Privacy Policy
Last Updated: 09/01/2024
This Privacy Policy describes Our policies and procedures regarding the collection, use, and disclosure of your information when you use the Service and informs You of your privacy rights and how the law protects you.
We use your personal data to provide and improve the Service. By using the Service, You consent to the collection and use of information in accordance with this Privacy Policy.
Please read this Privacy Policy carefully before using our service.
1 - Interpretation and definitions
1.1 - Interpretation
Words whose initial letter is capitalized have meanings defined under the following conditions. The following definitions will have the same meaning regardless of where they appear in the singular or plural.
1.2 - Definitions
For the purposes of this Privacy Policy:
● Account means a unique account created for You to access our Service or portions of our Service.
● Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
● Application means the software program provided by the Company or the Operator downloaded by You on any electronic device, called Chapinisima.com and its various pages, and/or stores.
- ●Business means the Company or Operator 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.
- ●You means the person accessing or using the Service, or the company, or other legal entity on behalf of which such person is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You may be referred to as the Data Subject or as the User, as you are the person using the Service.
- ●An order is a request by you to purchase or exchange products on the App or Website.
Company (referred to as "the Company", "the Operator", "We", "Us" or "Our" in this Agreement) refers to Wise2Win LLC, whose registered address is 7208 W Sand Lake Road Suite 305, Orlando, Florida.
● Consumer, refers to You.
● Cookies are small files that a website places on your computer, mobile device, or any other device, containing the details of your browsing history on that website among its many uses.
● Country refers to Guatemala or the United States depending on the country in which the purchase is being made.
● The Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company or Operator as the legal person that alone or jointly with others determines the purposes and means of the realization of Personal Data.
● Device means any device that can access the Service, such as a computer, cell phone, or digital tablet.
● Do Not Track (DNT) is a concept that has been promoted by regulatory authorities in the United States, in particular the United States Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism that allows Internet users to control the tracking of their online activities on websites.
● Operator (referred to as "the Operator", "We", "Us" or "Our" in this Agreement) refers to Chapinisima.com and its various storefronts. For the purposes of the GDPR, the Company or Operator is the Data Controller.
● Personal data is any information relating to an identified or identifiable individual. For the purposes of the GDPR, Personal Data means any information relating to you, such as a name, identification number, location data, online identifier, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity. For purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or can be associated with, or that can reasonably be linked, directly or indirectly, with you.
● GDPR: General Data Protection Regulation established by the European Union.
● CCPA: College of Public Accountants and Auditors of Guatemala.
● Sale, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or to a third party for monetary or other valuable consideration.
● The Service refers to the Application or the Website or both.
● Storefront: This is the part of the business where online shoppers see and interact.
● Service Provider means any natural or legal person who processes data on behalf of the Company or Operator. Refers to third-party companies or individuals employed by the Company or Operator 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 or Operator in analyzing how the Service is used. For the purposes of the GDPR, service providers are considered data processors.
Third-Party Social Media Service means any website or social networking website through which a User may 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's own infrastructure (e.g., the duration of a page visit).
● Website refers to the web page located on the net as Chapinisima.com, in its various storefronts, accessible from https://chapinisima.com/
2 - Contact Us
If you have any questions about these Terms of Service, you can contact us:
• By email:
- For billing: [email protected]
- For warranty requests, refunds and returns: [email protected] o For customer service (questions regarding the use of the Service):
● By visiting this page on our website: https://chapinisima.com/
3 - Collection and use of your personal data
3.1 - Types of data collected
3.1.1 - Personal data
When using Our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
● Email address
● Name and surname
● Phone Number
● Address, State, Province, Zip Code, City
● Bank account information
● Credit card number and expiration date
Usage Data
3.1.2 - Usage Data
Usage Data is collected automatically when you use 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 your diagnostic data.
When you access the Service through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique ID of your mobile device, 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 through a mobile device.
