Updated 5/12/2022
This Application collects some Personal Data from its Users.
Chooly, LLC. Email: contact@chooly.app
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; various types of Data.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this
privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data
may be freely provided by the User, or, in case of Usage Data, collected automatically when using this
Application.
Unless specified otherwise, all Data requested by this Application is mandatory and
failure to provide this Data may make it impossible for this Application to provide its services. In cases
where this Application specifically states that some Data is not mandatory, Users are free not to
communicate this Data without consequences to the availability or the functioning of the Service.
Users
who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of
Cookies – or of other tracking tools – by this Application or by the owners of third-party services used
by this Application serves the purpose of providing the Service required by the User, in addition to any
other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
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 this Application (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.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
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.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the
European Union or to any international organization governed by public international law or set up by two
or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their
Data.
If any such transfer takes place, Users can find out more by checking the relevant sections
of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent
to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to
retain Personal Data for a longer period whenever required to do so for the performance of a legal
obligation or upon order of an authority.
Once the retention period expires, Personal Data shall
be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right
to data portability cannot be enforced after expiration of the retention period.
The 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: Analytics, Contacting the User, Displaying content from external platforms, Content performance and features testing (A/B testing), Hosting and backend infrastructure, Remarketing and behavioral targeting, Social features, Managing contacts and sending messages, Handling payments, Access to third-party accounts, Location processing and Interaction with support and feedback platforms.
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”.
Personal Data is collected for the following purposes and using the following services:
This data is to allow Owner provide aggregated data for User's financial situation. These services are not activated automatically, but require explicit authorization by the User.
Plaid is an industry leading service to connect to banks and other financial institution.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Plaid's Privacy Policy.
This type of service allows this Application 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.
This service allows this Application to connect with the User's account on Google Drive, provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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 is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data
collected to track and examine the use of this Application, to prepare reports on its activities and share
them with other Google services.
Google may use the Data collected to contextualize and personalize
the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that connects data from the Google Ads advertising network with actions performed on this Application.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: email address; first name; last name.
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name.
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 this Application.
Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
This type of services allows you to view content hosted on external platforms directly from the pages of
this Application and interact with them.
This type of service might still collect web traffic data for
the pages where the service is installed, even when Users do not use it.
Unless otherwise specified, this Application 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. This Application 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.
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
This type of services has the purpose of hosting data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google Firebase and Google Cloud Platform are hosting and backend 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
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.
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data processed: email address.
Place of processing: US – Privacy Policy.
This type of service allows this Application and its partners to inform, optimize and serve advertising
based on past use of this Application 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.
In addition to any opt-out feature provided by any of the services below, Users may opt
out by visiting the Network Advertising Initiative
opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed: various types of Data.
This Application may send push notifications to the User.
Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
The Personal Data collected are used to provide the User with services or to sell goods, including
payment and possible delivery.
The Personal Data collected to complete the payment may include the
credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of
Data collected by this Application depends on the payment system used.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
This Application uses Trackers.
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to
possible legal action arising from improper use of this Application or the related Services.
The User
declares to be aware that the Owner may be required to reveal personal data upon request of public
authorities.
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
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.
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party
services it uses honor the “Do Not Track” requests, please read their privacy policies.
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on
this page and possibly within this Application and/or - as far as technically and legally feasible -
sending a notice to Users via any contact information available to the Owner. It is strongly recommended
to check this page often, referring to the date of the last modification listed at the bottom.
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.
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies are Trackers consisting of small sets of data stored in the User's browser.
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.