BREATHLIFT PRIVACY NOTICE
Last updated: 22.10.2026
This Privacy Notice is to inform you, as a user of the BreathLift app and/or related website https://[TROCAR dominio]/ (further the “App” and the “Website” respectively, together “we/us”, the “Product”), on the processing of your personal data in connection with the use of the Product.
When we say “personal data” or “personal information”, we are referring to information related to you. Such information is not limited to what directly identifies you, such as your name. In fact, you own and have legal rights to anything that speaks of you: the data you enter about your food intake, fitness experience, your aim for using the Product, even the way you use the Product itself. To avoid legalese, we can also use “your data” or “your information” in the same meaning.
This notice is meant to provide you with all relevant information to make an informed choice to use the Product. It also serves to inform you of your rights and how you can exercise them. Contact us if you have any questions or concerns.
Please note that the Product is intended for users who have reached the minimum legal age. Therefore, we expect you will not use the Product unless you are at least 16 or older.
This Notice was written in English. to the extent a translated version of the Notice conflicts with the English version, the English version prevails.
1. Who We Are
The controller responsible for processing with regard to the Product is Editora Lar Ltda, with its registered address at Rua Waldemar Dantas, 100, Grageru, Aracaju - SE, 49025-300, Brazil.
2. Contact Us
Should you have any general questions about this Privacy Notice, the use of your data by us, or if you want to assert your data protection rights, please use the following interchangeable contact options:
if relating to your use of the App: using the form.
if relating to your use of the Website: using the form or chat directly with support at https://[TROCAR dominio]/.
Please note that in some cases, for your safety and when we have reasonable concerns about the authenticity of a request, we may need to authenticate you before proceeding with your request.
3. Your Privacy Rights and How to Exercise Them
You are entitled to data-related rights as described below. You may assert them directly via the App (to the extent possible) or via the contact options.
Please note that these rights are based on European laws, namely the General Data Protection Regulation (the “GDPR”). Depending on your country of residence, those rights may have different interpretations. Should you wish to assert your country-specific rights, kindly let us know, and we will review your case individually.
Right to access
You may ask to confirm whether we process your data and if so, to provide you with the scope of such processing and a copy of the data concerning you stored by us.
Right to rectification
You have the right to request correction of inaccurate or outdated personal data concerning you and the completion of incomplete data. We try to allow you to correct/add data through the Product’s settings to the extent possible, e.g. you can log in to your user profile and correct, amend, or delete information about yourself. We will also inform third parties to whom we transferred your data in the event of rectification of your data.
Right to erasure (Right to be forgotten)
You may request the erasure of your personal data stored by us. Please note, however, that the right to erasure is not absolute and shall be fulfilled by us only provided specific legal requirements are met. You may request data erasure only if:
your personal data is no longer necessary for the purposes for which it was initially collected,
you have withdrawn your consent to personal data processing, and the consent was the sole legal basis for the processing,
you have successfully objected to the processing based on a balancing of interests relating to your particular situation,
your personal data has been unlawfully processed,
your personal data has to be erased for compliance with a legal obligation, or
you are an underage person and used our Product by mistake.
Further, your right to erasure is subject to restrictions. For example, we are not under obligation or even allowed to delete data that we are still obligated to retain due to statutory retention periods. Similarly, data that we need for the establishment, exercise, or defense of legal claims is excluded from your right to erasure.
If we have transferred personal data to third parties, we will either initiate the deletion of your data from such third parties or inform them about the erasure, insofar as required by applicable law.
In order to avoid any unnecessary legalese and keeping in mind the general use of such words, we will interpret all user requests asking us to “delete my data” as requests for erasure of data under Article 17 GDPR.
Right to restriction of processing
You have the right to request, under certain conditions, restriction of processing (i.e. the marking of stored personal data to restrict its future use). The requirements for restriction of processing are as follows:
The accuracy of your personal data is contested, and we must verify the accuracy of your data;
The processing is unlawful but you do not want your personal data to be erased, and instead you request restriction of use of your personal data;
We no longer need your personal data for the purposes of processing, but you need the data for the establishment, exercise, or defense of legal claims;
You have objected to data processing, and we are verifying whether our legitimate interests override yours.
Right to objection
You have the right to object to the processing of your personal data in whole or in part at any time, and in any form, in the event that our processing is based on a legitimate interest (balancing of interests). In order to process your objection, we kindly request you to refer to your particular situation as to why you believe that your rights and freedoms are at a particular risk (see Article 21 of GDPR for more details).
Please note that the right to objection is not absolute, and we will stop the processing of your data only provided we cannot demonstrate compelling legitimate grounds for processing.
Where the processing you object against concerns direct marketing purposes, we will stop any processing once we receive an objection from you. A common example of how you can exercise an objection to marketing communications is pressing the “unsubscribe” button in emails.
Right to data portability
You have the right to receive the data you provided to us in a commonly used and machine-readable format to transfer that data to another controller without our interference, in accordance with the applicable laws and regulations.
To the extent possible, we will allow you to export data for further use directly via the App. You may also ask us to assist you with moving your data where it is technically feasible. Please note that this option relates only to data processed based on the performance of our contract with you or based on your consent. For more information about the contract and consent, please refer to Section 5 below.
Right to withdraw consent
If you provide consent to the processing of your personal data, you can withdraw it at any time. Consent withdrawal does not have a retroactive effect, meaning that any processing which occurred before the withdrawal shall not be affected.
