Last updated: March 2, 2022
We use Your Personal data to provide and improve the Service. By using
the Service, You agree to the collection and use of information in
accordance with this Privacy Policy.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings
defined under the following conditions. The following definitions
shall have the same meaning regardless of whether they appear in
singular or in plural. For the purposes of this Privacy Policy:
-
Account means a unique account created for You to access our
Service or parts of our Service.
-
Business, for the purpose of the CCPA (California Consumer
Privacy Act), refers to the Company as the legal entity that
collects Consumers' personal information and determines the purposes
and means of the processing of Consumers' personal information, or
on behalf of which such information is collected and that alone, or
jointly with others, determines the purposes and means of the
processing of consumers' personal information, that does business in
the State of California.
-
Company (referred to as either "the Company",
"I", "We", "Us" or "Our" in
this Agreement) refers to HEX, R. Prof Maria Jose Barone Fernandes, 02117022 SP - Brazil. For the purpose of the GDPR, the Company is the
Data Controller.
-
Consumer, for the purpose of the CCPA (California Consumer
Privacy Act), means a natural person who is a California resident. A
resident, as defined in the law, includes (1) every individual who
is in the USA for other than a temporary or transitory purpose, and
(2) every individual who is domiciled in the USA who is outside the
USA for a temporary or transitory purpose.
-
Cookies are small files that are placed on Your computer,
mobile device or any other device by a website, containing the
details of Your browsing history on that website among its many
uses.
- Country refers to: California, United States
-
Data Controller, for the purposes of the GDPR (General Data
Protection Regulation), refers to the Company as the legal person
which alone or jointly with others determines the purposes and means
of the processing of Personal Data.
-
Device means any device that can access the Service such as a
computer, a cellphone or a digital tablet.
-
Do Not Track (DNT) is a concept that has been promoted by US
regulatory authorities, in particular the U.S. Federal Trade
Commission (FTC), for the Internet industry to develop and implement
a mechanism for allowing internet users to control the tracking of
their online activities across websites.
-
Facebook Fan Page is a public profile named BrainzillaHQ
specifically created by the Company on the Facebook social network,
accessible from
https://www.facebook.com/BrainzillaHQ/
-
Personal Data is any information that relates to an
identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information
relating to You such as a name, an identification number, location
data, online identifier or to one or more factors specific to the
physical, physiological, genetic, mental, economic, cultural or
social identity.
For the purposes of the CCPA, Personal Data means any information
that identifies, relates to, describes or is capable of being
associated with, or could reasonably be linked, directly or
indirectly, with You.
-
Sale, for the purpose of the CCPA (California Consumer
Privacy Act), means selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a
Consumer's personal information to another business or a third party
for monetary or other valuable consideration.
- Service refers to the Website.
-
Service Provider means any natural or legal person who
processes the data on behalf of the Company. It refers to
third-party companies or individuals employed by the Company to
facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the
Company in analyzing how the Service is used.
For the purpose of the GDPR, Service Providers are considered Data
Processors.
-
Third-party Social Media Service refers to any website or any
social network website through which a User can log in or create an
account to use the Service.
-
Usage Data refers to data collected automatically, either
generated by the use of the Service or from the Service
infrastructure itself (for example, the duration of a page visit).
-
Website refers to Brainzilla, accessible from
https://www.brainzilla.com
-
You means the individual accessing or using the Service, or
the company, or other legal entity on behalf of which such
individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred
to as the Data Subject or as the User as you are the individual
using the Service.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain
personally identifiable information that can be used to contact or
identify You. We only ask for Personally identifiable information when
it is necessary to provide a particular Service. For example, if You
purchase something from Us using a credit card, We ask for Your full
name and address in order to complete the purchase. Personally
identifiable information may include, but is not limited to:
- Email address
- Username
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
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 Service that You visit, the time and date of Your visit,
the time spent on those pages, unique device identifiers and other
diagnostic data.
When You access the Service 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.
