UPDATED: March 30, 2023
Table of Contents
Information Company Collects About You
How We Use Your Personal Information
How We Share Information
Third Party Content and Links
General Audience Site
Do Not Track and Global Privacy Control Signals
NOTICE TO NEVEDA RESIDENTS
NOTICE TO VERMONT RESIDENTS
NOTICE TO VIRGINIA RESIDENTS
NOTICE TO CALIFORNIA RESIDENTS
Notice to Residents of the European Economic Area/UK/Switzerland
1. Information Company Collects About You
We may collect personal information from you directly, automatically when you visit the Services, and sometimes from third parties.
Personal Information You Provide
When you interact with our Services, we collect personal information that you choose to share with us. If you wish to use certain Services, you may be asked to create an account, which will require you to provide certain additional personal information. Similarly, you will be asked to provide certain additional personal information if you wish to contact us through the Services. The personal information that we collect can vary depending on which Service you utilize, for example:
When you interact with one of our cryptocurrency kiosks, we collect your name, phone number, and a picture of you for all transactions. Depending on the amount of the proposed transaction, we may collect additional personal information about you for identity verification, fraud prevention, and other internal business purposes, such as a selfie image which may be collected using facial recognition software (when you opt-in to collection of biometric data), in accordance with any applicable laws, your government ID/driver’s license, Social Security number, source of funds, and a second form of ID. You will be asked to provide additional verifying personal information depending on the size of the transaction. If you apply to host a cryptocurrency kiosk in your business, we ask you to provide personal information such as your name and phone number, W9 information (such as EIN or SSN), banking information (such as routing and account number), as well as information about your store.
When you interact with the Company Order Desk, we collect your name, phone number, and a picture of you, which may be collected using facial recognition software (when you opt-in to collection of biometric data), in accordance with any applicable laws. Depending on the amount of the proposed transaction, we may collect additional personal information about you, such as a selfie image, your government ID/driver’s license, Social Security number, source of funds, and a second form of ID. You will be prompted for such personal information depending on the size of the transaction.
When you contact us through the Services, or through our accounts on third party social media websites, with a question, a comment, or to sign up to receive communications about Company and its products and services from us, you will be asked to provide your name and email address. You can ask us to stop or start sending you such marketing messages at any time by following the instructions in the marketing messages you receive (e.g., following an “Unsubscribe” link in an email or texting “STOP” to stop marketing text messages) or otherwise by writing, electronic messaging or calling us.
When you comment on one of our blogs, you may be asked to provide name and email address, and username information.
In addition, some of the Services allow you to buy make purchases, in which case we will ask you to provide payment information (such as credit/debit card, or other associated card information), which may be processed by a third party payment processor. When you make purchases, we will also collect your transaction history.
Automatically Collected Information
We and third party business partners (including service providers and third-party advertising and analytics and similar companies) may use a variety of technologies that automatically or passively collect certain information (“Usage Information”) whenever you with the Sites, or otherwise interact with the Services. Usage Information may include:
your time zone, and location;
referrer addresses or advertisement;
the type and version of your web browser;
device identifiers including mobile advertising identifiers;
your operating system, hardware model, and browser; and
areas within the Services that you visit and the content you interact with.
In addition, we automatically collect your internet protocol (IP) address or other unique identifier for any computer, mobile phone, or other device you use to access the Services (“Device Identifier”). Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal information.
We also record page views (hit counts) and other general statistical and tracking information. We use this data to help us administer and operate our Services, to better understand how our users access and interact with the Services, and for security and monitoring purposes. We may also collect information to meet our regulatory obligations; for example, we may identify your IP address in order to ascertain and verify your residency status.
We may send email messages that use a “click-through URL” linked to content on our Services. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, simply do not click text or graphic links in the email.