Right to lodge a complaint
You can lodge a complaint with the data protection authority at any time if you believe that your data has been processed unlawfully. Here is the contact information for the Cypriot supervisory data protection authority:
Office address: kypranoros 15, Nicosia 1061 , Cyprus; Postal address P.O.Box 23378, 1682 Nicosia, Cyprus; Email: commissioner@dataprotection.gov.cy
3.1. California Privacy Rights
In this Section, you can find a description of your privacy rights as a California resident, which are established under California laws, such as the California Consumer Privacy Act (the “CCPA”).
Please note that in this Section 3.1, we describe California-specific rights that substantially differ from those established under the GDPR. These rights are in addition to those established under the GDPR described above in Section 3 for California residents.
You may assert these rights directly via the Product (to the extent possible) or via the contact options.
Access to specific information and data portability rights
Generally, your right to request data access and data portability are described above in Section 3 under the titles “Right to access” and “Right to rectification”, respectively. The scopes of these rights differ slightly under the CCPA.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months only. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you.
If we sold or disclosed your personal information for a business purpose, we will disclose such facts separately.
Please note that you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Right to request deletion of data
Generally, your right to request erasure is described above in Section 3 under the name “Right to erasure (Right to be forgotten)”.
Despite the fact that the right to request deletion of data under the CCPA and the right to erasure under the GDPR are essentially the same, please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information for certain reasons. For your convenience, you may find below an abridged version of such exceptions. To learn more, please refer to the full text of the CCPA or the additional clarifications from the California Attorney General.
Under the CCPA, we may retain your personal information if we need it to, among other things:
Complete the transaction for which the personal information was collected, or fulfill the terms of a written warranty or product recall.
Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
Comply with the California Electronic Communications Privacy Act.
Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
Comply with a legal obligation.
Otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information, etc.
Right to non-discrimination
California consumers have the right to non-discrimination in relation to the exercise of their rights under the CCPA. In particular, we cannot deny you the Product, charge you different prices for the Product, either by denying benefits or imposing penalties, provide you with a different level or quality of the Product in comparison to how we proceed with other California users, or threaten you with any of the above.
Right to request information on data transfer for third party’s direct marketing purposes
Under California’s “Shine the Light” law (Civil Code Section § 1798.83) users can request information regarding the disclosure of personal information to third parties for their direct marketing purposes.
Right to prohibit sale of information
We do not sell the personal data we collect (as defined in the CCPA) and will not sell it without providing you with the right to opt out. Please note that we share users’ personal information for our business purposes as described in Section 7 “Personal Data Transfers”.
We do not sell or share your personal information with Committed Coaches, LLC (“Committed Coaches”) - the partner whose services we might promote. We do not pass them any of your data, and the links in our marketing emails do not identify you.
3.2. Brazil Privacy Rights
In this Section, you can find a description of your privacy rights as a data subject located in Brazil, which are established under the Brazilian General Data Protection Law (the “LGPD”).
Please note that in this Section 3.2, we describe Brazil-specific rights that substantially differ from those established under the GDPR. These rights are in addition to those established under the GDPR described above in Section 3 for data subjects located in Brazil.
You may assert these rights directly via the Product (to the extent possible) or via the contact options.
Right to request anonymization/blockage/erasure
You may request the anonymization/blockage/erasure of your personal data stored by us. Please note, however, that this right is not absolute and shall be fulfilled by us only provided specific legal requirements are met. You may request them only if your personal data is unnecessary, excessive or has been unlawfully processed.
Right to obtain information about shared data
You have the right to obtain information about the entities with which we have shared your personal information.
Right to lodge a complaint
You can lodge a complaint with the Brazilian National Data Protection Authority (ANPD) at any time if you believe that your data has been processed unlawfully.
3.3 Mexico Privacy Rights
If you are located in Mexico, your personal data is processed in accordance with the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP).
For transactions in Mexico, Editora Lar Ltda, company no. 16558886, (RFC OTN250723LN1), registered office 4th Floor Office, 205 Regent Street, London W1B 4HB, acts as the local data controller for billing and tax information.
Mexican users may exercise their ARCO rights (Access, Rectification, Cancellation and Opposition) or revoke consent using the form and specifying the right they wish to exercise.
Users may also contact the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI) via https://www.inai.org.mx if they believe their data protection rights have been infringed.
4. Personal Data We Collect
Your user journey may vary depending on whether it is the App or the Website (or both) you have chosen to use. Similarly, the scope and peculiarities of data processing will vary:
if you access the Product through the Website, both Website Data Collection and App Data Collection will apply;
if you access the Website only, Website Data Collection will apply;
if you accessed the App via an application store, only App Data Collection will apply.