We may also collect information that Your browser sends whenever You
visit our Service or when You access the Service by or through a
mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity
on Our Service and store certain information. Tracking technologies
used are beacons, tags, and scripts to collect and track information
and to improve and analyze Our Service. The technologies We use may
include:
-
Cookies or Browser Cookies. A cookie is a small file placed
on Your Device. You can instruct Your browser to refuse all Cookies
or to indicate when a Cookie is being sent. However, if You do not
accept Cookies, You may not be able to use some parts of our
Service. Unless you have adjusted Your browser setting so that it
will refuse Cookies, our Service may use Cookies.
Cookies can be "Persistent" or "Session" Cookies.
Persistent Cookies remain on Your personal computer or mobile device
when You go offline, while Session Cookies are deleted as soon as You
close Your web browser.
We use both Session and Persistent Cookies for the purposes set out
below:
-
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services
available through the Website and to enable You to use some of its
features. They help to authenticate users and prevent fraudulent use
of user accounts. Without these Cookies, the services that You have
asked for cannot be provided, and We only use these Cookies to
provide You with those services.
-
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when
You use the Website, such as remembering your login details or
language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter
your preferences every time You use the Website.
-
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic
to the Website and how users use the Website. The information
gathered via these Cookies may directly or indirectly identify you
as an individual visitor. This is because the information collected
is typically linked to a pseudonymous identifier associated with the
device you use to access the Website. We may also use these Cookies
to test new pages, features or new functionality of the Website to
see how our users react to them. These Cookies help Us improve the
Website.
-
Targeting and Advertising Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies track your browsing habits to enable Us to
show advertising which is more likely to be of interest to You.
These Cookies use information about your browsing history to group
You with other users who have similar interests. Based on that
information, and with Our permission, third party advertisers can
place Cookies to enable them to show adverts which We think will be
relevant to your interests while You are on third party websites.
Advertising is how We keep the Website online for you to enjoy for
free.
For more information about the cookies we use and your choices
regarding cookies, please visit our Cookies Policy or the Cookies
section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
-
To provide and maintain our Service, including to monitor the
usage of our Service.
-
To manage Your Account: to manage Your registration as a user
of the Service. The Personal Data You provide can give You access to
different functionalities of the Service that are available to You
as a registered user.
-
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 Service.
-
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.
-
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
inquired about unless You have opted not to receive such
information.
-
To manage Your requests: To attend and manage Your requests
to Us.
-
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 Service users is among the assets
transferred.
-
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 Service, products, services, marketing and
your experience.
We may share Your personal information in the following situations:
-
With Service Providers: We may share Your personal
information with Service Providers to monitor and analyze the use of
our Service, to show advertisements to You to help support and
maintain Our Service, for payment processing, to contact You.
-
For business transfers: We may share or transfer Your
personal information in connection with, or during negotiations of,
any merger, sale of Company assets, financing, or acquisition of all
or a portion of Our business to another company.
-
With Affiliates: We may share Your information with Our
affiliates, in which case we will require those affiliates to honor
this Privacy Policy. Affiliates include Our parent company and any
other subsidiaries, joint venture partners or other companies that
We control or that are under common control with Us.
-
With business partners: We may share Your information with
Our business partners to offer You certain products, services or
promotions.
-
With other users: when You share personal information or
otherwise interact in the public areas with other users, such
information may be viewed by all users and may be publicly
distributed outside. If You interact with other users or register
through a Third-Party Social Media Service, Your contacts on the
Third-Party Social Media Service may see Your name, profile,
pictures and description of Your activity. Similarly, other users
will be able to view descriptions of Your activity, communicate with
You and view Your profile.
-
With Your consent: We may disclose Your personal information
for any other purpose with Your consent.
Retention of Your Personal Data
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.
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 Service, or We are legally obligated
to retain this data for longer time periods.
Transfer of Your Personal Data
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.
Your consent to this Privacy Policy followed by Your submission of
such information represents Your agreement to that transfer.
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.
Disclosure of Your Personal Data
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.
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).