We use the following types of tracking technologies (collectively referred to as “Tracking Technologies”) to automatically collect information when you interact with us online:
Cookies, Pixel Tags, and Similar Technologies
In particular, the Services use:
Third party advertising cookies and pixels. The ads appearing on this Site, if any, may be delivered to users by third-party network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding use of and traffic (including without limitation the pages viewed and the actions users take when visiting) and the effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as device identifier). Some of these parties may collect personal information over time when you visit the Services or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as device identifiers, hashed information, records of transactions you conduct on our Services or offline, and other types of de-identified or pseudonymized information with third-party advertising companies, analytics providers, and other vendors for advertising and analytics purposes. In addition, we and our third-party service providers may use this information to perform matching with third-party cookies in order to provide targeted online marketing. You may find more information on what cookies and similar technologies have been set and how to manage and delete them at https://youradchoices.com/control. For more information on advertising cookies, please also consult the Network Advertising Initiative’s online resources at http://www.networkadvertising.org. If you do not want Twitter specifically to show you interest-based advertising on and off Twitter, you can visit your Twitter settings under Personalization and data, or visit the Digital Advertising Alliance’s consumer choice tool at optout.aboutads.info. If you do not want Facebook to show you interest-based advertising, you can visit Facebook settings under Your Ad Preferences on Facebook. For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. You may also download the AppChoices app at youradchoices.com/appchoicesto opt out of the delivery of interest-based advertisements in participating mobile apps. Certain states provide additional rights. Please see our sections for residents below for additional rights you may have. To opt out of certain cookies, please modify your cookie settings through the “Cookie Preferences” link in our website footer.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted advertisements while online.
Software Development Kits (SDKs)
SDKsarea software package that contain a set of tools that can be used to help build applications and implement new features in existing apps. These tools can be used to create and operate features that collect information from your device.
Data Collection from Mobile Devices.
We use embedded scripts and the tools provided in SDKs to collect information from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website usage behavior. In addition, we may use a variety of other technologies that collect similar information for security, fraud detection, and maintenance purposes.
We may capture session interactions with user interfaces for website analytics purposes, solely for our internal business purposes, to improve the Sites and our products and services.
When you participate in our Chat feature, we can record and use your communications and the information you provide in order to assist you during the Chat session, to improve our products and services, and otherwise as necessary to respond to your customer service inquiries.
We may collect your location information through our mobile applications by capturing the location (e.g., latitude/longitude) of your mobile device. If you have given the app permission to access your location at any time, we may collect your device’s location even if you are not using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to restrict the app’s access to your location data. Geolocation data may be used to enhance the Services, for example to offer additional functionality and information regarding your location in connection with the location of Company properties and to personalize the content you see on the Services.
2. How We Use Your Personal Information
We use your personal information for the following business purposes:
to process transactions that you have authorized us to make, including to fulfill and recover your orders such as to process your financial information and payment methods to complete your transactions;
to facilitate your activities with respect to our Services and to allow you to participate in the features of the Services we offer, including to register your account;
to customize and optimize the Services for you;
to contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments, questions, feedback or requests;
to verify and authenticate your identity, to help us ensure that the individuals who use the Services are who they claim to be;
for internal business purposes, such as to verify your identity, to prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including, for example, activities prohibited by the Anti-Money Laundering Act, and to protect ourselves and you from people violating our terms, or otherwise to protect our or third-party rights or interests, which may include sharing information with other companies, lawyers, courts, or other government entities;
to personalize your experience and tailor content we display to you, such as advertising, recommendations, promotions, and offers we display to you, both on the Services and elsewhere online;
to help us operate the Services, including to improve the Service which may include tracking traffic, usage, trends, and navigation patterns relating to your activities;
to deliver notices regarding your account, the services, content, features, or products you use or request, including to provide you with information concerning changes to the Services which may affect your account and/or your use of the Services – or in our discretion, changes to our policies;
to send you information we believe is relevant to you, such as news, bulletins, marketing materials, or other information;
to respond to subpoenas, court orders, or legal process – or to establish or exercise our legal rights or defend against legal claims;
to conduct user surveys and questionnaires;
to comply with Applicable Law; and
in any other way w describe to you when you provide the information, or otherwise with your prior consent.
3. How We Share Information
Service Providers. To assist us in running our business and to perform certain services and functions, your personal information may be disclosed, stored, and/or transferred (or otherwise made available) to third-party providers of services such as identification and background checks, cloud-based information hosting and maintenance, website hosting, record keeping, payment processing, transfer agent, email communication and customer support services, analytics, marketing, and advertising service providers, and to exchanges, trading platforms, and financial institutions.