Data you provide
Data Category | Website Data Collection | App Data Collection |
|---|---|---|
General Information | When you start using the Website, or in the course of Website use, we collect the following personal data: - Name, - Email address, - Birth year or age (inferred based on the birth year), - Country of residence, - Sex. We also use your email address to send you marketing emails, including offers from selected partners. You can unsubscribe at any time (see Section 5). | When you start using the App, or in the course of App use, we collect the following personal data: - Name, - Email address, - Birth year, age (inferred based on the birth year), - Country of residence, - Sex. If you accessed the App from the Website, we may use the information already collected on the Website for the App. We also use your email address to send you marketing emails, including offers from selected partners. You can unsubscribe at any time (see Section 5). |
Fitness & Wellness Onboarding Information
| To tailor your Product experience to your needs, we may ask you to answer some questions about your fitness and wellness experience. Such Fitness & Wellness Onboarding Information may include your height and weight, target weight and body type and target zones, fitness level, sleep information, well-being details, etc. If you do not provide us with Fitness & Wellness Onboarding Information, we will not be able to create a personalized fitness experience for you. | |
Payment Data | To make a purchase via the Website, you need to enter your payment information, such as bank card credentials, payment service (e.g. PayPal) credentials, etc. We may or may not have access to such payment information depending on the service provider processing your payment. Payment gateways, such as PayPal, Stripe, and Braintree, act independently; we receive limited information from them allowing us to recognize and record your subscription status, such as the date, time, and amount of the transaction, the type of payment method used, the payment transaction identification number, and the last four digits of the bank card. Our one-stop shop payment provider acts on our behalf; it collects and otherwise processes your payment data, including bank card credentials, IP address, email, and name, on our behalf. In practice, it shares with us only limited details regarding your payment, such as the date, time, and amount of the transaction, so our employees/contractors cannot view your payment credentials. | N/A |
Customer Support and Other Communications Information | When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of the Product, additional contact information, payment information, identification documents, or other information you may find helpful to resolve your query. We also collect information on the feedback you provide on the customer support experience. | |
Your User Choices | We collect: - information about your Website settings, privacy settings, and - records about when you accepted our Terms of Use, Privacy Notice, Refund Policy, and/or provided consent to marketing communications; - information on whether you have enabled web browser notifications. | We collect: - information about your in-App settings, privacy settings, and - records about when you accepted our Terms of Use, Privacy Notice, Subscriptions Policy, and/or provided consent to the processing of your data or to marketing communications; - information about whether you have enabled push notifications. |
Feedback Information
| We will collect and process your feedback should you communicate it to us. | Our App contains a feature via which you can provide us with feedback, rate our application, and/or engage in deeper discussions. We will collect and analyze the data you submit to make our Product better. We will also collect and process feedback should you communicate it to us in any other way. |
Automatically collected data
Data Category | Website Data Collection | App Data Collection |
|---|---|---|
Usage Information | We collect information about your activity on our Website, like frequency of use, areas and features that you access, visit, or use, and engagement with particular features. | We collect information about your activity on our App, such as: - Product interaction, e.g. frequency of use, areas and features that you access, visit, or use, and engagement with particular features. - In-App fitness activities, like performed/active workouts, workout choices, etc. - Access to external groups/communities created by the App for additional communications, feedback collection. |
Device-Related Information | When you install, access, or use the Website, we collect device-related information. This includes IP address, user agent, hardware model, operating system information, browser information, language and time zone, etc. Device-related information also includes approximate location information. | When you install, access, or use the App, we collect device-related information. This includes IP address, user agent, hardware model, operating system information, App version, browser information, mobile network, language and time zone, device identifiers, including Android Advertising Identifier (GAID)/Apple ID for Advertisers (IDFA), etc. Device-related information also includes approximate location information. |
Subscription Status | N/A | By exchanging information with your application store, we understand and record your subscription status. |
Log and Troubleshooting Information | We collect some troubleshooting, bug, and crash reporting information from you to help determine problems with the Product. We also collect and write logs to be able to access historical data for internal and external investigations. | |
Marketing Email Engagement | When you receive our marketing emails, our email platforms record whether you open them, which links you click and whether you unsubscribe. We use this to measure our campaigns, choose which offers to show you and avoid sending you messages you do not want. | When you receive our marketing emails, our email platforms record whether you open them, which links you click and whether you unsubscribe. We use this to measure our campaigns, choose which offers to show you and avoid sending you messages you do not want. |
Information third parties provide about you
Data Category | Website Data Collection | App Data Collection |
|---|---|---|
Advertising Network Information | Advertising networks provide us with insights on which channels (e.g. social networks) and which particular ad campaigns helped you reach the Product. | |
Partner Booking and Purchase Information | If you book with a partner whose services we promote (for example, Committed Coaches), the partner may tell us whether you started or completed a booking, made a purchase (including its value), cancelled it or asked not to be contacted, and when. The partner might identify you to us by the email address you gave it when booking. We never receive the content of your sessions or anything else you share with the partner. | |
Cookies and Similar Technologies
On the Website, we also use cookies and other tracking technologies for various purposes. Please refer to Section 6 for more information on cookies and similar technologies.
On-device Data Collection
There may be other features for which data is stored and processed locally on your device, and we do not have any access to that information. This may be true for the Omo food recognition feature [subject to availability].
5. How and Why We Use Your Data. Legal Bases for Processing
All processing of your data must be lawful, i.e. reliant upon one of the lawful bases referenced under applicable law, namely:
Performance of a contract with you, i.e. provision of the Product as described in our Terms of Use,
Your consent, i.e. when you provide consent to the processing of particular personal information,
Our legitimate interests, i.e. when we believe that we can use and/or share your data since we have a legitimate balanced reason to do so,
Performance of our obligations under the applicable law.
Below you can see described the purposes of our processing (why we process your information) for each lawful basis and the corresponding data categories used in each case.
As mentioned earlier, your user journey may vary depending on whether it is the App or the Website (or both) you have chosen to use. However, the purposes and legal bases for data processing in relation to the Website and the App coincide.
Performance of a contract with you
Why and how we process your information | Data Used |
|---|---|
To ensure the intended operation of the Product, namely, to maintain your profile in the Product, ensure you have easy access to it, and provide you with the functionality of the Product provided for in the Product descriptions as well as included materials. For example, we use your data to create fitness plans best suited for you.
| |
For billing purposes, account management, and feature accessibility. |
Please note that provision of the information above is necessary for us to provide our Product to you (perform our contract with you). We will not be able to provide the Product without the information listed above. We will also not be able to continue providing the Product if you request data erasure or otherwise restrict our access to such data.