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 Service or the public
- Protect against legal liability
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.
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 Service in accordance with
their Privacy Policies.
Analytics
We may use third-party Service providers to monitor and analyze the
use of our Service.
-
Google Analytics
Google Analytics is a web analytics service offered by Google that
tracks and reports website traffic. Google uses the data collected
to track and monitor the use of our Service. 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 Service
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.
For more information on the privacy practices of Google, please
visit the
Google Privacy
&
Terms
web pages
Advertising
We may use Service Providers to show advertisements to You to help
support and maintain Our Service.
-
Google AdSense & DoubleClick Cookie
Google, as a third party vendor, uses cookies to serve ads on our
Service. Google's use of the DoubleClick cookie enables it and its
partners to serve ads to our users based on their visit to our
Service or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for
interest-based advertising by visiting the Google Ads Settings web
page:
http://www.google.com/ads/preferences/
-
Publift
Publift, as a third party vendor, uses cookies to serve ads on our
Service. Their Privacy Policy can be viewed at
https://publift.com/privacy-policy/
-
Amazon
We are a participant in the Amazon Services LLC Associates Program,
an affiliate advertising program designed to provide a means for us
to earn fees by linking to Amazon.com and affiliated sites.
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 or
updating your settings on the Website.
We may use Email Marketing Service Providers to manage and send emails
to You.
-
Mailchimp
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their Privacy policy:
https://mailchimp.com/legal/privacy/
Payments
We may provide paid products and/or services within the Service. 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.
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
-
Consent: You have given Your consent for processing Personal
Data for one or more specific purposes.
-
Performance of a contract: Provision of Personal Data is
necessary for the performance of an agreement with You and/or for
any pre-contractual obligations thereof.
-
Legal obligations: Processing Personal Data is necessary for
compliance with a legal obligation to which the Company is subject.
-
Vital interests: Processing Personal Data is necessary in
order to protect Your vital interests or of another natural person.
-
Public interests: Processing Personal Data is related to a
task that is carried out in the public interest or in the exercise
of official authority vested in the Company.
-
Legitimate interests: Processing Personal Data is necessary
for the purposes of the legitimate interests pursued by the Company.
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.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal
Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are
within the EU, to:
-
Request access to Your Personal Data. The right to access,
update or delete the information We have on You. 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. This also enables You to receive a copy of the Personal
Data We hold about You.
-
Request correction of the Personal Data that We hold about
You.
You have the right to to have any incomplete or inaccurate
information We hold about You corrected.
-
Object to processing of Your Personal Data. This right exists
where We are relying on a legitimate interest as the legal basis for
Our processing and there is something about Your particular
situation, which makes You want to object to our processing of Your
Personal Data on this ground. You also have the right to object
where We are processing Your Personal Data for direct marketing
purposes.
-
Request erasure of Your Personal Data. You have the right to
ask Us to delete or remove Personal Data when there is no good
reason for Us to continue processing it.
-
Request the transfer of Your Personal Data. We will provide
to You, or to a third-party You have chosen, Your Personal Data in a
structured, commonly used, machine-readable format. Please note that
this right only applies to automated information which You initially
provided consent for Us to use or where We used the information to
perform a contract with You.
-
Withdraw Your consent. You have the right to withdraw Your
consent on using your Personal Data. If You withdraw Your consent,
We may not be able to provide You with access to certain specific
functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
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.
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.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected
while using the Service. As operator of the Facebook Fan Page
https://www.facebook.com/BrainzillaHQ/, the Company and the operator of the social network Facebook are
Joint Controllers.
The Company has entered into agreements with Facebook that define the
terms for use of the Facebook Fan Page, among other things. These
terms are mostly based on the Facebook Terms of Service:
https://www.facebook.com/terms.php
Visit the Facebook Privacy Policy
https://www.facebook.com/policy.php
for more information about how Facebook manages Personal data or
contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy
Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.