For Legal and Compliance Reasons. We and our service providers may share your personal information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, such as a warrant, subpoena, or other court order, or to protect against fraud, illegal activity, or as otherwise required or permitted by applicable domestic or international laws or legal processes. Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property, or to otherwise protect the rights, property, safety, or security of Company, users of the Services, and others. We may also use device identifiers, such as IP addresses, to identify users in cooperation with copyright owners, Internet service providers, website service providers, and/or law enforcement agencies, in our discretion and in accordance with applicable laws.
Sweepstakes, Contests, Promotions. We may offer sweepstakes, contests or other promotions (any, a "Promotion"), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, without limitation and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion's terms or official rules (such as on a winners list).
In Connection with a Corporate Transaction. Your personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Company or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship. Your personal information may also be one of the transferred assets as part of the transaction or bankruptcy. We may also share your personal information in the diligence process or to otherwise facilitate any such transaction, and with individuals assisting in the transaction or in connection with a bankruptcy.
For Safety & Security. We may reveal your personal information to third parties, including law enforcement agencies, in order to protect the safety and security of our users or of any third party.
4. Social Media
We may offer you the opportunity to interact with and engage with our content on or through third-party social networking websites, plug-ins and applications, for example “liking” or “sharing” content from the Services, posting your social media posts to the Services, or including a hashtag associated with us in your social media post (“Social Media Features”). When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture and gender) to deliver the content or as part of the operation of the Services, plug-in or application.If others give us access to their profile, page, or other content on a third-party platform, we may also receive information about you if it is accessible through that content.
If you use Social Media Features, your interaction and personal information may be publicly disclosed on the Services and on the third-party platform. Your use of Social Media Features is subject to our Terms of Service.
5. User Submissions
Feedback, Questionnaires and Surveys
Our Services allows site visitors and customers to participate in surveys and questionnaires, which from time to time we may post on the Services. We also encourage our users to provide feedback to us about our Services. You are free to choose whether you participate in these activities. We may ask that, in addition to providing your responses, you also provide us with your contact information. In these instances, we use any personal information you choose to provide to us in connection with these activities for the purposes for which you submit the information.
We aggregate information derived from survey and questionnaire information – with your personal information removed – for monitoring or improving the use and appeal of the Services (with no other obligation to you and, specifically, with no obligation to compensate you for these uses). You are not obligated to participate in any of these activities and, if you undertake these activities, you will have the ability to opt-out as provided below.
6. Third Party Content and Links
Company is not responsible for the privacy practices of third party sites, and we encourage you to be aware when you leave our site and to read the privacy statements of each and every web site that collects personal information.
7. Data Security
We have put in place commercially-reasonable administrative, technical, and physical measures in an effort to prevent unauthorized access to or disclosure of personal information, and we take reasonable steps to secure and safeguard this Information against loss, theft, and unauthorized use, disclosure, or modification. With that said, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. For example, email sent to or from the Services may not be secure. Before submitting any personal information via the Site, please be aware of these inherent risks and understand that you do so at your own risk.
8. Data Retention
to do so in connection with your account, or as required by law (e.g., for tax, legal, compliance, regulatory, accounting or other purposes), whichever is longer.
9. Your Choices
Depending on the functionality associated with the Services feature you are using, you may be able to update or delete certain of your personal information on the Services. We will take reasonable steps to make requested changes in our active databases. Note, however, that we may retain information that you have updated or deleted in backup systems or for internal or administrative purposes and for other reasons to the extent allowed by applicable law, such as to resolve disputes, troubleshoot problems and enforce our Terms of Service.
Any deletion requests may be sent to [email protected]
If Company offers and you choose to sign-up to communicate with us via text message, you may unsubscribe by replying "STOP."
You can also turn off push notifications in your device settings.
10. General Audience Site
This Services are not directed to children younger than the age of 18. We do not knowingly seek to collect or maintain personal information or other information from children younger than the age of 18. We will use commercially reasonable efforts to delete any personal information or other information later determined to be provided by a child younger than the age of 18. If you become aware that a minor has provided personal information through our Services, please email us at [email protected].
12. “Do Not Track” and Global Privacy Control Signals
Do Not Track
Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. When you choose to turn on the “Do Not Track” setting in your browser, your browser will send a signal to websites, analytics providers, advertisement networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity. To find out more about and set up “Do Not Track,” please visit http://www.allaboutdnt.com.