Our legitimate interest
Why and how we process your information | Substantiation of Legitimate Interest | Data used |
|---|---|---|
To analyze the performance of our Product, improve it, and further deliver a better user experience based on analysis of your interaction with the Product. For example: - We count users and events for reporting to identify how many users the Product has. This includes metrics like how many unique users the Product has. - We analyze bugs and fix issues with the Product. | Our interest is to measure the use of our Product and count the people who interact with it. Such actions are aimed at improving Product development and enabling the provision of accurate and reliable internal reporting. | Log and Troubleshooting Information Payment Data (the fact of purchase)/Subscription Status |
To assess the effectiveness of our advertising campaigns by understanding which advertisements led you to the Product and whether you finally used the Product or purchased it/some of its features. | It is our interest to understand who may be interested in our Product and to offer our Product to new potentially interested audiences as well as remind old users about it. | General Information (in a limited scope) Payment Data (the fact of purchase)/Subscription Status |
To communicate with you in various ways, e.g.: - to send you technical notices, updates, and security alerts; - to send reminders to your smartphone or web browser via in-App messages and in-App and web push notifications; - to send promotional communications, such as product updates, offers, discounts, and to provide news and information that we think will be of interest to you. You can unsubscribe from our promotional communications at any time – see “Marketing emails and partner offers” at the end of this Section 5. | We believe the provision of presumably relevant information will be a plus in addition to the provision of the Product functionality. | |
To tell you about selected partner offers. Our marketing emails may also promote services of our commercial partners, such as Committed Coaches, including offers, follow-ups and reminders to finish a booking you have started. We send these emails ourselves and, where the law requires, only with your prior consent. We also use the booking and purchase information partners send us to stop follow-ups you no longer need, calculate the commission we earn and measure our campaigns.
| It is in our interest to offer you partner services that complement our Product, to earn revenue from these partnerships and to avoid sending you unnecessary messages. | General Information (email address, name, country) Your User Choices (marketing preferences) Usage Information Marketing Email Engagement Partner Booking and Purchase Information
|
To provide customer support/ request processing to the customer support team. This includes, for example: - responding when you request our help such as assisting with your account login or verification process; - addressing your comments and questions. | It is in our interest to assist our users with any inquiries or requests. | |
To defend ourselves from prospective legal claims, litigation, or other disputes, including in relation to violations of the Terms of Use, Privacy Notice, Subscription Policy, and/or Refund Policy. To ensure the safety, security, and integrity of the Product. To provide information to the authorities upon request. | It is in our interest to respond to complaints and prevent and address fraud, unauthorized use of the Product, violations of our Terms of Use and/or other policies, or other harmful or illegal activity. It is in our interest to seek legal advice and protect ourselves (including our rights, personnel, property, or products), and our users or others, including as part of investigations or regulatory inquiries and litigation or other disputes. | |
To identify disruptions and maintain Product security, including the detection and tracking of inadmissible access attempts and access to our servers. | It is in our interest to eliminate disruptions, maintain system security, and detect and track inadmissible access and access attempts. |
Performance of our obligations under the law
Why and how we process your information | Data used |
|---|---|
According to applicable tax and accounting laws, we may need to report your payments to conduct any necessary statutory reports/withdrawals. Further, sometimes in order to comply with applicable laws, we need to authenticate you, i.e. collect your identification information. Finally, according to applicable law, we need to understand whether you allow the processing of your data, push notifications, marketing communications, and similar activities. To provide information to authorities upon request. |
Automated processing of your data
We do not use your data to make decisions based solely on automated processing that would create legal or comparably significant effects.
Marketing emails and partner offers
Our marketing emails may feature selected services of our commercial partners, such as Committed Coaches. In short:
We send them, and share nothing. Partner offers come from us, through our own email platforms. We do not give partners your contact details or any other information about you, and our links tell them only that you came from our email.
Booking pages belong to the partner. Our emails may link to a partner’s website, and our Product may display a partner’s booking page. Either way, what you enter there goes directly to the partner, not to us, and is handled under the partner’s own privacy policy.
The partner tells us what happened next. The partner may tell us whether you started or completed a booking, made a purchase (and its value), cancelled, or asked not to be contacted – and when. It my identify you by the email address you used when booking. We might use this to stop follow-ups you no longer need, calculate our commission and measure our campaigns.
We may earn a commission when you buy a partner’s services through our emails. This does not change the price you pay.
You stay in control. You can unsubscribe at any time using the link in any of our marketing emails or by contacting us (see Section 2). This stops all our marketing emails, including partner offers; you will still receive essential service messages, such as payment receipts. Once you have booked, messages about your sessions come from the partner, and you can unsubscribe from them using the partner’s own link.
6. Cookies and Similar Technologies, Your Choices
Cookies (“Cookies” or “Cookie”) are small text files that are placed on your device while you browse our Website. They help us remember/recognize some of your actions or choices during Website use for various purposes. Sometimes, they help us track you through websites and devices to understand the effectiveness of our ads.
We use similar technologies (“Similar Technologies”) which are technically different but serve the same purpose of remembering/recognizing your actions during App or Website use. Similar Technologies include:
Pixels/Web beacons/Tags - code snippets added to our Website, for example, to create a tiny graphic. We usually use pixels that are dependent on cookies so your Cookie choices may limit the performance of pixels.