Facebook Insights
We use the Facebook Insights function in connection with the operation
of the Facebook Fan Page and on the basis of the GDPR, in order to
obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user
visiting Our Facebook Fan Page. Each Cookie contains a unique
identifier code and remains active for a period of two years, except
when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the
Cookie, especially when the user visits the Facebook services,
services that are provided by other members of the Facebook Fan Page
and services by other companies that use Facebook services.
For more information on the privacy practices of Facebook, please
visit Facebook Privacy Policy here:
https://www.facebook.com/full_data_use_policy
CCPA Privacy
This privacy notice section for California residents supplements the
information contained in Our Privacy Policy and it applies solely to
all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes,
references, is capable of being associated with, or could reasonably
be linked, directly or indirectly, with a particular Consumer or
Device. The following is a list of categories of personal information
which we may collect or may have been collected from California
residents within the last twelve (12) months.
Please note that the categories and examples provided in the list
below are those defined in the CCPA. This does not mean that all
examples of that category of personal information were in fact
collected by Us, 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 collected. For example, certain categories of
personal information would only be collected if You provided such
personal information directly to Us.
-
Category A: Identifiers.
Collected by Us: Yes.
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.
-
Category B: Personal information categories listed in the
California Customer Records statute (Cal. Civ. Code §
1798.80(e)).
Collected by Us: Yes.
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.
-
Category C: Protected classification characteristics under
California or federal law.
Collected by Us: Yes.
Examples: Age (40 years or older), race, color, 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).
-
Category D: Commercial information.
Collected by Us: Yes.
Examples: Records and history of products or services purchased or
considered.
-
Category E: Biometric information.
Collected by Us: No.
Examples: Genetic, physiological, behavioral, 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.
-
Category F: Internet or other similar network activity.
Collected by Us: Yes.
Examples: Interaction with our Service or advertisement.
-
Category G: Geolocation data.
Collected by Us: No.
Examples: Approximate physical location.
-
Category H: Sensory data.
Collected by Us: No.
Examples: Audio, electronic, visual, thermal, olfactory, or similar
information.
-
Category I: Professional or employment-related information.
Collected by Us: No.
Examples: Current or past job history or performance evaluations.
-
Category J: Non-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34
C.F.R. Part 99)).
Collected by Us: No.
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.
-
Category K: Inferences drawn from other personal information.
Collected by Us: No.
Examples: Profile reflecting a person's preferences,
characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.
Under CCPA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
-
Information excluded from the CCPA's scope, such as:
-
Health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the
California Confidentiality of Medical Information Act (CMIA) or
clinical trial data
-
Personal Information covered by certain sector-specific privacy
laws, including the Fair Credit Reporting Act (FRCA), the
Gramm-Leach-Bliley Act (GLBA) or California Financial
Information Privacy Act (FIPA), and the Driver's Privacy
Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the
following categories of sources:
-
Directly from You. For example, from the forms You complete
on our Service, preferences You express or provide through our
Service, or from Your purchases on our Service.
-
Indirectly from You. For example, from observing Your
activity on our Service.
-
Automatically from You. For example, through cookies We or
our Service Providers set on Your Device as You navigate through our
Service.
-
From Service Providers. For example, third-party vendors to
monitor and analyze the use of our Service, third-party vendors to
provide advertising on our Service, third-party vendors for payment
processing, or other third-party vendors that We use to provide the
Service to You.
Use of Personal Information for Business Purposes or Commercial
Purposes
We may use or disclose personal information We collect for
"business purposes" or "commercial purposes" (as
defined under the CCPA), which may include the following examples:
- To operate our Service and provide You with our Service.
-
To provide You with support and to respond to Your inquiries,
including to investigate and address Your concerns and monitor and
improve our Service.
-
To fulfill or meet the reason You provided the information. For
example, if You share Your contact information to ask a question
about our Service, We will use that personal information to respond
to Your inquiry. If You provide Your personal information to
purchase a product or service, We will use that information to
process Your payment and facilitate delivery.
-
To respond to law enforcement requests and as required by applicable
law, court order, or governmental regulations.
