasible
  
• The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  
• The right to review personal data used in the profiling;
  
• If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
  

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have

• The right to opt out of the processing of your Personal Information for Targeted Advertising;
• The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

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

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

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

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on AMBAYO.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

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

Additional information about Data collection and processing

Legal action

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

Additional information about User's Personal Data

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

System logs and maintenance

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

Information not contained in this policy

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

Changes to this privacy policy

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

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