3.1.3 - Information from Third-Party Social Media Services
The Company or the Operator may allow you to create an account and log in to use the Service through the following Third-Party Social Media Services. These Third-Party Social Media Services may include, but are not limited to:
• Apple
- •YouTube
If you choose to register through or grant us access to a Third-Party Social Media Service, we may collect personal data that is already associated with your Third-Party Social Media Service account, such as your name, email address, activities, or contact list associated with that account.
You may also have the option to share additional information with the Company or Operator through Your third-party Social Media Service account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company or Operator permission to use, share, and store it in a manner consistent with this Privacy Policy.
3.1.4 - Tracking Technologies and Cookies
We use cookies and similar tracking techniques to track activity on our service and store certain information. The 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 settings to refuse cookies, our Service may use cookies.
● Web beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags, and singlepixel gifs) that allow the Company or Operator, for example, to count users who have visited those pages or opened an email and for other related applications or website statistics (e.g., record the popularity of a certain section and verify the integrity of the system and the server).
Cookies can be either "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 session and persistent cookies for the purposes detailed below:
● Necessary/Essential Cookies Type:
Session CookiesManaged by: UsPurpose: These cookies are essential to provide you with the services available through the App or Website and to enable you to use some of its features. They help authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services you have requested cannot be provided, and we only use these cookies to provide you with those services.
● Cookies Policy / Acceptance Notice Type of cookies:
Persistent cookiesManaged by: UsPurpose: These Cookies identify whether users have agreed to the use of cookies on the Application or Website.
● FunctionalityCookies Type: Persistent t Cookies managed by: WePurpose: These cookies allow us to remember choices you make when you use the App or 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 prevent you from having to re-enter your preferences each time you use the App or Website.
● Tracking and Performance CookiesType: Persistent CookiesManaged by: Third PartiesPurpose: These cookies are used to track information about traffic to the App or Website and how users use the App or Website. The information collected through 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 App or the Website. We may also use these Cookies to test new pages, features or new functionalities of the App or Website to see how our users react to them.
3.2 - Use of your personal data
The Company or Operator may use Personal Data for the following purposes:
● To provide and maintain our Service, including to monitor the use of our Service.
● To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide may 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, performance and performance of the contract for the purchase of the products, items or services You have purchased or any other contract with Us through the Service.
● To contact you: To contact you by email, phone calls, SMS, or other equivalent forms of electronic communication, such as push notifications from a mobile application about updates or informational communications related to contracted functionalities, products, or services, including 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 we offer that are similar to those you have already purchased or enquired about, unless you have opted out of receiving such information.
● To manage your requests: To fulfill and manage your requests to us.
● To send you targeted advertising: We may use your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and/or location and to measure their effectiveness.
● 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 we hold about users of our Service is among the assets transferred.
● To fulfill or fulfill 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 government regulations.
● As described to you when collecting your personal information or as set forth in the CCPA.
● For administrative and internal audit purposes.
● To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, where necessary, prosecuting those responsible for such activities.
- ●For Other Purposes: We may use your information for other purposes, such as analyzing data, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing, and your experience.
- ●With service providers: We may share your personal information with service providers to monitor and analyze the use of our service, to advertise to you on third-party websites after you have visited our service, for payment processing, to contact you.
- ●With your consent: We may disclose your personal information for any other purpose with your consent.
We may share your personal information in the following situations:
● For Business Transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company or Operator 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 comply with 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 of you. 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 see descriptions of your activity, communicate with you, and view your profile.
Please note that the examples provided above are illustrative and not exhaustive. For more details on how we use this information, please see the "Use of Your Personal Data" section.
If we decide to collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.
3.3 - Retention of your personal data
The Company or Operator will retain Your Personal Data only for as long as 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 or Operator 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 security or to improve the functionality of our service, or we are legally required to retain this data for longer periods of time.
Where your personal data is no longer required by law or the rights or obligations of us or you, we will delete the personal data. In most cases, Personal Data will be deleted upon termination or expiration of the agreement between You and the Company or Operator or upon written request.
3.4 - Transfer of your personal data
Your information, including Personal Data, is processed at the Company's or the Operator's operational offices and at any other location 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 data protection laws may differ from those in your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your acceptance of that transfer.