-
As described to You when collecting Your personal information or as
otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
-
To detect security incidents and protect against malicious,
deceptive, fraudulent or illegal activity, including, when
necessary, to prosecute those responsible for such activities.
Please note that 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.
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.
Disclosure of Personal Information for Business Purposes or Commercial
Purposes
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:
- Category A: Identifiers
-
Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))
-
Category C: Protected classification characteristics under
California or federal law.
- Category D: Commercial information
- Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the
CCPA. 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.
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.
Sale of Personal Information
As defined in the CCPA, "sell" and "sale" mean
selling, 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 valuable
consideration. This means that We may have received some kind of
benefit in return for sharing personal information, but not
necessarily a monetary benefit.
Please note that the categories listed below are those defined in the
CCPA. This does not mean that all examples of that category of
personal information were in fact sold, 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 shared for value in
return.
We may sell and may have sold in the last twelve (12) months the
following categories of personal information:
- Category A: Identifiers
-
Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))
-
Category C: Protected classification characteristics under
California or federal law.
- Category D: Commercial information
- Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the above
categories with the following categories of third parties:
- Service Providers
- Payment processors
- Our affiliates
- Our business partners
-
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
Sale of Personal Information of Minors Under 16 Years of Age
We do not sell the personal information of Consumers We actually know
are less than 16 years of age, unless We receive affirmative
authorization (the "right to opt-in") from either the
Consumer who is between 13 and 16 years of age, or the parent or
guardian of a Consumer less than 13 years of age. Consumers who opt-in
to the sale of personal information may opt-out of future sales at any
time. To exercise the right to opt-out, You (or Your authorized
representative) may submit a request to Us by contacting Us.
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.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding
their personal information. If You are a resident of California, You
have the following rights:
-
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.
-
The right to request. Under CCPA, You have the right to
request that We disclose information to You about Our collection,
use, sale, disclosure for business purposes and share of personal
information. Once We receive and confirm Your request, We will
disclose to You:
-
The categories of personal information We collected about You
-
The categories of sources for the personal information We
collected about You
-
Our business or commercial purpose for collecting or selling
that personal information
-
The categories of third parties with whom We share that personal
information
-
The specific pieces of personal information We collected about
You
-
If we sold Your personal information or disclosed Your personal
information for a business purpose, We will disclose to You:
-
The categories of personal information categories sold
-
The categories of personal information categories disclosed
-
The right to say no to the sale of Personal Data (opt-out).
You have the right to direct Us to not sell Your personal
information. To submit an opt-out request please contact Us.
-
The right to delete Personal Data. You have the right to
request the deletion of Your Personal Data, subject to certain
exceptions. Once We receive and confirm Your request, We will delete
(and direct Our Service Providers to delete) Your personal
information from our records, unless an exception applies. We may
deny Your deletion request if retaining the information is necessary
for Us or Our Service Providers to:
-
Complete the transaction for which We collected the personal
information, provide a good or service that You requested, take
actions reasonably anticipated within the context of our ongoing
business relationship with You, or otherwise perform our
contract with You.
-
Detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible
for such activities.
-
Debug products to identify and repair errors that impair
existing intended functionality.
-
Exercise free speech, ensure the right of another consumer to
exercise their free speech rights, or exercise another right
provided for by law.
-
Comply with the California Electronic Communications Privacy Act
(Cal. Penal Code § 1546 et. seq.).
-
Engage in public or peer-reviewed scientific, historical, or
statistical research in the public interest that adheres to all
other applicable ethics and privacy laws, when the information's
deletion may likely render impossible or seriously impair the
research's achievement, if You previously provided informed
consent.
-
Enable solely internal uses that are reasonably aligned with
consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
-
Make other internal and lawful uses of that information that are
compatible with the context in which You provided it.
