Privacy policy

I. INTRODUCTION

DEVMEAPP LLC, registered at 18401 COLLINS AVE 100-241 SUNNY ISLES BEACH, FL 33160 ("we," "us" or "our") takes your privacy seriously. This Privacy policy ("Privacy policy") explains our data protection policy and describes the types of information we may process when you install and/or use software application for mobile devices (the "App", "our App") and explains how we and some of the companies we cooperate while processing that information.

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy policy applies to all users, and others who access the App ("Users").

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

PLEASE READ the FOLLOWING PRIVACY POLICY, for INFORMATION REGARDING the WAYS YOUR PERSONAL INFORMATION MAY be PROCESSED, CAREFULLY. WHEN YOU USE the APP YOU ACKNOWLEDGE that YOU HAVE READ, UNDERSTOOD, and AGREE TO be BOUND by THESE TERMS.

II. INFORMATION WE PROCESS

There are two general categories of information we can process.

II.1 Information that you submit

We process the following personal information about you when you use the App. This information is necessary for  the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.

  • Other Information directly related to your use of the App, such as photos and documents you upload to the App. Upon your consent we also may have access to your camera roll.

II.2 Information that is Processed Automatically

When you use the App, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data, we may not be able to provide you with all the requested services and features of the App.

We use third-party automatic data processing technologies to analyze certain information sent by your device or our App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise or respond for how the third parties process your personal data, that might be collected by their own means (not through our App). Due to the fact that some of our third parties declare themselves controllers for the purposes of the GDPR, any information request regarding your personal data should be directed to such third parties.

  • Information related to your device. When you use a mobile device to access our App, we may monitor one or more "device identifiers". Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. Device identifier enables generalized reporting or personalized content and ads by the third parties. What data can be processed:

  • type of your mobile device and operational system version which is installed on your mobile device;

  • region information of your mobile device;

  • region associated with your SIM card;

  • Internet Protocol ("IP") address;

  • Identity for Advertisers / Advertising ID which is a string of numbers and letters that identifies your individual smartphone or tablet.

  • Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App. The App may use automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements. Processing information through automatic data processing technologies starts automatically when you start using the App.

  • Cookies and similar technologies. When you use the App, we may use cookies and similar technologies like pixels, web beacons, scripts to process information about how you use our App and provide features to you. A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to our server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access a specific area or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.

III. The PURPOSES of PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) to make our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.

(b) to improve, test and monitor the effectiveness of our App. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

(c) to provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.

(d) to communicate with you. We use the information we have to communicate with you through newsletters, i.e., to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e) to prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise, we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING of YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy. We adhere to the U.S. Digital Advertising Alliance’s Self‑Regulatory Principles for the Mobile Environment.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third‑party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

We may engage the following third parties in order to provide us with necessary infrastructure for delivery and improvement of our services.

Our App may contain links to third-party websites / services or you may access the App from a third‑party site. We are not responsible for the privacy practices of these third‑party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

  • as required by law;

  • when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

  • if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

In the event of transferring personal data from the European Economic Area (EEA) to countries lacking an adequate level of data protection, we rely on one of the following legal bases: (i) Implementation of Standard Contractual Clauses approved by the European Commission, or (ii) Adherence to adequacy decisions made by the European Commission regarding specific countries (details accessible here).

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

VII. EXERCISING YOUR RIGHTS

For the personal data we store and access you are entitled to address us regarding the following issues:

  • Data Access and Portability. You can request copies of your personal information held by us.

  • Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask us to correct change, update or rectify your data.

  • Data Retention and Deletion. We generally retain data for as long as your account is in existence or as it is needed to provide services of the App. However, specific retention times can vary based on the context of the processing we perform and on our legal obligations. You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account at any time. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, or where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).

  • Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which we use your personal information.

Please bear in mind that we ensure the above‑mentioned rights only with respect to the information that you submit.

When your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third-party services listed in Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

Please note that you can opt-out of marketing tracking by choosing:

Please mind when you opt out of certain interest-based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

VIII. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through email or contact form displayed below.

IX. CHILDREN’S PRIVACY

Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

X. CHANGES to the PRIVACY POLICY

This Privacy policy will be regularly updated.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

XI. CONTACT INFORMATION

We reserve the right to respond to user support requests. If you want to submit a support request or have any questions about this Privacy Policy, please contact us using our support email [email protected]

CALIFORNIA RESIDENT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request: a) the categories of personal information that is processed; b) the categories of sources from which personal information is obtained; c) the purpose for processing of user personal data; d) the categories of third parties with whom we may share your personal information; e) the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above. Be informed that according to CCPA personal information does not include de-identified or aggregated consumer information.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

OPT-OUT OPTIONS. If you don’t want us to process your personal information any more, please contact us through [email protected]. Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above.

REQUESTS To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

OPT-OUT OPTIONS. If you don’t want us to process your personal information any more, please contact us through [email protected]. Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above.