The Company or Operator 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 country unless there are appropriate controls in place, including the security of Your data and other personal information.
3.5 - Deleting your personal data
You have the right to delete or request that we assist in deleting the Personal Data we have collected about you.
Our Service may give you the ability to delete information about You from within the Service.
You may update, modify, or delete your information at any time by logging into your account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information you have provided to us.
Please note, however, that we may need to retain certain information where we have a legal obligation or basis to do so.
3.6 - Disclosure of your personal data
3.6.1 - Commercial transactions
If the Company or Operator is involved in a merger, acquisition, or sale of assets, Your Personal Data may be transferred. We will notify you before your personal data is transferred and becomes subject to a different Privacy Policy.
3.6.2 - Law enforcement
Under certain circumstances, the Company or the Operator may be required to disclose Your Personal Data if required to do so by law or in response to valid requests from public authorities (e.g., a court or government agency).
3.6.3 - Other legal requirements
the Company or Operator 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 or Operator
● Prevent or investigate potential wrongdoing in connection with the Service
● Protect the personal safety of Service Users or the public
- ●Protect Yourself Against Legal Liability
3.7 - Security of your personal data
The security of your personal data is important to us, but please 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.
4 - Detailed information on the processing of your personal data
The service providers we use may have access to your personal data. These third-party providers collect, store, use, process, and transfer information about your activity on our service in accordance with their privacy policies.
4.1 - Analysis
We may use third-party service providers to monitor and analyze the use of our Service. They may include, but are not limited to:
● 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 data collected to contextualize and personalize ads from its own ad network. You may opt out of making our activity on the Service available to Google Analytics by installing the Google Analytics Opt-Out Browser Add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about activity on the services. You may opt out of certain Google Analytics features through your mobile device settings, such as your device's advertising settings or by following the instructions provided by Google in its Privacy Policy: https://policies.google.com/pr... For more information about Google's privacy practices, please visit Google's privacy and terms webpage: https://policies.google.com/privacy
● Matomo
Matomo is a web analytics service. You can visit their Privacy Policy page here:
https://matomo.org/privacy-policy
● Fathom
Fathom is a web analytics service. You can visit their Privacy Policy page here:
https://www.fathomhq.com/privacy
4.2 - 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 (you can see the bottom of the email for specific steps to stop receiving these emails) or by contacting us.
We may use email marketing service providers to manage and send you emails. They may include, but are not limited to:
● Mailchimp
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. To learn more about Mailchimp's privacy practices, please visit their Privacy Policy:
https://mailchimp.com/legat/privacy/
4.3 - Payments
We may provide paid products and/or services within the Service. In that case, we may use thirdparty 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 administered by the PCI Security Standards Council, which is a joint effort of brands such as Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
They may include, but are not limited to:
● Stripe
Your Privacy Policy can be viewed on https://stripe.com/us/privacy
● PayPal's Privacy Policy can be viewed on https://www.paypal.com/us/webapps/mpp/ua/privacy-full
● Tigo Money's Privacy Policy can be viewed on https://www.tigo.com.gt/legales/terminos-y-condiciones#tigo-tigo-money-terminos-ycondiciones
● Pay By Link
Your Privacy Policy can be viewed on https://paybylink.com/en/privacy-policy/
4.4 - Behavioral Geomarketing
The Company or Operator uses geomarketing services to advertise to you after you accessed or visited our Service. We and our third-party vendors use cookies and non-cookie technologies to help us understand your device and understand how you use our Service so that we can improve our Service to reflect your interests and show you advertisements that are likely to be of most interest to you.
These third-party providers collect, store, use, process, and send information about your activity on our service in accordance with their privacy policies and to enable us to:
● Measure and analyze traffic and browsing activity on our service
● Show you advertisements for our products and/or services on third-party websites or applications
● Measure and analyze the performance of our advertising campaigns.