-
The right not to be discriminated against. You have the right
not to be discriminated against for exercising any of Your
consumer's rights, including by:
- Denying goods or services to You
-
Charging different prices or rates for goods or services,
including the use of discounts or other benefits or imposing
penalties
-
Providing a different level or quality of goods or services to
You
-
Suggesting that You will receive a different price or rate for
goods or services or a different level or quality of goods or
services
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are
a California resident, You can contact Us:
Only You, or a person registered with the California Secretary of
State that You authorize to act on Your behalf, may make a verifiable
request related to Your personal information.
Your request to Us must:
-
Provide sufficient information that allows Us to reasonably verify
You are the person about whom We collected personal information or
an authorized representative
-
Describe Your request with sufficient detail that allows Us to
properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required
information if We cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge
within 45 days of receiving Your verifiable request. The time period
to provide the required information may be extended once by an
additional 45 days when reasonable necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period
preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your
personal information that is readily useable and should allow You to
transmit the information from one entity to another entity without
hindrance.
Do Not Sell My Personal Information
You have the right to opt-out of the sale of Your personal
information. Once We receive and confirm a verifiable consumer request
from You, we will stop selling Your personal information. To exercise
Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or
advertising partners) may use technology on the Service that sells
personal information as defined by the CCPA law. If you wish to opt
out of the use of Your personal information for interest-based
advertising purposes and these potential sales as defined under CCPA
law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You
may need to opt out on every browser that You use.
Website
You can opt out of receiving ads that are personalized as served by
our Service Providers by following our instructions presented on the
Service:
The opt out will place a cookie on Your computer that is unique to the
browser You use to opt out. If you change browsers or delete the
cookies saved by your browser, You will need to opt out again.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of
information about the apps You use in order to serve You ads that are
targeted to Your interests:
-
"Opt out of Interest-Based Ads" or "Opt out of Ads
Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from Your
mobile device by changing the preferences on Your mobile device.
"Do Not Track" Policy as Required by California Online
Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing
activities. If You are visiting such websites, You can set Your
preferences in Your web browser to inform websites that You do not
want to be tracked. You can enable or disable DNT by visiting the
preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light
law), California residents with an established business relationship
with us can request information once a year about sharing their
Personal Data with third parties for the third parties' direct
marketing purposes.
If you'd like to request more information under the California Shine
the Light law, and if You are a California resident, You can contact
Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and
Professions Code Section 22581)
California Business and Professions Code section 22581 allow
California residents under the age of 18 who are registered users of
online sites, services or applications to request and obtain removal
of content or information they have publicly posted.
To request removal of such data, and if You are a California resident,
You can contact Us using the contact information provided below, and
include the email address associated with Your account.
Be aware that Your request does not guarantee complete or
comprehensive removal of content or information posted online and that
the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated
by Us. If You click on a third party link, You will be directed to
that third party's site. We strongly advise You to review the Privacy
Policy of every site You visit.
We have no control over and assume no responsibility for the content,
privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You
of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our
Service, prior to the change becoming effective and update the
"Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any
changes. Changes to this Privacy Policy are effective when they are
posted on this page.
Children's Online Privacy Protection Act (COPPA)
We do not collect information from children under the age of 13. If
You have reason to believe that a child under the age of 13 has
provided Us with personal information, please contact Us with
sufficient detail to enable Us to delete that information.
Privacy/security incident plan
In the event of a privacy/security incident, the plan of the Company’s Privacy/ Incident Response Team are to:
- Investigate the incident internally (in cooperation with law enforcement if necessary);
- Mitigate potential harm to affected parties;
- Minimize adverse impact to the Company in an ethically and legally appropriate manner, to include minimizing reduction in operations, reputational harm, and/or financial harm;
- Appropriately communicate the incident or loss:
- To affected parties in a timely manner (as appropriate or as otherwise may be required by law);
- To regulatory agencies, news media, or other entities (as appropriate or required);
- To staff (as appropriate or required, especially to leadership);
- Provide guidance or assistance in the development of specific corrective actions (including disciplinary actions when appropriate);
- Conduct post-incident reviews, training and education, and provide internal communications in order to minimize potential future incidents.
Contact Us
If you have any questions about this Privacy Policy, You can contact
us: