Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 Our website does not have built-in privacy controls for managing personal data, as we do not collect or store personal user information beyond necessary cookies for analytics and advertising. However, you can manage your privacy preferences, including opting out of personalized advertising, through third-party platforms such as Google Ad Settings (https://adssettings.google.com/) and YourAdChoices (https://youradchoices.com).

1.4 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and its functionalities, we will ask you to consent to our use of cookies when you first visit our website.

1.5 In this policy, “we,” “us,” and “our” refer to DAVCNA.com, under the brand name DAVI – Your Guide to the Best Books.

2. Credit

2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1 In this Section 3, we have set out the general categories of personal data that we process in compliance with GDPR (EU and UK), CCPA (USA), and Australian Privacy Principles (APPs).

3.2 We do not collect direct personal contact data. However, if you contact us voluntarily through email or other communication channels, we may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, and any other details you provide in your communication. The source of the contact data is you.

3.3 Our website does not have user accounts, and therefore, we do not process “account data” related to logins, registrations, or stored user preferences.

3.4 We do not process transaction data as our website does not handle direct sales, payments, or financial transactions. However, we provide affiliate links to Amazon through AAWP, which may collect data under Amazon’s own privacy policy. Users should refer to Amazon’s privacy policy for details on data collection and processing: Amazon Privacy Notice.

3.5 We may process information contained in or relating to any communication that you send to us (“communication data”). The communication data may include the content of your messages and metadata associated with your communication. If you use our contact form, our website may generate metadata related to the communication.

3.6 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address (anonymized), geographical region (general, non-precise), browser type and version, operating system, referral source, visit duration, page views, and navigation paths. The source of the usage data is Google Analytics (with all tracking features disabled except for basic anonymous data collection)

3.7 We may process advertising data to facilitate Google AdSense advertisements. This data may include non-personally identifiable tracking information related to your interaction with ads. The source of this data is Google AdSense, which operates under its own privacy policy: Google Privacy Policy.

3.8 Additional Privacy Protections

  • We do not track individual users across different websites.
  • We do not use behavioral tracking cookies beyond Google AdSense’s contextual ad targeting.
  • Users can manage ad personalization settings via Google Ads Settings.
  • We comply with GDPR, CCPA, and APPs providing transparency regarding the data collected.

4. Purposes of processing and legal bases

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2 Operations – We may process usage data for the purposes of operating our website, monitoring traffic, and ensuring the proper functionality of our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

4.3 Publications – Our website does not have user accounts or allow user-generated content. Therefore, we do not process account data for publication purposes.

4.4 Relationships and communications – We may process contact data and communication data for the purposes of responding to inquiries, managing relationships, and providing support services. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and the proper administration of our website and business.

4.5 Direct marketing – We do not send direct marketing communications via email, SMS, or post. Any advertising on our website is managed by Google AdSense, and users can opt out of personalized ads through Google Ads Settings.

4.6 Research and analysis – We may process usage data for the purposes of analyzing website traffic and improving user experience. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving, and securing our website and business.

4.7 Record keeping – We may process communication data for the purposes of maintaining our business records and correspondence. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.8 Security – We may process usage data for the purposes of website security, fraud prevention, and protection against unauthorized access. The legal basis for this processing is our legitimate interests, namely the protection of our website, services, and business, as well as the protection of others.

4.9 Insurance and risk management – We may process personal data related to legal or compliance matters where necessary for obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

4.10 Legal claims – We may process communication data or any other relevant personal data where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

4.11 Legal compliance and vital interests – We may process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.

5. Providing your personal data to others

5.1 We may disclose usage data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice.

5.2 Usage data and other non-personally identifiable information collected on our website will be stored on the servers of our hosting service providers. We use NameHero, ChemiCloud, and MechanicWeb for hosting services. You can review their privacy policies at the following links:

5.3 We do not share personal data with third-party suppliers or subcontractors. However, we use third-party services such as Google Analytics (with limited tracking enabled), Google Tag Manager, Google AdSense, and AAWP (Amazon Affiliate WordPress Plugin), which may collect non-personally identifiable data under their own privacy policies.

5.4 We do not process financial transactions, as our website does not handle direct payments or purchases. Any financial transactions occur directly through Amazon, via affiliate links. Users should refer to Amazon’s Privacy Notice at https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ for details on how Amazon processes transactions and user data.

5.5 In addition to the specific disclosures of data set out in this Section 5, we may disclose personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data if required for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. International transfers of your personal data

6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law, EU data protection law, US privacy laws (CCPA), and Australian privacy regulations (APPs).

6.2 We do not actively transfer personal data from the European Economic Area (EEA), the UK, the USA, or Australia to other regions. However, some of our third-party service providers and hosting facilities may process data in jurisdictions outside these regions.

6.3 The hosting facilities for our website are situated in the United States and other locations where our hosting providers operate. Specifically, our website is hosted by:

Transfers to these hosting providers may be protected by appropriate safeguards, such as Standard Contractual Clauses (SCCs) or reliance on adequacy decisions by the European Commission and the UK government.