Some of these third-party providers may use non-cookie technologies that may not be affected by browsing settings that block cookies. Your browser may not allow you to block such technologies. You may use the following third-party tools to opt out of the collection and use of information for the purpose of serving you interest-based advertising:
● The NAI's out-put platform: http://www.networkadvertising.org/choices/
● The EDAA opt-out platform http://www.youronlinechoices.com/
● DAA Opt-Out Platform: http://optout.aboutads.info/?c=2&lang=EN
You can opt out of all personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ad Personalization (Android). Please refer to your mobile device's help system for more information.
We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party providers. This allows our third-party vendors to recognize and deliver ads to you across devices and browsers. For more information about the technologies used by these third-party providers and their cross-device capabilities, please see each provider's Privacy Policy listed below.
The third-party providers we may use are, but are not limited to:
● Google Ads (AdWords)
The Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt out of Google Analytics for display advertising and personalize Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-Out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for your web browser. Google Analytics Optout Browser Add-on gives visitors the ability to prevent their data from being collected and used by Google Analytics. For more information about Google's privacy practices, please visit Google's privacy and terms webpage: https://policies.google.com/privacy
● Twitter' s Twitter remarketing service is provided by Twitter Inc. You can opt out of
Twitter's interest-based ads by following its instructions: https://support.twitter.com/articles/20170405
You can learn more about Twitter's privacy practices and policies by visiting its Privacy Policy: https://twitter.com/privacy
● Facebook/Meta' s Facebook or Meta remarketing service is provided by Facebook Inc. and Meta Inc. You can learn more about Facebook's interest-based advertising by visiting this page: https://www.facebook.com
To opt out of receiving interest-based ads from Facebook, please follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Advertising Behavior set forth by the Digital Advertising Alliance. You may also opt out of Facebook and other participating companies through the Digital Advertising Alliance in the U.S. http://www.aboutads.info/choic.... You can choose from the U.S., the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out in your mobile device settings. For more information about Facebook's privacy practices, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
● PinterestPinterest' s remarketing service is provided by Pinterest Inc. You can opt out of Pinterest's interest-based ads by enabling your web browser's "Do Not Track" functionality or by following Pinterest's instructions: http://help.pintere st.com/en/articles/personalization-and-data
You can learn more about Pinterest's privacy practices and policies by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy
4.5 - Usage, Performance and Miscellaneous
We may use third-party service providers to provide better improvement of our Service. They may include, but are not limited to:
● Intercom
Your Privacy Policy can be viewed on https://www.intercom.com/legal/privacy
● FacebookMessenger Your privacy policy can be viewed on https://www.facebook.com/privacy/policy
● Zendesk
Its Privacy Policy can be found at https://www.zendesk.com/company/agreements-andterms/privacy-notice/
● Tawk
Your Privacy Policy can be viewed in https://www.tawk.to/privacy-policy/
5 - 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 site. We encourage you to review the Privacy Policy of each 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.
6 - GDPR Privacy
6.1 - Legal basis for processing personal data under GDPR
We may process Personal Data under the following conditions:
● Consent: You have consented to the processing of Personal Data for one or more specific purposes.
● Performance of a contract: The provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
● Legal obligations: The processing of Personal Data is necessary to comply with a legal obligation to which the Company or Operator is subject.
● Vital interests: The processing of personal data is necessary to protect your vital interests or those of another natural person.
● Public interests: The processing of personal data is related to a task that is carried out in the public interest or in the exercise of an official authority vested in the Company or Operator.
- ●Legitimate interests: The processing of personal data is necessary for the purposes of the legitimate interests pursued by the Company or the Operator.
In any case, the Company or the Operator will be happy to help clarify the specific legal basis that applies to the processing and, in particular, whether the provision of Personal Data is a legal or contractual requirement, or a requirement necessary to enter into a contract.
6.2 - Your rights under the GDPR
The Company or Operator undertakes to respect the confidentiality of Your Personal Data and to ensure that You can exercise Your rights.
You have the right under this Privacy Policy, and by law if you are located within the EU, to:
● Request access to your personal data. The right to access, update, or delete the information we hold about you. Whenever possible, you can access, update, or request deletion of your personal data directly in the settings section of your account. 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 we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
● Object to the processing of your personal data. This right exists where we rely on a legitimate interest as a 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 process your personal data for direct marketing purposes.
● Request deletion of your personal data. You have the right to ask us to delete or delete Personal Data where there is no good reason for us to continue processing it.
● Request the transfer of your personal data. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used and machinereadable format. Please note that this right only applies to automated information that you initially consented to us use when we use the information to perform a contract with you.
- ●Withdraw your consent. You have the right to withdraw your consent to the use of 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.
6.3 - Exercising Your GDPR Data Protection Rights
You can 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 do our best to respond to you as soon as possible.
You have the right to lodge a complaint with a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if you are located in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
7 - CCPA, CalOPPA, and California Privacy Rights
This section of the Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies only to all visitors, users, and others who reside in the State of California.
7.1 - Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, can be 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 that we may collect or that may have been collected from California residents in the past 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 have been collected by us, but rather reflects our good faith, to the best of our knowledge, that some of that information in 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.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: Yes.
● Category B: Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
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 report or health insurance information. Some of the personal information included in this category may overlap with other categories. Collected: Yes.
● Category C: Protected classification features under California or federal law. 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 family genetic information). Collected: No.
● Category D: Commercial information.
Examples: Records and history of products or services purchased or considered. Collected: Yes.
● Category E: Biometric Information.
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 ice prints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Order Collected: No.
● Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertising. Updo: Yes.
● Category G: Geolocation data.
Examples: Approximate physical location. Collected: No.
● Category H: Sensory data.
Examples: audio, electronic, visual, thermal, olfactory, or similar information. Collected: No.
● Category I: Professional or employment-related information.
Examples: Current or past work history or performance evaluations. Collected: No.
● Category J: Nonpublic education information (under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class rosters, student schedules, student identification codes, student financial information, or student discipline records. Collected: No.
● Category K: Inferences drawn from other personal information.
Examples: A profile that reflects a person's preferences, characteristics, psychological tendencies, predispositions, behavior, attitudes, intelligence, skills, and aptitudes. Collected: No.
Under CCPA, personal information does not include:
● Publicly available information from government records
● De-identified or aggregated consumer information
● Information excluded from the scope of the CCPA, such as:
○ Medical or health 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 the
California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
7.2 - 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 forms you fill out on our Service, preferences you express or provide through our Service, or from your purchases on our Service.
● Indirectly from you. For example, by observing your activity on our Service.
● Automatically from you. For example, through cookies that We or our Service Providers set on Your Device while You are browsing our Service.
- ●From service providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to deliver targeted advertising to you, third-party vendors for payment processing, or other third-party vendors we use to provide the Service to you.
7.3 - Disclosure of Personal Information for a Business or Commercial Purpose
We may use or disclose and may have used or disclosed in the past twelve (12) months the following categories of personal information for a business or commercial purpose:
● Category A: Identifiers
● Category B: Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
● 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 have been disclosed, but it rejects our good faith belief, to the best of our knowledge, that some of that information in the applicable category may be and may have been disclosed.
When we disclose personal information for a business or commercial purpose, we enter into a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except to perform the contract.
7.5 - Sale of Personal Information
As defined in the CCPA, "sell" and "sell" mean selling, renting, releasing, disclosing , disseminating, making available, transferring, or communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for consideration. This means that we may have received some form of benefit in exchange 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 rather reflects our good faith belief, to the best of our knowledge, that some of that information in the applicable category may be and may have been shared in exchange for value.
We may sell and have sold in the last twelve (12) months the following categories of personal information:
● Category A: Identifiers
● Category B: Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
● Category D: Commercial Information
- ●Category F: Internet or other similar network activity
7.6 - Sharing 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 the products or services We provide to You.
- ○The categories of personal information we collect about you
- ○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 perform our contract with You.
- ○Denying you goods or services
7.7 - Sale of Personal Information of Children Under the Age of 16
We do not knowingly collect personal information from children under the age of 16 through our Service, although certain third-party websites to which we link may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's internet use and instruct their children never to provide information on other websites without their permission.
