Privacy Policy

This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.

Owner and Data Controller

Legal Representative: M. Ashley Lacour
Phone: +590 590 29 88 90
Email: [email protected]
Website: sibarth.com

Types of Data Collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

• Trackers
• Usage Data
• First name
• Last name
• Address
• Contact details
• Email address
• Phone number
• Number of Users
• Session statistics

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

Mode and Place of Processing the Data

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational 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.

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

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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:

• Traffic optimisation and distribution
• Tag management
• Analytics
• Advertising
• Remarketing
• Managing contacts and sending messages

Detailed Information on the Processing of Personal Data

Traffic Optimisation and Distribution

This type of service allows this Application to distribute their content using servers located across different countries and to optimise 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 this Application 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.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

Analytics

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

Advertising

This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, 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 this Application. 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.

Remarketing

This type of service allows User Data to be utilised for remarketing and retargeting purposes. These communications are displayed in the form of targeted advertisements on other websites and applications across the internet, based on the User’s previous interactions with our Application.

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.

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

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

Further Information for Users in the European Union

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes
• Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof
• Processing is necessary for compliance with a legal obligation to which the Owner is subject
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party

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.

Further Information About Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner
• 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 fulfil a legal obligation or upon order of an authority

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of 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 Rights of Users Based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time: Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data
• Object to processing of their Data: Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent
• Access their Data: Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing
• Verify and seek rectification: Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected
• Restrict the processing of their Data: Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it
• Have their Personal Data deleted or otherwise removed: Users have the right to obtain the erasure of their Data from the Owner
• Receive their Data and have it transferred to another controller: Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance
• Lodge a complaint: Users have the right to bring a claim before their competent data protection authority

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation 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 enquire with the Owner using the information provided in the contact section.

Details About the Right to Object to Processing

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, free of charge and without providing any justification.

Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

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 and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

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 this Application 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 anonymised 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
• 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

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 anonymised 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
• 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 authorised 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

Additional 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 this Application 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, Maryland, Indiana, Kentucky, Rhode Island 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.

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.

Identifiers

Personal Data processed: Various types of data as specified in the privacy policy of the service; Trackers

Personal Information collected or disclosed:

• Various types of Data as specified in the privacy policy of the service
• Trackers

Purposes:

• Traffic optimisation and distribution

Retention period: for the time necessary to fulfill the purpose
Sold or Shared: No
Targeted Advertising: No
Third-parties: Cloudflare, Inc.

Internet or Other Electronic Network Activity Information

Personal Data processed: Various types of data as specified in the privacy policy of the service; Trackers; Usage data; Number of users, session statistics

Personal Information collected or disclosed:

• Various types of Data as specified in the privacy policy of the service
• Trackers
• Usage Data
• Number of Users
• Session statistics

Purposes:

• Traffic optimisation and distribution
• Tag management
• Advertising
• Analytics
• Remarketing

Retention period: for the time necessary to fulfill the purpose
Sold or Shared: No
Targeted Advertising: Yes (for remarketing purposes)
Third-parties: Cloudflare, Inc., Google LLC, Hotjar Ltd.

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 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 this Application. For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, 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 this Application 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
• The right to non-discrimination. We will not discriminate against you for exercising your privacy rights

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, Maryland, Indiana, Kentucky, Rhode Island 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, Maryland, Indiana, Kentucky, Rhode Island 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 Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you

In Minnesota and Maryland 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 this Application. 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.

Google Ads Remarketing

This Application uses Google Ads Remarketing, a service provided by Google LLC that allows us to display targeted advertising to users based on their previous interactions with our website or app.

What is Google Ads Remarketing?

Google Ads Remarketing (also known as retargeting) is a feature that enables us to advertise to users who have previously visited our Application across other websites and applications across the internet. This service helps us deliver relevant advertising content to users who have already shown interest in our products or services. When you visit our Application, Google Ads Remarketing places cookies and other tracking technologies on your device to identify your visit. This information is then used to serve you targeted ads on other websites you visit that are part of the Google Display Network or other ad networks.

Types of Personal Data Processed for Remarketing

For Google Ads Remarketing purposes, the following types of Personal Data may be collected and processed:

• Trackers (cookies and unique identifiers)
• Usage Data (pages visited, time spent, interaction patterns)
• Device Information (device type, operating system, browser)
• Behavioral Data (browsing history, interests based on website interaction)
• Session Information (session duration and frequency of visits)

Important: We do not use Enhanced Conversions with Personally Identifiable Information (PII) such as names, email addresses, phone numbers, or addresses for remarketing purposes unless we have obtained explicit, separate consent for such processing.

How We Use Google Ads Remarketing

We use Google Ads Remarketing for the following purposes:

• Marketing and Advertising: To deliver targeted advertisements to users who have shown interest in our products or services
• Campaign Performance: To measure the effectiveness of our advertising campaigns and track user engagement
• Audience Building: To create custom audience segments based on user behavior and interactions with our Application
• Cross-Device Tracking: To display relevant ads to users across multiple devices they may use

How Third-Party Vendors Display Ads

Third-party vendors, including Google, display our remarketing ads on other websites across the internet. These vendors use cookies, device identifiers, and similar tracking technologies to:

• Identify users who have previously visited our Application
• Build audience profiles based on browsing history and user behavior
• Deliver targeted advertisements based on these profiles
• Track the performance of remarketing campaigns

Google and other third-party vendors may combine information from our Application with information from other sources to deliver more targeted advertising.

