Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about 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 agree to the collection and use of information in accordance with
this Privacy Policy.

Interpretation and Definitions
——————————

Interpretation
~~~~~~~~~~~~~~

The words of which the initial letter is capitalized have meanings defined
under the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.

Definitions
~~~~~~~~~~~

For the purposes of this Privacy Policy:

* Account means a unique account created for You to access our Service or
parts 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 election of directors or other managing authority.

* Business , for the purpose of CCPA/CPRA, refers to the Company as the
legal entity that collects Consumers’ personal information and determines
the purposes and means of the processing of Consumers’ personal
information, or on behalf of which such information is collected and that
alone, or jointly with others, determines the purposes and means of the
processing of consumers’ personal information, that does business in the
State of California.

* CCPA and/or CPRA refers to the California Consumer Privacy Act (the
“CCPA”) as amended by the California Privacy Rights Act of 2020 (the
“CPRA”).

* Company (referred to as either “the Company”, “We”, “Us” or “Our” in this
Agreement) refers to oldtw.

For the purpose of the GDPR, the Company is the Data Controller.

* Consumer , for the purpose of the CCPA/CPRA, means a natural person who is
a California resident. A resident, as defined in the law, includes (1)
every individual who is in the USA for other than a temporary or
transitory purpose, and (2) every individual who is domiciled in the USA
who is outside the USA for a temporary or transitory purpose.

* Cookies are small files that are placed on Your computer, mobile device or
any other device by a website, containing the details of Your browsing
history on that website among its many uses.

* Country refers to: New York, United States

* Data Controller , for the purposes of the GDPR (General Data Protection
Regulation), refers to the Company as the legal person which alone or
jointly with others determines the purposes and means of the processing of
Personal Data.

* Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.

* GDPR refers to EU General Data Protection Regulation.

* Personal Data is any information that relates to an identified or
identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to
You such as a name, an identification number, location data, online
identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA/CPRA, Personal Data means any information
that identifies, relates to, describes or is capable of being associated
with, or could reasonably be linked, directly or indirectly, with You.

* Service refers to the Website.

* Service Provider means any natural or legal person who processes the data
on behalf of the Company. It refers to third-party companies or
individuals employed by the Company to facilitate the Service, to provide
the Service on behalf of the Company, to perform services related to the
Service or to assist the Company in analyzing how the Service is used. For
the purpose of the GDPR, Service Providers are considered Data Processors.

* Usage Data refers to data collected automatically, either generated by the
use of the Service or from the Service infrastructure itself (for example,
the duration of a page visit).

* Website refers to oldtw, accessible from
<https://oldtw.com/>

* You means the individual accessing or using the Service, or the company,
or other legal entity on behalf of which such individual is accessing or
using the Service, as applicable.

Under GDPR, You can be referred to as the Data Subject or as the User as
you are the individual using the Service.