We do not sell the personal information of Consumers we know to be under the age of 16, unless we receive affirmative authorization (the "right to opt-in") from the Consumer who is between 13 and 16 years of age, or from the parent or guardian of a Consumer under 13 years of age. Consumers who opt out of 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 allow us to delete that information.
7.8 - Your Rights Under the CCPA
The CCPA gives California residents specific rights regarding their personal information. If you are a California resident, you have the following rights:
● The right to notification. You have the right to be notified of what categories of Personal Data are being collected and the purposes for which the Personal Data is used.
● The right to request. Under the CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for a business purpose, and sharing of personal information. Once we receive and confirm your request, we will disclose to you:
○ The categories of sources of personal information we collect 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 collect 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 categories of personal information sold
■ The categories of categories of personal information disclosed
● The right to say no to the sale of Personal Data (opt-out). You have the right to tell us not to sell your personal information. To submit a departure 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 retention of the information is necessary for us or our service providers to:
○ 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 freedom of expression, guarantee 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 render impossible or seriously impair the research's achievement, if you previously provided informed consent.
○ Allow only 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 rights as a consumer, including:
○ Charging different prices or fees for goods or services, including using discounts or other benefits or imposing penalties
○ Provide you with a different level or quality of goods or services
○ Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
7.9 - Exercising Your CCPA Data Protection Rights
To exercise any of your rights under the CCPA, and if you are a California resident, you may 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 that you are the person about whom we collected personal information or an authorized representative
- ●Describe your request in sufficient detail to allow us to understand, evaluate, and respond to it appropriately
- ●And confirm that personal information relates to you
We cannot respond to your request or provide you with the required information if we are unable to:
● Verify your identity or authority to make the request
We will lose the disk and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period for providing the required information may be extended once for an additional 45 days when reasonably necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period prior to receipt of the verifiable request.
For data portability requests, we will select a format for providing your personal information that is readily usable and that allows you to transmit information from one entity to another entity without hindrance.
7.10 - 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 request from your consumer, we will stop selling your personal information. To exercise your right to opt-out, please contact us.
Service Providers with whom we partner (e.g., our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA. If you would like to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined in the CCPA, you may do so by following the instructions below.
Please note that any opt-out is specific to the browser you are using. You may need to opt out of all browsers you use.
7.10.1 – On Site
You may opt out of receiving personalized advertisements as served by our Service Providers by following our instructions presented on the Service:
● The NAI opt-out platform: http://www.networkadvertising.org/choices/
● The EDAA opt-out platform http://www.youronlinechoices.com/
● DAA Opt-Out Platform: http://optout.aboutads.info/?c=2&lang=EN
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 cookies saved by your browser, you will need to opt-out again.
7.10.2 - Mobile Devices
Your mobile device may give you the ability to opt out of using information about the apps you use to show you ads targeted to your interests:
● "Opting Out of Interest-Based Ads" or "Opting Out of Ad 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.
7.11 - "Do Not Track" Policy as Required by the California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites do track 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 wish to be tracked. You can enable or disable DNT by visiting your web browser's preferences or settings page.
7.12 - Your California Privacy Rights (California 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 may request information once a year about how we share their Personal Data with third parties for the third party's direct marketing purposes.
If you would like to request more information under the California Shine the Light law, and if you are a California resident, you may contact us using the contact information provided below.
8 - Privacy Rights of Children and Minors
8.1 - General Children's Privacy Rights
Our Service is not directed to anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you know that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, we take steps to delete that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires a parent's consent, we may require your parent's consent before collecting and using that information.
8.2 - California Privacy Rights for Underage Users (California Business and Professions Code Series 22581)
California Business and Professions Code Section 22581 permits 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 deletion of such data, and if you are a California resident, you may contact us using the contact information provided below and include the email address associated with your account.
Please note that your request does not guarantee complete or incomplete removal of content or information posted online and that removal may not be permitted or required by law in certain circumstances.
9 - 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 inform You via email and/or a prominent notice on Our Service, before the change becomes effective and we will update the "Last Updated" date at the top of this Privacy Policy.
We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.
