Last Revised: November 25, 20201. INTRODUCTION
. This notice ("Privacy Notice
") uses certain terms that have the meanings given to them by California Consumer Privacy Act of 2018 and the California Consumer Privacy Act Regulation by the Attorney General (collectively, "CCPA
"). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.
If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy Notice.2. WHAT INFORMATION DO WE COLLECT?
We collect certain information which identifies an individual or may with reasonable effort identify an individual ("Personal Information
"). In addition, we treat information which is specifically connected or linked to any Personal Information - as long as such connection or linkage exists - as Personal Information.
We have collected the following categories of Personal Information in the last 12 months:a. Category and business/commercial purpose of collection of Personal Information
· Directly from consumers upon registration or use of the Service. Directly or indirectly from activity on our Service by cookies or other tracking technologies. From third parties that interact with us, including social networks, other consumers who use our Service and other publicly available sources.
· Directly from consumer's device by using cookies or other tracking technologies.
· Directly from consumer's device using Wi-Fi or cellular technology in your device, or by using IP address, or as directly submitted from the consumer, or as made available on publicly available sourcesc. Shared your Personal Information with the following categories of third parties:
· We disclose your Personal Information to third parties for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires both parties to confidential and not use it for any purpose except in the performance of the contract.
· In the preceding twelve (12) months, we have disclosed the above-mentioned categories of Personal Information with the following categories of recipients for a business purpose:
i. Our business partners;
ii. Our affiliates; iii. Service providers; iv. Social media networks v. Third-party marketing partners
vi. Regulators, courts or competent authorities, to the extent necessary, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
vii. We may share or transfer Personal Information to third parties as assets that are part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Information (as it is defined in the CCPA).d. Sale of data
· We may sell (according to the CCPA definition of a "sale") your Personal Information to third parties and businesses for commercial purposes. You have the right to opt-out of a sale of Personal Information (see below for more information on how to exercise your rights). We sold the following categories of personal information
i. Identifiers (online) associated with a device used to interact with our digital properties or advertisements (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology)
ii. Internet and other electronic network activity information associated with a device used to interact with Digital Properties or advertisements
We do not sell the personal information of consumers under the age of 16 if we have actual knowledge of the individual's age. We do not sell personal information as the term is traditionally understood, versus the definition under the CCPA — for example, we do not exchange for money personal information to data brokers or third parties for their marketing purposes independent of us.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.3. YOUR RIGHTS UNDER THE CCPA3.1.
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights (which may be subject to certain exemptions or derogations) and explains how to exercise those rights.
· You have the right to know what Personal Information is being collected about you, this include the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;
· You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
· You have the right to know whether your Personal Information is sold or disclosed and to whom;
· You have the right to the restriction of, or to object to, the processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
· You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA;
· You can exercise your rights by submitting a verifiable consumer request to our email address: firstname.lastname@example.org
You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law, or we will inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
· Marketing emails – opt-out
: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to email@example.com
. Please note that the email must come from the email account you wish to block.3.3. Response Timing and Format
· In accordance with the CCPA, our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.
· To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive (if we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request). In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
· In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
· Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.3.4. Designating Agents
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. You can designate an authorized agent to make a request under the CCPA on your behalf if:
• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf.
• If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.4. NON-DISCRIMINATION
If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our Website/App, our products and/or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program.
If you provide us with the above-mentioned categories of Personal Information, our Service will enable you to report and block spam calls and get a live caller-id and spam detector. If you do not provide your Personal Information or ask us to delete or to not sell or share your Personal Information, we will not be able to provide you with our App service, since your Personal Information is essential to provide our Service to you.5. DO-NOT-TRACK SIGNALS (SHINE THE LIGHT)
"Do Not Track" ("DNT
") mechanisms is a privacy preference that users can set in certain web browsers. Please note that we currently do not respond to web browser DNT signals that provide a method to opt out of the collection of information about online activities over time and across third-party websites or online services.6. UPDATES OR AMENDMENTS TO THE PRIVACY NOTICE
We reserve the right to change this Privacy Notice at any time, so please re-visit this page frequently. If we implement significant changes to the use of your Personal Information in a manner different from that stated at the time of collection, we will provide notice of such changes of this Privacy Notice on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered, or by other means. To the maximum extent permitted by law, such substantial changes will take effect seven (7) days after such notice was provided on any of the above-mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated "Last Revised" date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.7. HOW TO CONTACT US
If you have any questions (or comments) concerning this Privacy Notice, you are welcome to contact us here: firstname.lastname@example.org