2.1.1 Personal Data

While using Our Services, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address

First name and last name

Usage Data

2.2.1 Usage Data is collected automatically when using the Services.

2.2.2 Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

2.2.3 When You access the Services by or through a mobile device, We may collect certain information automatically, including, but not limited to,

The type of mobile device You use

Your mobile device unique ID

The IP address of Your mobile device

Your mobile operating system

The type of mobile Internet browser You use

Unique device identifiers and other diagnostic data

2.2.4 We may also collect information that Your browser sends whenever You visit our Services or when You access the Services by or through a mobile device.

2.2.5 Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Services. The technologies We use may include:

2.3.1 To provide and maintain our Services

Including to monitor the usage of our Services.

2.3.2 To manage Your Account

To manage Your registration as a user of the Services. The Personal Data You provide can give You access to different functionalities of the Services that are available to You as a registered user.

2.3.3 For the performance of a contract

The development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Services.

2.3.4 To contact You

To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

2.3.5 To provide You with news, special offers and general information

About other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

2.3.6 To manage Your requests

To attend and manage Your requests to Us.

2.3.7 For business transfers

We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Services users is among the assets transferred.

2.3.8 For other purposes

We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, services, marketing and your experience.

2.3.9 Sharing Your Personal Information

2.4.1

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

2.4.2

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Services, or We are legally obligated to retain this data for longer time periods.

2.5.1

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

2.5.2

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

2.5.3

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

2.6.1

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

2.6.2

Our Services may give You the ability to delete certain information about You from within the Services.

2.6.3

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

2.6.4

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

2.7.1 Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

2.7.2 Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

2.7.3 Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation

Protect and defend the rights or property of the Company

Prevent or investigate possible wrongdoing in connection with the Service

Protect the personal safety of Users of the Services or the public

Protect against legal liability

2.7.4 Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

2.7.5 Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Services in accordance with their Privacy Policies.

2.7.6 Analytics

We may use third-party Service Providers to monitor and analyse the use of our Services.

(a) Google Analytics - Google Analytics is a web analytics Services offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: policies.google.com

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: policies.google.com

(b) Mixpanel - Mixpanel is provided by Mixpanel Inc. You can prevent Mixpanel from using your information for analytics purposes by opting out. For more information visit mixpanel.com

(c) Hotjar - Their Privacy Policy can be viewed at hotjar.com

(d) Hubspot - Their Privacy Policy can be viewed at legal.hubspot.com

(e) Invisible reCAPTCHA - We use an invisible captcha Services named reCAPTCHA. reCAPTCHA is operated by Google. The reCAPTCHA Services may collect information from You and from Your Device for security purposes. The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: google.com

(f) Stripe - Their Privacy Policy can be viewed at stripe.com

2.7.7 Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

2.7.8 Payments

We may provide paid products and/or services within the Services. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

4.1.1 Conditions for Processing Personal Data

Where the General Data Protection Regulation applies, We may process Personal Data under the following conditions:

4.1.2 Clarification of Legal Basis

In any case, the Company 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.

4.2.1 Confidentiality Commitment

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

4.2.2 Additional Rights under GDPR

Where the General Data Protection Regulation applies, you are also provided with additional rights. This allows you, subject to certain conditions, to:

4.2.3 Access via Account

Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You.

4.3.1 Contacting the Company

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

4.3.2 Complaints to Data Protection Authority

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

5.1.1 Category A: Identifiers

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes

5.1.2 Category B: Personal information categories listed in the California Customer Records statute

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes

5.1.3 Category C: Protected classification characteristics under California or federal law

Examples: Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical Conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No

5.1.4 Category D: Commercial information

Examples: Records and history of products or services purchased or considered.

Collected: Yes

5.1.5 Category E: Biometric information

Examples: Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No

5.1.6 Category F: Internet or other similar network activity

Examples: Interaction with our Services or advertisement.

Collected: Yes

5.1.7 Category G: Geolocation data

Examples: Approximate physical location.

Collected: No

5.1.8 Category H: Sensory data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No

5.1.9 Category I: Professional or employment-related information

Examples: Current or past job history or performance evaluations.

Collected: No

5.1.10 Category J: Non-public education information

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No

5.1.11 Category K: Inferences drawn from other personal information

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Collected: No

5.1.12 Category L: Sensitive personal information

Examples: Account login and password information, geolocation data.

Collected: Yes

5.2.1 Directly from You

From forms you complete on our Services, preferences you express, or your purchases on our Services.

5.2.2 Indirectly from You

From observing your activity on our Services.

5.2.3 Automatically from You

Through cookies set by us or our service providers on your device as you navigate our Services.

5.2.4 From Service Providers

Third-party vendors to monitor and analyse the use of our Services, payment processing, or to provide the Services.

5.3.1 Use Examples

We may use or disclose personal information We collect for 'business purposes' or 'commercial purposes' (as defined under the CCPA/CPRA), which may include the following examples:

(a) To operate our Services and provide You with Our Services.