6.4 Our third-party service providers include:

  • Google (Google Analytics, Google AdSense, Google Tag Manager) – Google operates data centers globally, including in the USA, EU, and other locations. Data transfers are protected under Google’s Standard Contractual Clauses (SCCs) and EU-US Data Privacy Framework.
  • AAWP (Amazon Affiliate Plugin) – Data related to Amazon affiliate links may be processed under Amazon’s data policies. Amazon operates in multiple jurisdictions and complies with GDPR, CCPA, and other privacy frameworks. See Amazon Privacy Notice.

6.5 You acknowledge that personal data that you submit for publication through our website or services (if applicable) may be available via the internet worldwide. We cannot prevent the use (or misuse) of such data by third parties.

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 We will retain your personal data as follows:

(a) Contact data (if applicable) will be retained for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 12 months following that date, unless required for legal reasons.

(b) Account data – We do not process account data as our website does not have user login or account registration functionality.

(c) Transaction data – We do not process direct transaction data, as all transactions occur via Amazon’s affiliate program. Users should refer to Amazon’s data retention policies in their Privacy Notice.

(d) Communication data (including inquiries and messages) will be retained for a minimum period of 6 months following the date of the communication in question and for a maximum period of 24 months, after which it will be securely deleted unless required for legal purposes.

(e) Usage data (collected via Google Analytics with tracking restrictions) will be retained for 14 months following the date of collection, after which it will be anonymized or deleted in accordance with Google’s data retention policies.

(f) Advertising and affiliate tracking data (via Google AdSense and AAWP) is processed by third parties under their own retention policies. You can review their policies at:

7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Your rights

8.1 In this Section 8, we have listed the rights that you have under data protection law.

8.2 Your principal rights under data protection law are:

(a) the right to access – you can ask for copies of your personal data;

(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure – you can ask us to erase your personal data;

(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e) the right to object to processing – you can object to the processing of your personal data;

(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) Advertising – We use cookies to help us display advertisements that are relevant to you through Google AdSense. These cookies allow Google to serve ads based on your previous interactions with our website or other websites.

(b) Event Tracking – We use cookies to centralize tracking events via Google Tag Manager, which helps manage analytics and marketing tools without directly storing personal data.

(c) Affiliate Link Optimization – We use cookies through AAWP to determine your country and redirect you to the appropriate Amazon store for affiliate purposes. These cookies do not store personal data beyond location-based redirection.

(d) Cookie Consent – We use cookies to store your preferences regarding cookie usage on our website.

  • Cookies used for this purpose: Cookie Consent cookies (cookie_consent_status)

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics, which gathers information about the use of our website and uses cookies for this purpose. We use the information gathered by Google Analytics to create reports about the use of our website while keeping tracking features restricted to anonymous data collection.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/products/firefox/privacy-and-security (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.apple.com/en-gb/guide/safari/welcome/mac (Safari); and

(e) https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Amendments

13.1 We may update this policy from time to time by publishing a new version on our website.

13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

13.3 We will notify you of significant changes to this policy by updating the policy date on our website. If legally required, we will also provide further notice via email (if applicable) or a website banner notification.

14. Our details

14.1 This website is owned and operated by DAVCNA.com, under the brand name DAVI – Your Guide to the Best Books.

14.2 We are registered in Brazil under registration number 33.821.832/0001-28, and our registered office is at Ipatinga, Minas Gerais, Brazil.

14.3 Our principal place of business is at Ipatinga, Minas Gerais, Brazil.

14.4 You can contact us:

(a) by email, using the email address published on our website: contact@davcna.com

15. Representatives

15.1 EU and UK Representative – As our operations are based in Brazil, and we do not have a physical presence or representative within the EU or UK, we rely on Article 27 exemptions under the GDPR and UK GDPR, as we do not process personal data on a large scale or engage in high-risk processing activities.

15.2 If required under applicable laws, users within the EU or UK may contact us directly regarding data protection matters at:

Email: [contact@davcna.com]

16. Data protection officer

16.1 As we are a Brazil-based entity, we do not have a formally appointed Data Protection Officer (DPO). However, we are committed to data protection and compliance with applicable laws. For any data privacy concerns or GDPR-related inquiries, you may contact us at:

Email: [contact@davcna.com]

17. Law and jurisdiction

17.1 These terms and conditions shall be governed by and construed in accordance with Brazilian law, as well as applicable data protection laws of the European Union (GDPR), the United Kingdom (UK GDPR), the United States (CCPA and relevant state laws), and Australia (Privacy Act 1988 and Australian Privacy Principles – APPs), to the extent they apply to users in those jurisdictions.

17.2 Any disputes relating to these Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Comarca of Ipatinga, Minas Gerais, Brazil, with express waiver of any other jurisdiction, no matter how privileged it may be, to resolve any doubt, dispute, or litigation arising from this document.

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