Global Privacy Control
Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking. To find out more about and set up GPC, please visit https://globalprivacycontrol.org/#about.
13. Contact Us
14. NOTICE TO NEVADA RESIDENTS
Company does not currently sell your covered information as those terms are defined under applicable Nevada law. You may still submit an opt-out request and we will honor that request as required by Nevada law if Company were to engage in such a sale in the future. If you are a Nevada resident and would like to opt-out of the sale of your covered information, please submit your request to [email protected] Your request must include your full name and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via such email address us as needed regarding this request. If you previously provided a phone number to us, including it in your Nevada Opt-Out request email will assist us in identifying you and processing your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request.
15. NOTICE TO VERMONT RESIDENTS
If you are a Vermont resident, we will not share personal information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account, or for joint marketing. We will not share personal information about your creditworthiness with our affiliates or for joint marketing other than as permitted by Vermont law, unless you authorize us to make those disclosures.
16. NOTICE TO VIRGINIA RESIDENTS
If you are a Virginia Consumer and would like to exercise your rights pursuant to the Virginia Consumer Data Protection Act (VCDPA), and any implementing regulations adopted thereunder, please email [email protected] or call 1-877-757-2646 to submit a request.
Virginia Consumers have the following rights, all subject to the meanings and exceptions set forth in the VCDPA:
To confirm whether we are processing your Personal Data and request to access such data ("Right to Access").
That we correct inaccurate Personal Data we hold about you (“Right to Correct”).
That we delete the Personal Data provided by you or obtained about you ("Right to Delete").
To obtain a copy of the Personal Data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability (“Right to Obtain”).
To opt-out out of: the processing of your Personal Data for the purposes of targeted advertising (“Right to Opt-Out of Targeted Advertising”).
*Company engages in online advertising practices (and certain analytics or similar activities) that may be considered “targeted advertising” under the VCDPA. To opt out of certain tracking cookies set by 3rd parties that may be considered targeted advertising under the VCDPA, please modify your cookie settings by clicking the “Cookie Preferences” link in our website footer.
Pursuant to the VCDPA, if, for any reason, you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by completing this form please email [email protected] or call 1-877-757-2646. Please include your full name, the basis for your appeal, and any additional information to consider.
17. NOTICE TO CALIFORNIA RESIDENTS
This California Privacy Notice is effective as of March 30, 2023.
EXERCISING YOUR CALIFORNIA RIGHTS
California Consumers have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know”); (2) that we delete the Personal Information we collect about you (“Right to Delete”); (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”), (4) to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”), (5) to opt-out from the sale of their Personal Information and Sensitive Personal Information (“Right to Opt-Out of Sale”), and (6) that we limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit The Use and Disclosure of Sensitive Personal Information”), all subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.
In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
Verifying Your Requests
We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making.
When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
If you are an authorized representative submitting a request on a user’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
Right to Know
California Consumers have the right to know what information we have collected about you (the categories and the specific pieces of information).
If you are a California Consumer and would like to exercise your Right to Know, please submit your request by emailing [email protected] or by calling us toll-free at 1-877-757-2646.
In order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
Right to Delete
California Consumers have the right to request that we delete information we have collected from you. If you are a California Consumer and would like to exercise your Right to Delete, please submit your request by emailing [email protected] or by calling us at 1-877-757-2646.
Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.
Right to Correct Inaccurate Information
California Consumers have the right to request that we correct inaccurate information we hold about you. If you are a California Consumer and would like to exercise your Right to Correct, please submit your request by emailing [email protected] or by calling us at 1-877-757-2646.
Right to Limit The Use and Disclosure of Sensitive Personal InformationAs disclosed in the chart below, we may collect certain information which is considered Sensitive Personal Information under California law. This includes: SSN, government ID and passport information, racial or ethnic origin, religious or philosophical beliefs; sexual orientation, precise geolocation data, and biometric information (collected solely for identity verification and fraud prevention purposes). If you are a California Consumer and would like to limit our use or disclosure of such Sensitive Personal Information, please submit your request by emailing [email protected] or by calling us at 1-877-757-2646.
Do Not Sell or Share for Cross Context Behavioral Advertising
California Consumers have the right to opt-out of the sale of your Personal Information (Company does not sell Personal Information for monetary compensation) and to opt-out of the sharing of your Personal Information or Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising). If you are a California Consumer and would like exercise your Right to Opt-Out of the Sale and Sharing of your Personal Information, please submit your request by emailing [email protected] or by calling us at 1-877-757-2646.
Cookie Based Opt-Outsfor Do Not Sell or Share
Olliv engages in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising as defined in the CCPA and CPRA. To opt out of certain tracking cookies set by 3rd parties that may be considered "sales" or “sharing” under the CCPA and CPRA, please modify your cookie settings by clicking the “Cookie Preferences” link in our website footer.
In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of personal information by some or all of the participating companies: https://www.privacyrights.info/.
Company criteria for determining the period of time in which we will retain Personal Information also considers the time period reasonably necessary to: provide the Services to you; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our terms for use of the Services; and comply with legal and regulatory requirements.
Users Younger Than 18
Company does not knowingly Sell or Share Personal Information of users younger than under 18 years of age.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California consumers have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising your CCPA and CPRA rights.
Notice of Financial Incentive Under California regulation, certain aspects of our loyalty and similar programs, which provide benefits to consumers, may be considered a financial incentive program. We collect personal information from you in connection with our loyalty program, e.g. contact information (name, email address, residential address) and commercial information (like purchase history) for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, and to fulfill your requests associated with the program. To opt into our loyalty or similar programs, as set forth herein you will need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with the loyalty or other similar programs. Participation in our loyalty or other similar programs is voluntary and you can withdraw at any time. To the extent that we provide programs that may be considered a financial incentive because the program is directly or reasonably related to the collection, deletion or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program.
PERSONAL INFORMATION WE COLLECT
The Personal Information we collect about you will depend upon how you use our Services or otherwise interact with us. Accordingly, we may not collect all of the below information about you.
In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.
Contact for More Information
By Email: [email protected]
By Mail (US):
CoinFlip – Olliv
433 W. Van Buren St. Suite 1050N
Chicago, Illinois 60607
Other California Privacy Rights /“Shine the Light” Law
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for such third parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. However, Company does not share your Personal Information with third parties for their direct marketing purposes.
18. Notice to Individuals Located in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland
If you are a resident of the European Union or other EEA countries, or of the UK or Switzerland, the following information applies.
Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Services. We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy.
Right to lodge a complaint: Users that reside in the EEA, UK, or Switzerland have the right to seek information and assistance or lodge a complaint about our data collection and processing actions with the supervisory authority where they reside. Contact details for data protection authorities are available here. EEA: https://edpb.europa.eu/about-edpb/board/members_en, UK: https://ico.org.uk/, Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html.
Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 45-49 of the GDPR.
Withdraw consent: If we have collected personal information with your consent, you have the right to withdraw that consent at any time.
Access: You have the right to request access to personal information we collected about you and information about its sources, purposes, and sharing.
Correction: You have the right to request that we correct the personal information we hold about you if it is inaccurate or incomplete.
Erasure: You have the right to request that we erase data we have collected from you. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated, e.g., because of a legal obligation or right to retain it.
Portability: You have the right, in certain circumstances, to request that we provide your personal information to you in a format that can be transferred to another entity.
Restrict Processing: You have the right, in certain circumstances, to request that we limit our processing of your personal information if you are (1) contesting the accuracy of your personal information, (2) asserting that our processing is unlawful; (3) asserting that we no longer need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing.
Object: You have the right to object to our processing if we are processing your personal information based on legitimate interests, using your personal information for direct marketing (including profiling), or processing your personal information for purposes of scientific or historical research and statistics.
Automated Decision-making: You have the right, in certain circumstances, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you.
Verification Procedures: We must verify your identity for everyone’s protection, so we may require you to provide us with verification information prior to accessing any records containing personal information about you. We do this by:
Asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone account stated in the request; or
Having you submit your request through your account page, which will automatically verify your identity and will result in faster processing of your request.
We will use the information you provide for verification only for the purpose of verification. We may have a reason under the law why we do not have to respond to your request or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
19. Prevailing Language
In the event this document is available in multiple languages, the English version of these Terms represents the understanding of both Parties. Any other version is provided as a translation. In the event of conflict between the two versions, the English version shall be controlling.