Cookies and Tracking Technologies Used in Remarketing

Google Ads Remarketing uses various cookies and tracking technologies to collect and store data about your interactions with our Application:

Google Remarketing Cookie:

• Cookie Name: Various (including _gcl_au, _gid, _ga)
• Duration: Up to 90 days (varies by cookie type)
• Purpose: To identify users and track their interactions for remarketing purposes

Conversion Tracking Cookies:

• Cookie Name: _gcl_* (Google Click Identifier)
• Duration: 90 days
• Purpose: To track conversions and measure the effectiveness of Google Ads campaigns

Advertising ID and Device Identifiers:

• Mobile devices may use Advertising IDs instead of cookies
• These identifiers serve the same purpose as cookies on desktop browsers

For a comprehensive list of all cookies used in remarketing, please refer to our Cookie Policy section on “Google Ads Remarketing.”

Legal Basis for Processing

The processing of Personal Data for Google Ads Remarketing is based on:

• User Consent: We obtain explicit consent from users in the European Union and other jurisdictions where consent is required before placing remarketing cookies or using remarketing features
• Legitimate Interests: We may process data for remarketing purposes based on our legitimate interest in promoting our products and services, subject to your rights and applicable law
• Compliance with Google’s Terms: We process data in accordance with Google’s advertising policies and EU User Consent Policy

GDPR Compliance

For users in the European Union, we comply with the General Data Protection Regulation (GDPR) by:

• Obtaining explicit, unambiguous, and prior informed consent before placing remarketing cookies
• Providing clear information about how we use remarketing to advertise online
• Enabling users to withdraw their consent at any time
• Maintaining detailed records of user consent for remarketing activities
• Allowing users to exercise their rights (access, rectification, erasure, portability)

User Rights Regarding Remarketing

Users have the following rights regarding their data processed for remarketing purposes:

• Right to Opt-Out: You can opt out of Google Ads Remarketing at any time
• Right to Access: You have the right to know what personal data is collected for remarketing
• Right to Rectification: You can request correction of inaccurate data
• Right to Erasure: You can request deletion of your data used for remarketing
• Right to Data Portability: You can request your data in a portable format
• Right to Object: You can object to the processing of your data for remarketing purposes

How to Opt Out of Google Ads Remarketing

Users can opt out of Google Ads Remarketing in several ways:

Option 1: Google Ads Settings

Visit Google’s Ads Settings page at https://adssettings.google.com to:

• View ads personalized based on your Google Account
• Turn off personalized ads
• Manage your interests and ad preferences

Option 2: Google Marketing Platform

Access Google’s Ad Settings at https://myaccount.google.com/ads-preferences to:

• Control which ads you see across Google and partner sites
• Manage your interests and demographics used for targeting

Option 3: Browser Cookie Settings

You can disable cookies in your browser settings to prevent remarketing cookies from being placed on your device. However, this may affect your overall browsing experience on our Application.

Option 4: Opt-Out Tools

• Network Advertising Initiative (NAI): https://www.networkadvertising.org/choices
• Digital Advertising Alliance (DAA): https://www.aboutads.info/choices
• YourOnlineChoices (EU): https://www.youronlinechoices.eu

Note: Even after opting out of remarketing, you may still see Google Ads, but they will not be personalized based on your browsing history.

Data Sharing with Google

We share the following information with Google for remarketing purposes:

• Cookie and Device Identifier Data: Information about your visits to our Application
• Behavioral Data: Pages visited, time spent on pages, and interactions with content
• Campaign Interaction Data: Information about ads you view and interact with

Google acts as a Data Processor on our behalf and is bound by the Data Processing Agreement between us and Google. Google may also use this data for its own purposes as a Data Controller, as described in Google’s Privacy Policy at https://policies.google.com/privacy.

International Data Transfers

Personal data collected for remarketing purposes may be transferred to countries outside the European Union and the European Economic Area, including the United States, where Google maintains its servers and processes remarketing data. We ensure that such transfers comply with applicable privacy laws through appropriate safeguards such as Standard Contractual Clauses.

Retention of Remarketing Data

Personal data processed for Google Ads Remarketing purposes is retained for:

• Remarketing Cookies: Up to 90 days from the last interaction with our Application
• Audience Lists: As long as the audience is active for remarketing campaigns, typically ranging from 30 days to several months
• Conversion Data: Up to 90 days for conversion tracking purposes

After the retention period expires, your data is automatically deleted and can no longer be used for remarketing purposes.

Contact for Remarketing-Related Inquiries

If you have questions about our use of Google Ads Remarketing or wish to exercise your rights regarding your data, you can contact us at the details provided in the “Owner and Data Controller” section above.