(b) To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Services.

(c) To fulfil or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Services, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or Services, We will use that information to process Your payment and facilitate delivery.

(d) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

(e) As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.

(f) For internal administrative and auditing purposes.

(g) To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

(h) Other one-time uses.

5.3.2 Notes

The examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the 'Use of Your Personal Data' section.

5.3.3 Additional Categories

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

5.4.1 Categories

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

(a) Category A: Identifiers

(b) Category B: Personal information categories listed in the California

(c) Customer Records statute (Cal. Civ. Code § 1798.80(e))

(d) Category D: Commercial information

(e) Category F: Internet or other similar network activity

5.4.2 Notes

The categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

5.4.3 Contractual Obligations

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

5.5.1 Service Providers

5.5.2 Payment processors

5.5.3 Affiliates

5.5.4 Business partners

5.5.5 Third Party Vendors

Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You.

5.6.1 Definition of Sale

As defined in the CCPA/CPRA, 'sell' and 'sale' mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer's personal information to a third party for valuable consideration.

5.6.2 General Sale Notes

We do not sell personal information as the term sell is commonly understood. Service Providers may use Your personal information for business purposes that may be deemed a sale under CCPA/CPRA.

5.6.3 Categories Sold

1. Category A: Identifiers
2. Category B: Personal information categories listed in the California
3. Customer Records statute (Cal. Civ. Code § 1798.80(e))
4. Category D: Commercial information
5. Category F: Internet or other similar network activity

5.6.4 Notes

The categories listed above are defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were sold, but reflects our good faith belief to the best of our knowledge that some of that information may have been shared for value in return.

5.7.1 Collection

We do not knowingly collect personal information from minors under the age of 16 through our Services, although certain third party websites may do so.

5.7.2 Opt-in Rights

Consumers who are 13-16 may opt-in. Parents can submit requests for minors under 13.

5.7.3 Contact

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

5.8.1 The Right to Notice

1. The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
2. The right to know/access. ...

5.8.2 Right to Opt-out

Right to direct Us to not sell Your personal information.

5.8.3 Right to Correct

Right to correct any inaccurate personal information collected.

5.8.4 Right to Limit Use/Disclosure of Sensitive Data

Right to limit use/disclosure of sensitive personal information.

5.8.5 Right to Delete

Right to request deletion of personal information, subject to exceptions.

5.8.6 Right Not to Be Discriminated Against

Right not to be discriminated against for exercising any rights, including denying goods, charging different prices, providing different quality, etc.

5.9.1 How to Exercise

Refer to Do Not Sell and Limit the Use or Disclosure sections.

5.9.2 Contact

Contact via [email protected]

5.9.3 Authorized Persons

Only You or an authorized person may make a verifiable request.

5.9.4 Request Requirements

Must provide sufficient info to verify identity and describe request in detail.

5.9.5 Verification Limitations

We cannot respond if identity or relation to personal info cannot be verified.

5.9.6 Disclosure Time

We will disclose free of charge within 45 days; may extend once by 45 days.

5.9.7 Period Covered

Disclosures cover only 12-month period preceding request.

5.9.8 Data Portability

We provide a readily usable format for data portability requests.

5.10.1 Definition

Definition of 'sell' and 'sale' as per CCPA/CPRA.

5.10.2 Notes

We do not sell personal information as commonly understood, Service Providers may use info in ways deemed 'sale'.

5.10.3 Right to Opt-out

You have the right to opt-out; contact Us to exercise this right.

5.10.4 Technology Use

Service Providers may use tech that sells personal info as defined by CCPA/CPRA.

5.10.5 Browser Specific

Opt-out is specific to the browser; may need to opt out on each browser.

5.11.1 Privacy Preferences

Click buttons on Services to review privacy preferences and opt out.

5.11.2 Opt-out of Personalized Ads

Follow NAI, EDAA, DAA platforms to opt-out.

5.11.3 Cookie Note

Opt-out will place a cookie unique to browser; may need to repeat if browsers change.

5.12.1 Opt-out of Ads

Android: 'Opt out of Interest-Based Ads' or 'Opt out of Ads Personalization'

iOS: 'Limit Ad Tracking'

5.12.2 Location Info

Stop collection of location info by changing mobile device preferences.

5.13.1 Right

Right to limit use/disclosure to necessary purposes for services or goods requested.

5.13.2 Usage

We collect, use, and disclose sensitive personal information as necessary to provide Services.

5.14.1 CalOPPA

1. Our Services does not respond to Do Not Track signals.
2. Some third party websites track browsing; preferences can be set in browser settings.

5.14.2 California Privacy Rights

1. Request info once a year about sharing Personal Data with third parties.
2. Contact Us using provided contact info.
3. California Privacy Rights for Minor Users.
4. Minors can request removal of content they posted.
5. Contact Us including account email.
6. Removal is not guaranteed in all circumstances.