CALIFORNIA PRIVACY RIGHTS.
  • The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months. Please, note that we shall not be required to provide personal information to you more than twice in a 12-month period.
  • The right to prohibit sale of information means that you have the right to request that we stop the processing of your data for direct marketing purposes either by asking us to cease processing all data about you or asking us not to send you direct marketing communications. We generally do not sell your Personal Information for profit.
  • The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
  • The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
  • The right to opt out of automated decision-making technologies means your right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
  • The right to restrict the use of your sensitive information means directly contacting us to stop such processing of your sensitive personal information for such purposes. We do not process any sensitive personal information to infer characteristics about you.
  • The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. Please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information if we need it to, among other things: (a) complete the transaction for which the personal information was collected, or (b) fulfill the terms of a written warranty or product recall; (c) detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (d) debug to identify and repair errors that impair existing intended functionality; (e) comply with the California Electronic Communications Privacy Act; (f) enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; (g) comply with a legal obligation. Otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information, etc.
  • The rights to portability means your right to receive your personal information in an electronic and structured form to you or to another party.

SALE OF DATAWe do not sell any of your personal data to third parties.

COLORADO RESIDENT NOTICE

This section applies only to Colorado residents in addition to the rest of this Privacy Policy. We process personal data in compliance with the Colorado Privacy Act that requires us to disclose the following additional information related to our privacy practices.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will provide you with the required information in an alternative format that you can access.

PERSONAL INFORMATION.All about the categories of information, its sources and purposes of processing is described above.

DATA SHARING.Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

COLORADO PRIVACY RIGHTS.
  • The right of access means the right to know if a controller is processing the consumer’s data.
  • The right to portability provides the ability for you to receive the data in their right to access in a portable and machine-readable format, where technically feasible, that enables you to transmit the data to another entity without hindrance. Please note that you may only exercise the right to data portability twice per calendar year.
  • The right to opt-out means your right to object to the processing of your personal data for such purposes as (1) the sale of your personal data. Please note that we do not sell any of your personal data to third parties; (2) Targeted advertising, or (3) Profiling to help make decisions that produce legal or similarly notable effects concerning a consumer.
  • The right of correction means your right to request that we rectify inaccurate information about you.
  • The right of deletion means that you can ask us to delete or stop processing your personal data.
  • The right of appeal means that if you are not satisfied with resolving your privacy request, you can initiate an appeal procedure described below.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts. If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee. If we refuse to take action on your request, you can follow the appeal procedure within 30 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”. We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps we are unable to verify your identity, we reserve the right to decline your rights request.

SALE OF DATA. We do not sell any of your personal data to third parties.

VIRGINIA PRIVACY NOTICE

The following section pertains exclusively to residents of Virginia. It outlines our practices regarding the collection, utilization, and sharing of Personal Data belonging to Virginia residents, in our capacity as a business operating under the Virginia Consumer Data Protection Act ("VCDPA"). Additionally, it outlines your rights in relation to your Personal Data. Please note that the term "Personal Data" used in this section holds the definition ascribed to it by the VCDPA, with the exception of information exempted from the VCDPA's scope.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

VIRGINIA PRIVACY RIGHTS. As a resident of Virginia, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

  • Correct inaccuracies in the consumer’s personal data that is collected by the controller.
  • Confirm if the controller is actually processing their personal data or request a copy of the personal data.
  • Delete personal data provided by or obtained about the consumer.
  • Obtain copies of the personal data collected by the controller.
  • Opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.
  • The right to restrict processing of your sensitive personal information. We do not process any sensitive personal information to infer characteristics about you.
  • You have the right to be free from discrimination related to your exercise of any of your Virginia privacy rights.
  • Appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts. If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee. If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”. We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps we are unable to verify your identity, we reserve the right to decline your rights request.

SALE OF DATA. We do not sell any of your personal data to third parties.

CONNECTICUT PRIVACY NOTICE

This notice outlines the manner in which we, acting as a "Controller" under Connecticut's Data Protection Act ("CTDPA"), collect, utilize, and disclose your personal data, as well as the rights you have concerning your personal data, including sensitive personal data. In this context, "personal data'' and "sensitive data'' carry the definitions provided in the CTDPA and do not encompass information excluded from the scope of the CTDPA.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTSTo submit a verifiable consumer request please contact us through the email [email protected]. Before processing most requests, we will need to verify your identity and confirm that you are a resident of the State of Connecticut. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. If you are submitting a request on behalf of a Connecticut resident, including a minor child, we will also need sufficient information to verify that the individual is the person about whom we collected personal data, and that you are authorized to submit the request on their behalf. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CONNECTICUT PRIVACY RIGHTS. As a resident of Connecticut, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations. Right to know. You have the right to verify whether we are processing your personal data or not. Right to deletion. You have the right to request the deletion of your personal data under certain circumstances. If you make such a request, we will assess whether we are legally obligated to comply or if there are reasons that limit the scope of the deletion. If there are any reasons, we will provide you with an explanation in our response. Right to access. The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible. The right to opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling. The right to ppt out of profiling. You have the right to choose not to have your personal data processed for profiling purposes that could lead to decisions with significant legal or similar effects on you. If you wish to exercise this right, you can opt out of such profiling activities. The right to appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

Last updated: June 26, 2024