Privacy Policy: General Data Protection Regulation (GDPR)

Background:

SkipperMyBoat Inc. respects and values the privacy of everyone who visits Our Site and will only collect and use information as set forth in this Privacy Policy and in a manner consistent with your User rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site and Our Services. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site or our Services. If you do not accept and agree with this Privacy Policy, you must stop using Our Site and the Services immediately.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

1. Definitions and Interpretation:
In this Policy, the following terms shall have the following meanings:

2. Information About Us:

2.1.1 Our Site, SkipperMyBoat.com, is operated by SkipperMyBoat Inc.

2.1.2 If you have any questions about this Privacy Policy or Our Site or Services, please contact us at: [email protected]

By email: [[email protected]]By mail: [SKIPPERMYBOAT INC., 8 The Green, Suite A Dover, DE 19901] Or through the contact page in your Account.

2.1.3 You have the right to make a complaint at any time to the applicable supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

3. Scope – What Does This Policy Cover?

3.1.1 This Privacy Policy applies only to your use of Our Site and Services. It does not extend to any websites that are linked to or from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Information

The types of personal information we collect depend on the nature of your interaction with us. Information that we collect from you may include the following categories however not all, if any, of the examples shown may be collected by us in a particular category:

Usage 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 ("Usage Data").

This Usage Data may include information such as your computer’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 with a mobile device, this Usage Data may include information such as 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.

Location Data

We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

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 portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Third-Party Cookies. We use certain third-party cookies as identified in the Data Sharing section below.

We collect your personal information from the following sources:

- When you interact with our Site and our Services;
- Using cookies and automatic collection methods as described in this policy;
- When you contact us or receive communications from us;
- When you complete a transaction with us;
- If you share from the Site or post a comment or other content with a friend/contact on social media, we may collect your friend’s/contact’s name;
- We may receive information about you and your activities on and off the Site from third- party partners, such as information from a partner when we jointly offer services or from an advertiser about your experiences or interactions with them. We may add this information to the information we have already collected from you in order to improve the products and services we provide.

5. How Do We Use Your Data?

5.1.1 Your personal data is stored securely in accordance with the security details in section 6, below.

5.1.2 We use your data to provide the best possible products and services to you. This includes the following:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- 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

A) 5.1.3 In some cases, the collection of data may be a statutory or contractual requirement, and for Us to be able to use such data, We may be limited in the products and services that We are permitted to provide you without your consent.

B) 5.1.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message with information, news and offers on Our services (direct marketing). We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (ECDirective) Regulations 2003, as amended in 2004, 2011 and 2015. You will receive direct marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

C) 5.1.5 Advertisers whose content appears on Our Site may engage in what is known as “behavioral advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.

D) 5.1.6 Under GDPR, We will ensure that your personal data is processed lawfully, fairly, and transparently without adversely affecting your rights.

If you are in the European Economic Area (EEA) or the UK, Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights For payment processing purposes
- To comply with the law

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purpose for which we will use your personal data:

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. How and Where Do We Store Your Data?

6.1.1 We keep your data only for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention 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.

We 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 periods.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

6.1.2 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

6.1.3 We take steps to make sure your data is secure.

6.1.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to Us via the internet.

Your information, including Personal Data, 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 from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. We may transfer your data to third parties as set forth herein, but shall maintain responsibility for such data in cases of onward transfer to third parties as required under applicable law.

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

We will take all the 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.

7. Do We Share Your Data?

7.1.1 We do not sell your personal information to third parties; however, We contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business 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. These are Our obligations, and the obligations of the third party under the law.

We share your personal information with the following categories of third parties:

Business Partners and Affiliated Companies. We disclose personal information and other data with select partners who provide goods, services and offers that enhance your experience on the Site, or that we believe will be of interest to you.

Linked Accounts and Promotional Activity. We partner with certain third parties that allow you to enroll in their services or participate in their promotions. When you enroll in those services, we disclose your personal information and other data to those third parties. Data shared in this way will be governed by the third party’s privacy policy and not this Privacy Policy. Examples include Facebook (privacy policy at https://www.facebook.com/privacy/explanation), Twitter (privacy policy at https://twitter.com/en/privacy), Pinterest (privacy policy at https:// policy.pinterest.com/en/privacy-policy), and Instagram (privacy policy at https:// help.instagram.com/155833707900388).

Service Providers. We disclose personal information and other data to third-party service providers for the purposes described in this Privacy Policy. These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.

We currently contract with:

Intercom
Stripe Connect
Google Analytics

7.1.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

7.1.3 In certain circumstances, We may be legally required to share certain data held by Us which may include your personal information. For example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us. We may disclose your personal information in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Skipper My Boat
  • To prevent or investigate possible wrongdoing in connection with the Service To protect the personal safety of users of the Service or the public
  • To protect against legal liability

7.1.4 In the preceding twelve (12) months, We have disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • Personal information (under California statute).
  • Protected classification characteristics (under California or federal law).
  • Commercial information.
  • Internet or other similar network activity.
  • Geolocation data.
  • Sensory data.
  • Inferences drawn from other Personal Information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Affiliates
  • Service providers
  • Third parties to whom you authorize us to disclose your personal information in connection with products or services we provide you.

8. What Happens If Our Business Changes Hands?

8.1.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

8.1.2 We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.

9. How Can You Control Your Data?

9.1.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data.