Additional Resources

For more information about Google Ads Remarketing, please visit:

• Google Ads Policies: https://support.google.com/adspolicy/
• Google Privacy Policy: https://policies.google.com/privacy
• Google Ads Help Center: https://support.google.com/google-ads/
• Google EU User Consent Policy: https://support.google.com/google-ads/answer/7521212

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 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.

Additional Information About User’s Personal Data

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.

System Logs and Maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (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 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.

Definitions and Legal References

Personal Data (or Data) / Personal Information (or Information)
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.

Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

Usage Data
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 utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised 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 utilised 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.

User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Processor)
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.

Data Controller (or Owner)
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.

This Application
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.

Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to a third party for cross-context behavioural advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

Targeted Advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)
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.

Cookie
Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker
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.

Legal Information

This privacy statement has been prepared based on provisions of multiple legislations. This privacy policy relates solely to this Application, if not stated otherwise within this document.

How Can We Help?

What You Can Do - Your Data

• Ask us to know and access the information we hold on you
• Ask us to correct information we hold on you
• Ask us to be forgotten (delete the information we hold on you)
• Ask to port your data to another service

In Case of Issues

While we strive to create a positive user experience, we understand that issues may occasionally arise between us and our users. If this is the case, please feel free to contact us.

Contact Us

SIBARTH
M. Ashley Lacour (Legal Representative)
Phone: +590 590 29 88 90
Email: [email protected]
Website: sibarth.com

SIBARTH veille à la protection des données personnelles des Utilisateurs conformément aux dispositions de la Loi n° 78-17 Informatique et Libertés du 6 janvier 1978. SIBARTH invite les Utilisateurs du Site à consulter la Charte de Protection des Données Personnelles qui précise les dispositions relatives à la collecte, au traitement et au transfert des données personnelles des Utilisateurs.

I. INFORMATIONS GENERALES

Par l’intermédiaire du site Internet «www.sibarth.com» (ci-après désigné le “Site”), SIBARTH peut être amenée à collecter les données personnelles de toute personne (ci-après désigné “l’Utilisateur”) effectuant une réservation en ligne.

Le responsable du traitement des données personnelles est le représentant légal de SIBARTH:
M. Ashley Lacour
Tél: (590) 590 29 88 90
E-mail: [email protected]

II. DROITS DES UTILISATEURS

L’Utilisateur dispose d’un droit à l’information, d’un droit d’accès, d’un droit de rectification, d’effacement et de limitation du traitement de ces données, d’un droit à la portabilité, ainsi que la possibilité de s’opposer au traitement de ses données, qu’il peut exercer à tout moment en adressant un courrier à l’adresse suivante: SIBARTH, La Maison Suédoise, 37 rue Samuel Fahlberg, Gustavia, 97133 Saint-Barthélemy, France ou à l’adresse e-mail suivante: [email protected].

S’il n’est pas satisfait, l’Utilisateur a également la possibilité d’introduire une réclamation auprès de la Commission nationale de l’informatique et des libertés («CNIL»), soit par voie électronique auprès de la CNIL via le téléservice de plainte en ligne accessible sur le site de la CNIL (www.cnil.fr), soit par voie postale à l’adresse suivante:

CNIL
Services des plaintes
3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07

III. GESTION DES DONNEES PERSONNELLES

3.1 Finalités de la collecte des données

La collecte des données à caractère personnel a pour finalité de permettre aux Utilisateurs de réserver en ligne des villas proposées par SIBARTH, réserver des services de conciergerie proposées par SIBARTH, permettre aux Utilisateurs d’entrer en relation avec SIBARTH dans le but de mener une opération de transaction sur immeubles et fonds de commerce. Les informations indispensables pour répondre aux demandes des Utilisateurs sont leur nom, prénom, adresse, email de l’Utilisateur.

3.2 Conservation des données à caractère personnel

SIBARTH s’engage à n’utiliser les données personnelles des Utilisateurs que pendant la durée nécessaire à la réalisation des finalités décrites ci-dessus. Elles sont conservées conformément aux durées prévues par la loi. Les délais de conservation des données varient selon la nature de la donnée et des obligations légales qui incombent au responsable de traitement.

3.3 Destinataires des données

SIBARTH est destinataire des données à caractère personnel des Utilisateurs. SIBARTH ne transmet les données d’un Utilisateur à un tiers que lorsque:
L’Utilisateur a donné son accord préalable à SIBARTH pour le partage de ses données avec ce tiers; SIBARTH doit partager les données avec ce tiers pour fournir le service demandé par l’Utilisateur ou répondre à sa demande; SIBARTH est enjoint par une autorité judiciaire ou toute autre autorité administrative compétente de lui communiquer les données en question. A ce titre, les données personnelles collectées et traitées par SIBARTH sont susceptibles d’être utilisées dans le cadre de l’application de réglementations comme celle relative à la lutte contre le blanchiment des capitaux et le financement du terrorisme.

3.4 Sécurité et confidentialité des données personnelles

SIBARTH s’est efforcée de mettre en place toutes mesures utiles pour préserver la confidentialité et la sécurité des données personnelles de l’Utilisateur traitées et empêcher qu’elles ne soient altérées, endommagées, détruites ou que des tiers non autorisés y aient accès.