Local storage - a property that allows us to save information in your web browser with no expiration date (even after the browser window is closed).
Who sets Cookies or Similar Technologies on our Website
There are two main types of Cookies and Similar Technologies that we can set:
First-party Cookies and Similar Technologies: these Cookies and Similar Technologies are placed and read by us directly;
Third-party Cookies: these Cookies are not set by us, but by our partners, like payment service providers (e.g., PayPal or Braintree) or advertising networks.
We recommend checking Section 7 of this Privacy Notice to understand with whom we cooperate while using Cookies and Similar Technologies.
Why and how we use Cookies and Similar Technologies
We use Cookies and Similar Technologies for a number of reasons, such as:
protecting your account,
saving your onboarding experience so that you can return to exactly where you left off,
analyzing Website performance,
advertising our Products,
assessing advertising campaign effectiveness, and
generally trying to make your experience with us better.
The Cookies and Similar Technologies we use generally fall into one of the following categories, whereas each category description allows us to understand why those Cookies and Similar Technologies are necessary.
Strictly Necessary Cookies and Similar Technologies
These Cookies and Similar Technologies are necessary for the Website to function and cannot be switched off in our systems.
They are set out in response to actions you make, mainly in order to remember your choices, including cookie preferences, onboarding completion status and values, and login data.
If you block strictly necessary Cookies, some parts of the Website will not work.
Strictly Necessary Cookies list
Cookie | Purpose | Domain | Type | Duration |
|---|---|---|---|---|
OptanonAlertBoxClosed | This Cookie is set by the Cookie compliance solution from OneTrust. It allows for the remembering of your Cookie preferences. | First-party | 365 days | |
OptanonConsent | This Cookie is set by the Cookie compliance solution from OneTrust. It stores information about the categories of Cookies the site uses and whether the user has given or withdrawn consent for the use of each category. | First-party | 365 days | |
sc_f | This Cookie is set via the PayPal payment widget which is embedded on the checkout page on our Website. | .c.paypal.com | Third-party | 1825 days |
ts_c | This Cookie is set via PayPal payment widget to prevent fraud. | .c.paypal.com | Third-party | 3 years |
l7_az | This Cookie is necessary for the PayPal login function on the website. | .c.paypal.com | Third-party | 20 days |
LANG | This Cookie is set by PayPal to save language preferences. | .c.paypal.com | Third-party | 365 days |
ts | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | 3 years |
KHcl0EuY7AKSMgfvHl7J5E7hPtK | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | 20 years |
tsrce | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | 3 days |
x-pp-s | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | Session (deleted once browser closed) |
_cf_bm | This Cloudflare cookie helps manage incoming traffic that matches criteria associated with bots for the FAQ service. | /legal/contact-us | First-party | 30 minutes |
_cfruid | Cloudflare cookie used in cases where multiple users are hidden behind the same client IP address by FAQ service. | /legal/contact-us | First-party | Session (deleted once browser closed) |
_zendesk_session | Stores FAQ service account ID, route for internal service calls and the cross-site request forgery token. | /legal/contact-us | First-party | 8 hours |
zendesk_thirdparty_test | Used during sign in on hostmapped accounts for cookie-restricted browsers by FAQ service. | /legal/contact-us | First-party | 8 hours |
_zendesk_shared_session | Authentication cookie - set to be anonymous. | /legal/contact-us | First-party | 8 hours |
_zendesk_authenticated | A flag set by FAQ service when a user is authenticated to display the most up to date content. | /legal/contact-us | First-party | Session (deleted once browser closed) |
cf_chl_prog | Used by Cloudflare for the execution of Javascript or Captcha challenges. These cookies are not used for tracking or beyond the scope of the challenge. Necessary for FAQ service. | /legal/contact-us | First-party | The storage duration is dependent on your browser policy |
cf_clearance | Cookie is to ensure that Captcha or Javascript challenges are no longer issued if the challenge has already been passed. Necessary for FAQ service. | /legal/contact-us | First-party | The storage duration is dependent on your browser policy |
cf_chl_2 | Used by Cloudflare for the execution of Javascript or Captcha challenges. These cookies are not used for tracking or beyond the scope of the challenge. Necessary for FAQ service. | /legal/contact-us | First-party | The storage duration is dependent on your browser policy |
articleVotes | This is only dropped when anonymous end-users actually vote on articles for FAQ service. | /legal/contact-us | First-party | Forever (Local Storage)/Session (cookie) |
_help_center_session | Stores unique session key for FAQ service | /legal/contact-us | First-party | Session (deleted once browser closed) |
Performance (Analytics) Cookies
These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us know which pages are the most and least popular and see how the user moves across the Website.
Performance (Analytics) Cookies list
Cookie | Purpose | Domain | Type | Duration |
|---|---|---|---|---|
_ga | Google Analytics Cookie used to identify unique users. | First-party | 2 years | |
_gid | Used by Google Analytics to distinguish users. | First-party | 90 days | |
help_center_data | Stores the text string of your search term in the FAQ service. It stores this so that it can check whether a ticket was created | /legal/contact-us | First-party | 48 hours |
_zdshared_user_session_analytics | Used to track information about visits for analytics purposes. | /legal/contact-us | First-party | 365 days |
Functional (Preference) Cookies
Preference Cookies are used to remember your preferences and to recognize you when you return to our Product.
If you do not allow these Cookies then some or all of the below services may not function properly.
Functional (Preference) Cookies list
Cookie | Purpose | Domain | Type | Duration |
|---|---|---|---|---|
GUIDE_REQUESTS_APP_COLUMN_CONFIG | This cookie saves the settings that you choose when configure own view in the Request List App in course of FAQ use. | /legal/contact-us |
| The storage duration is dependent on your browser policy |
Targeting (Tracking) Cookies and Similar Technologies
We and our service providers (advertising networks) use Cookies and Similar Technologies to direct our ads to you through targeted advertisements for our Product on other sites you visit and to measure your engagement with those ads.
These Cookies and Similar Technologies may be used by those advertising networks to build a profile of your interests and show you relevant ads on other sites.
Targeting (Tracking) Cookies list
Cookie | Purpose | Domain | Type | Duration |
|---|---|---|---|---|
_pinterest_ct_ | Cookie placed by Pinterest when it is unable to match the user. | .ct.pinterest.com | Third-party | 365 days |
_pin_unauth | Cookie placed by the Pinterest tag when Pinterest is unable to match the user. | First-party | 364 Days | |
_scid | Snapchat Cookie that sets a unique ID for the Website user. | First-party | 365 days | |
X-AB | This Cookie is used by us along with Snapchat in the context of multi-variable testing. | sc-static.net | Third-party | 1 day |
_fbp | Used by Facebook to deliver a series of advertisement products such as real-time bidding from third-party advertisers. | First-party | 3 month | |
_gat_gtag_xxxxxxxxxxxxxxxxxxxxxxxxxxx | Used by Google Analytics to store a unique user ID. | First-party | <24 hours | |
_tt_enable_cookie, _ttp | TikTok Cookies that collect data about behavior and purchases on our Website to measure the effect of our advertising. | First-party | 13 month | |
_ttp | TikTok uses this Cookie to measure and improve the performance of our advertising campaigns and to personalize the user's experience (including ads) on TikTok. | .tiktok.com | Third-party | 13 month |
sc_at | Used by Snapchat to identify a visitor across multiple domains. | snapchat.com | Third-party | 1 hear |
muc_ads | Twitter Cookie that сollects data on user behavior and interaction in order to make advertisements on the website more relevant. | .t.co | Third-party | 2 years |
personalization_id | This Cookie is set by Twitter for advertising and to identify and track the website visitor. | .twitter.com | Third-party | 2 years |
Your Cookie choices
Most browsers allow you to manage how Cookies are set and used as you’re browsing, and to clear Cookies and browsing data. Typically, such information can be found under the browser’s ‘Help’, ‘Preferences’, or ‘Options’ menus. Also, your browser may have settings allowing you to manage Cookies on a site-by-site basis as well as provide for incognito mode.
Should you wish to change your previously provided to us Cookie-related choices, please click the links below to take immediate effect:
reset cookie settings (you can configure your choices via the cookie banner upon your next visit).
Your Similar Technologies choices
Most mobile devices and applications allow you to manage how other technologies, such as unique identifiers used to identify a browser, app, or device, are set and used. For example, the Advertising ID on Android devices or Apple’s Advertising Identifier can be managed in your device’s settings, while app-specific identifiers may typically be managed in the app’s settings.
Opt out of Personalized Advertising
You can visit the below sites to opt out of personalized advertising in general, including regarding our Website:
Digital Advertising Alliance (DAA);
You can also opt out of advertising provided by particular networks both in the App and on the Website:
Outbrain opt out on desktop and mobile web (Section 3 -> Outbrain User Types, including Opt Out Options)
Please note that if you opt out of personalized advertising, you will still see advertisements – they will just not be tailored to your interests. Also note that deleting browser Cookies may remove the Cookie preferences you already made, so you may need to opt out again in the future.
Finally, you can exercise your preferences and opt out of personalized advertisements with regard to your mobile devices (smartphones, tablets) by:
updating your mobile device settings:
IOS devices: Settings -> Privacy -> Tracking -> Allow Apps to Request to Track (uncheck);
Android Devices -> Settings -> Google -> Ads -> Opt Out of Ads Personalization;
downloading the Digital Advertising Alliance’s AppChoices app and configuring it to opt out of particular advertising solutions.
Do Not Track
"Do Not Track" is a preference you can set in your web browser to let the websites you visit know that you do not want them collecting information about you. The Website does not currently respond to a "Do Not Track" or similar signal.
7. Personal Data Transfers
7.1. Data Transfers by Both the Website and the App
As we mentioned earlier, this Privacy Notice is aimed at describing data use in relation to the Product. Below, we explain with whom we share your personal data from the Product, i.e. both the Website and the App.
Third-party service providers
A number of Product functions rely upon services from third parties, so-called ‘processors’. Processors act based on and in accordance with our requests and shall not use your data for their own purposes.
The main service providers the Product shares your data with are as follows:
Amazon Web Services (Amazon Web Services EMEA SARL, 352 2789 0057, 38 Avenue John F. Kennedy, L-1855, Luxembourg)
We use Amazon Web Services, which is a hosting and backend service provided by Amazon, for personal data hosting and enabling our Product to operate and be distributed to its users.
AppsFlyer (AppsFlyer Ltd., 14 Maskit Str., Floor 6 POB 12371, Herzliya 46733149, Israel)
Appsflyer helps us understand, in particular, how users find our Product (for example, which advertiser delivered an ad that led you to our Product). Appsflyer also provides us with different analytics tools that enable us to research, analyze, and make your use of the Product better.
Amplitude (Amplitude Inc., 201 3rd Street, Suite 200, San Francisco, CA 94103)
We use Amplitude for analytics and customer support purposes, specifically to understand how customers use our App. As for analytics purposes, Amplitude provides us with different tools that enable us to research and analyze Your use of the Service, which helps us to decide what features we should focus on more. For customer support purposes, Amplitude helps us to respond to Your requests for technical support. For example, it allows us to track Your interaction with our App and in order to detect particular technical issues with the App.
Google Analytics / Google Analytics for Firebase (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland)
Google Analytics / Google Analytics for Firebase are product analytics tools provided by Google, which help us to analyze the Service data and understand our users to optimize the Service performance.
SendPulse (SendPulse Inc., 220 E 23rd St
We may transfer, among other information, your email address, phone number, device information, payment status, and subscription date to SendPulse in order to deliver customized emails, and web push notifications.
Reteno (Retention Yes Sp. Z.O.O., 02-972, Poland, voivodeship Mazovetsky, Warsaw city, Adama Branickiego Street, No. 21)
We may transfer, among other information, your email address, phone number, device information, payment status, and subscription date to Reteno in order to deliver customized emails, web push notifications and other communications.
SendPulse and Reteno may also help us send our marketing emails, including partner offers, and store your marketing preferences, email engagement and the booking and purchase information partners send us (see Section 4). They act only on our instructions.
Front (FrontApp, Inc., 1455 Market Street, 19th Floor, San Francisco, CA 94103)
In order to provide you with swift and smooth customer support, we use Front - software that allows us to optimize conversations between users and customer support agents. In this regard, Front receives and stores copies of all data related to your customer support requests, such as emails, purchase details, feedback, etc.
Customer support agents
People and companies providing us with professional app development and maintenance services
Partners
Our independent coaching partner - Committed Coaches, LLC (10195 SE Terra Linda Ct, Happy Valley, OR 97086, USA)
We do not share any of your personal data with Committed Coaches. We only promote its coaching services in our marketing emails and may earn a commission when you buy them (see “Marketing emails and partner offers” in Section 5). We may promote other partners in the same way.
Our Product may also display Committed Coaches’ booking page, embedded directly from its website. This page is owned and run by Committed Coaches: anything you enter there goes straight to Committed Coaches, not to us, and is handled under its own privacy policy. As an independent company, Committed Coaches decides how it uses that data, including for any coaching services you buy. It may tell us about your bookings and purchases, as described in Section 5.
Advertising networks
We use the services of third-party advertising platforms, for example, Instagram, Facebook, and Snapchat, which allows us to show targeted campaigns and messages to users within their platforms based on the user’s behaviour. To put it plainly, we provide information about you that will allow advertising platforms to locate you in their database and information that you performed a desirable action, such as making a purchase.
This allows an advertising network to understand which people are interested in our Product as well as to display advertisements of the Product to users who will most likely want it.
Please note that most advertising networks act as separate controllers or co-controllers of your data in full or in part, which means that such controllers decide whether to use the transferred data for their own purposes, e.g. providing you with advertisements of other providers similar to our Product. You can learn more about the data processing practices of such companies in their respective privacy policies:
We do not share any health & wellness information with advertising networks.
Should you wish to opt out of personalized advertising, please explore the options described in Section 6 above.
Related companies
We share your information with our affiliates, i.e. companies which are related to Editora Lar Ltda and/or Editora Lar Ltda, by having the same owner, for example. Where such sharing takes place, related companies will honor this Privacy Notice.
Public authorities and bodies
We may use and disclose personal data to enforce our Terms of Use to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by applicable law.
International data transfers
Please note that in the course of doing business, we transfer your personal data outside of EU/EEA countries (if you are located outside of EU/EEA countries, we may transfer your personal data to other jurisdictions). For example, some of our service providers are located in the United States of America.
We shall implement measures as established under applicable law to ensure data transfers are protected as required. When a recipient is located in one of the jurisdictions listed on the official website of the European Commission here, the appropriate safeguard is the corresponding adequacy decision of the Commission. Where no such adequacy decision is present, we rely on the so-called Standard Contractual Clauses (see more about them here), along with a thorough analysis of the law of the destination country to safeguard your data and your rights. Where we transfer your personal data out of the United Kingdom, we rely on the UK adequacy regulations for the destination country or, where none applies, on the Standard Contractual Clauses as amended and supplemented by the UK International Data Transfer Addendum. Where we disclose the personal data of users in Australia or New Zealand to a recipient overseas, we take the steps required of us by the Australian Privacy Principles or by the New Zealand information privacy principles, as applicable, including entering into contractual safeguards that require the recipient to protect your data to a standard comparable to the one that applies to us.
7.2. Website-Specific Data Transfers
In addition to the above, the Website may share your data as described below.
Merchants of Record and Agents
While Editora Lar Ltda is the data controller responsible for your data during your use of the Product, it's important to note that in some locations we engage our authorized third-party merchants of record or agents to distribute a Product via a Website. This is done to make the Product available to customers worldwide smoothly and seamlessly.
Below is a list of our authorized merchants of record and agents and their roles with regard to your data:
Editora Lar Ltda Technologies Ltd (4th Floor Office, 205 Regent Street, London, England, W1B 4HB), Editora Lar Ltda (registered office 4th Floor Office, 205 Regent Street, London W1B 4HB)
Editora Lar Ltda Technologies Ltd, as well as its affiliates, such as Editora Lar Ltda resell the Website for us in particular countries, meaning they enter into a contract and accept payments, for a part of our users. Where Editora Lar Ltda is a party to the contract, for payment data, Editora Lar Ltda will bear sole responsibility for handling your data and will be acting as a controller within the meaning of data protection law. For more information on how Editora Lar Ltda handles your data, please refer to their privacy policy at #.
Editora Lar Ltda (Detached Retail I5, Jumeirah Lakes Towers, Dubai, United Arab Emirates)
Editora Lar Ltda resells the Product via a Website for us in particular countries, meaning they enter into a contract and accept payments, for a part of our users. Editora Lar Ltda is a separate entity bearing individual responsibility for handling your data and acting as a controller within the meaning of data protection law.
Editora Lar Ltda (Rua Waldemar Dantas, 100, Grageru, Aracaju - SE, 49025-300, Brazil)
Editora Lar Ltda is one of our agents acting exclusively on our behalf to present the Website to you and accept payments. Editora Lar Ltda is a data processor acting upon our instructions.
Editora Lar Ltda (103 Foulk Road, Suite 202, Wilmington, Delaware, 19803)
Editora Lar Ltda resells the Product via a Website for us in particular countries, meaning they enter into a contract and accept payments, for a part of our users. Editora Lar Ltda is a separate entity bearing individual responsibility for handling your data and acting as a controller within the meaning of data protection law.
Payment solutions
We cooperate with a number of payment service providers to help us to receive payments via our Website. In particular, we cooperate with:
a one-stop payment processing platform Solidgate (Solidgate Tech Limited, 5-9 Main Street, Gibraltar, GX11 1AA), which acts on our behalf,
payment gateways, such as PayPal and Braintree, which act independently meaning that they are responsible for privacy-related questions with regard to their use;
Apple Pay, Google Pay, which also act independently meaning that they are responsible for privacy-related questions with regard to their use;
a number of banks.
Third-party service providers
Hotjar (Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta)
Hotjar makes it easier to find points for improvement on our Website, understand our users' needs and to optimize their experience. We can analyse how much time you spend on which pages, which links you’ve chosen to click, what features you liked the most, etc.
OneTrust (OneTrust, 1200 Abernathy Road, Atlanta, Georgia 30328, United States)
We engage OneTrust to ask for and manage your Cookie consent as required by different local regulations. OneTrust collects your country-level location to show you an appropriate cookie consent banner and places some Cookies to save and remember your choice and to aggregate some statistics on users' Cookie-related choices.
Zendesk (Zendesk, 989 Market st, San Francisco, CA 94103)
We engage Zendesk to make our FAQ self-service available to you in App and on Website.
Sentry (Functional Software, Inc. 45 Fremont Street, 8th Floor, San Francisco, CA 94105)
Sentry is a code analysis tool, which allows us to log software mistakes, monitor the software performance of a code, and analyse code vulnerabilities. While performing its functions, Sentry may access a limited number of your data, such as IP address, browser information, OS version, and device type.
7.3. App-Specific Data Transfers
Finally, on top of what has been described for both the Website and the App, the App itself shares data as follows.
Third-party service providers
Firebase Crashlytics (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland)
Firebase Crashlytics is a Google Firebase service that allows us to track application performance, i.e. we can discover the causes and severity of crashes in the Product.
Firebase Remote Config (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland)
Firebase Remote Config allows us to introduce changes to the App’s behaviour and appearance on the fly.
8. Retention of Your Personal Data
We keep your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Notice, unless further retention is required under applicable law. Once your data is no longer needed, we delete it in accordance with our internal data retention schedule. Whenever all or some of your personal data is scheduled for deletion under our internal data retention schedule, we will inform you in advance, for example, by email. Where the deletion has been scheduled because you have been inactive for some time, you can keep your data by logging into your account and continuing to use the Product before the deletion date indicated in our notice. Once deleted, the data cannot be restored. In all cases, we notify you in advance before any scheduled deletion takes place.
You can request to terminate your account and delete your data at any time. We treat such requests as a termination of your contract with us and as a revocation of your consent(s). We will accommodate such requests and terminate any data processing under respective legal bases.
Marketing data. We use your email address for marketing until you unsubscribe, ask us to delete your data or close your account. If you unsubscribe, we keep a record of it so that we do not email you again by mistake. We keep email engagement data and the booking and purchase information partners send us for as long as needed to run our campaigns and settle commission with our partners, unless the law requires us to keep it longer (for example, for accounting).
Please note that certain data can be retained even after your deletion request. That may be the case where processing is based upon our legitimate interest. For example, we may keep information on purchases in order to protect our rights in a legal action. Such storage is not indefinite and is limited to such data's usefulness and achieving our legitimate goals. As described in the Your Privacy Rights and How to Exercise Them section, you may object to our legitimate interests. If you wish to do so, please indicate this specifically in your message to us.
We may also keep data if deletion is not technically possible (for example, because your personal information has been stored in backup archives). We will securely store your personal information and isolate it from any further processing until deletion is possible.
The same applies to cases where we are obliged to retain your data under applicable law (e.g. accounting and tax laws). In the event of such retention, we will ensure via technical and organizational means that such data is not used for conflicting purposes, for example, advertising to you.
9. Changes to this Privacy Notice
We may change this Privacy Notice from time to time by posting those changes directly on this webpage. Please make sure to review this Privacy Notice regularly. Should the change be major, we will try our best to draw your attention to it, e.g. via a pop-up or email. By continuing to use our Product, you acknowledge you have read and understood the most up-to-date Privacy Notice.