9.1.2 We offer Site visitors a means to choose how we use the information provided. If you receive a marketing communication or promotion from us, you may opt-out of these communications at any time (i) by following the unsubscribe instructions included in the promotion (if sent by e-mail), or (ii) sending us an e-mail at the address noted in the Contact Information section in this Policy. If you are a California resident please see the contact options in “California Residents’ Exercising Access, Data Portability and Deletion Rights” below. If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), please see the “Your European Data Protection Rights” section below for more information.

9.1.3 You have the right to access and correct your personal information. If you want to review or correct your personal information, you can login to the Site and visit your account profile page, or you may send us an e-mail at the address noted in the Contact Information section in this Policy.

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it.

10.1.1 You may restrict your internet browser’s use of Cookies. For more information, see section 12.

10.1.2 When we have relied on consent as our lawful basis for processing your information, You may withdraw your consent for Us to use your personal data, as set out in section in 5, at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible service to you.

11. How Can You Access Your Data?

11.1.1 You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please Contact Us for more details at the following email:

[email protected]

12. What Cookies Do We Use and What For?

12.1.1 Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services/ products. For more details, please refer to section 5, above, and to section 12.6, below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

12.1.2 By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. We use third-party Cookies on Our Site for marketing and understanding our target audience. For more details, please refer to section 5, above, and to section 12.6, below. These Cookies are not integral to the functioning of Our Site.

12.1.3 All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

12.1.4 Certain features of Our Site depend on Cookies to function. EU Cookie Law deems these Cookies to be “strictly necessary.” These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.1.5 The following first-party Cookies may be placed on your computer or device:

'user'

- This cookie is used to keep you signed in between sessions and during your visit on our site.

'cookies_allow'

- A generic cookie to allow us to check whether you have previously consented to cookies on our domain.

12.1.6 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling Us to better understand how people use Our Site. However, while Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

12.1.7 The analytics service(s) used by Our Site use(s) the following Cookies:

12.1.8 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

12.1.9 You can choose to delete Cookies at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalization settings.

12.1.10 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

12.1.11 We provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom's use of cookies, please visit: https:// www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms- and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

12.1.12 The Stripe Connect Platform Agreement (“Connect Platform Agreement”) is an agreement between the legal entity (including sole proprietors) that you identified on the registration page (“you”) and Stripe. Your integration and use of Stripe Connect with your platform (“Platform”) are subject to your acceptance of the terms and conditions of this Connect Platform Agreement and the Stripe Services Agreement. By integrating and using Stripe Connect, you expressly agree to the terms and conditions of this Connect Platform Agreement, the Stripe Services Agreement, and any updates or modifications to either of those documents made from time to time by Stripe.

Summary of Your Rights under GDPR

If you are a resident of the European Economic Area (EEA) or the UK, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal information.

If you wish to be informed about what personal information we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • 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 information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your personal information.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Skipper My Boat relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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

14. Automated Decision-Making and Profiling:

14.1.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge such decisions under GDPR through requesting human intervention, expressing your own point of view, and obtaining an explanation of the decision from Us.

14.1.2 The right described in section 14.1 does not apply in the following circumstances:

A) The decision is necessary for the entry into, or performance of, a contract between You and Us;

B) The decision is authorized by law; or

C) You have given you explicit consent.14.1.3 Where We use your personal data for profiling purposes, the following shall apply:

A) Clear information explaining the profiling will be provided, including its significance and the likely consequences;

B) Appropriate mathematical or statistical procedures will be used;

C) Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and

D) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

15. Your California Privacy Rights

15.1.1 Under California law, a California resident with whom Skipper My Boat has an established relationship has the right to request certain information with respect to the types of personal information Skipper My Boat has shared with third parties for their direct marketing purposes (if any), and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. In response to a written request, Skipper My Boat is allowed to provide a cost-free means to opt-out of such sharing. Since Skipper My Boat does not provide your personal information to third parties for their direct marketing purposes, it is not necessary for us to establish this procedure; however, if you do not want Skipper My Boat to use your personal information to provide information about our programs, please follow the cost- free opt-out procedures in this policy.

15.1.2 Our Policy on “Do Not Track” Signals and Third-Party Website Tracking under the California Online Protection Act (CalOPPA)

  • We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
  • You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
  • We do not engage in the collection of Personal Data over time across third-party websites, and we do not permit third parties to gather information passively on our website for behavioral advertising purposes.

16. Children’s Privacy

16.1.1 Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

17. Contacting Us:

17.1.1 If you have any questions about Our Site or this Privacy Policy, please Contact Us by email at: [[email protected]], by telephone on [ +1 512-900-2374], or by post at [ 8 The Green St. A, Dover DE, 19901]. Please ensure that your query is clear, particularly, if it is a request for information about the data We hold about you (as under section 11, above).

18. Changes to Our Privacy Policy:

18.1.1 We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

[PRIVACY SHIELD]

California Residents’ Exercising Access, Data Portability and Deletion Rights

California residents have the right to request that Skipper My Boat disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer 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 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 (also called a data portability request).
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

California residents have the right to request that Skipper My Boat delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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 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.

If you are a California resident to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

EMAILING [[email protected]].
EMAILING [[email protected]].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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.

Non-discrimination

We will not discriminate against you for exercising any of your personal information rights. Unless permitted by applicable law, 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.

NEVADA PRIVACY RIGHTS

Nevada residents may opt out of the sale of their covered information, as those terms are defined in Nevada law, by submitting such request to our designated email address: [[email protected]]. Please note that we do not sell your covered information as defined by Nevada law.

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