Collecting and Using Your Personal Data
—————————————

Types of Data Collected
~~~~~~~~~~~~~~~~~~~~~~~

Personal Data
*************

While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:

* Email address

* First name and last name

* Phone number

* Usage Data

Usage Data
**********

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that You visit, the time and date of Your visit, the time spent on
those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, the type of
mobile device You use, Your mobile device unique ID, the IP address of Your
mobile device, Your mobile operating system, the type of mobile Internet
browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies
*********************************

We use Cookies and similar tracking technologies to track the activity on Our
Service and store certain information. Tracking technologies used are beacons,
tags, and scripts to collect and track information and to improve and analyze
Our Service. The technologies We use may include:

* Cookies or Browser Cookies. A cookie is a small file placed on Your
Device. You can instruct Your browser to refuse all Cookies or to indicate
when a Cookie is being sent. However, if You do not accept Cookies, You
may not be able to use some parts of our Service. Unless you have adjusted
Your browser setting so that it will refuse Cookies, our Service may use
Cookies.
* Web Beacons. Certain sections of our Service and our emails may contain
small electronic files known as web beacons (also referred to as clear
gifs, pixel tags, and single-pixel gifs) that permit the Company, for
example, to count users who have visited those pages or opened an email
and for other related website statistics (for example, recording the
popularity of a certain section and verifying system and server
integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on
Your personal computer or mobile device when You go offline, while Session
Cookies are deleted as soon as You close Your web browser. You can learn more
about cookies on [TermsFeed
website](https://www.termsfeed.com/blog/cookies/#What_Are_Cookies) article.

We use both Session and Persistent Cookies for the purposes set out below:

* Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services
available through the Website and to enable You to use some of its
features. They help to authenticate users and prevent fraudulent use of
user accounts. Without these Cookies, the services that You have asked for
cannot be provided, and We only use these Cookies to provide You with
those services.

* Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies
on the Website.

* Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use
the Website, such as remembering your login details or language
preference. The purpose of these Cookies is to provide You with a more
personal experience and to avoid You having to re-enter your preferences
every time You use the Website.

* Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the
Website and how users use the Website. The information gathered via these
Cookies may directly or indirectly identify you as an individual visitor.
This is because the information collected is typically linked to a
pseudonymous identifier associated with the device you use to access the
Website. We may also use these Cookies to test new pages, features or new
functionality of the Website to see how our users react to them.

* Targeting and Advertising Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies track your browsing habits to enable Us to show
advertising which is more likely to be of interest to You. These Cookies
use information about your browsing history to group You with other users
who have similar interests. Based on that information, and with Our
permission, third party advertisers can place Cookies to enable them to
show adverts which We think will be relevant to your interests while You
are on third party websites.

For more information about the cookies we use and your choices regarding
cookies, please visit our Cookies Policy or the Cookies section of our Privacy
Policy.

Use of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~

The Company may use Personal Data for the following purposes:

* To provide and maintain our Service , including to monitor the usage of
our Service.

* To manage Your Account: to manage Your registration as a user of the
Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered
user.

* For the performance of a contract: the development, compliance and
undertaking of the purchase contract for the products, items or services
You have purchased or of any other contract with Us through the Service.

* To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile
application’s push notifications regarding updates or informative
communications related to the functionalities, products or contracted
services, including the security updates, when necessary or reasonable for
their implementation.

* To provide You with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless You have opted
not to receive such information.

* To manage Your requests: To attend and manage Your requests to Us.

* For business transfers: We may use Your information to evaluate or conduct
a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of Our assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar proceeding, in
which Personal Data held by Us about our Service users is among the assets
transferred.

* For other purposes : We may use Your information for other purposes, such
as data analysis, identifying usage trends, determining the effectiveness
of our promotional campaigns and to evaluate and improve our Service,
products, services, marketing and your experience.

We may share Your personal information in the following situations:

* With Service Providers: We may share Your personal information with
Service Providers to monitor and analyze the use of our Service, to show
advertisements to You to help support and maintain Our Service, to contact
You.
* For business transfers: We may share or transfer Your personal information
in connection with, or during negotiations of, any merger, sale of Company
assets, financing, or acquisition of all or a portion of Our business to
another company.
* With Affiliates: We may share Your information with Our affiliates, in
which case we will require those affiliates to honor this Privacy Policy.
Affiliates include Our parent company and any other subsidiaries, joint
venture partners or other companies that We control or that are under
common control with Us.
* With business partners: We may share Your information with Our business
partners to offer You certain products, services or promotions.
* With other users: when You share personal information or otherwise
interact in the public areas with other users, such information may be
viewed by all users and may be publicly distributed outside.
* With Your consent : We may disclose Your personal information for any
other purpose with Your consent.

Retention of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

The Company will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use Your
Personal Data to the extent necessary to comply with our legal obligations
(for example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time
periods.

Transfer of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Your information, including Personal Data, is processed at the Company’s
operating offices and in any other places where the parties involved in the
processing are located. It means that this information may be transferred to —
and maintained on — computers located outside of Your state, province, country
or other governmental jurisdiction where the data protection laws may differ
than those from Your jurisdiction.

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

The Company will take all steps reasonably necessary to ensure that Your data
is treated securely and in accordance with this Privacy Policy and no transfer
of Your Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.

Delete Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~

You have the right to delete or request that We assist in deleting the
Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You
from within the Service.

You may update, amend, or delete Your information at any time by signing in to
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 that You have
provided to Us.

Please note, however, that We may need to retain certain information when we
have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Business Transactions
*********************

If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement
***************

Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).

Other legal requirements
************************

The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:

* Comply with a legal obligation
* Protect and defend the rights or property of the Company
* Prevent or investigate possible wrongdoing in connection with the Service
* Protect the personal safety of Users of the Service or the public
* Protect against legal liability

Security of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

The security of Your Personal Data is important to Us, but remember that no
method of transmission over the Internet, or method of electronic storage is
100% secure. While We strive to use commercially acceptable means to protect
Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data
————————————————————

The Service Providers We use may have access to Your Personal Data. These
third-party vendors collect, store, use, process and transfer information
about Your activity on Our Service in accordance with their Privacy Policies.

Analytics
~~~~~~~~~

We may use third-party Service providers to monitor and analyze the use of our
Service.

* Google Analytics

Google Analytics is a web analytics service offered by Google that tracks
and reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other Google
services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to
Google Analytics by installing the Google Analytics opt-out browser add-
on. The add-on prevents the Google Analytics JavaScript (ga.js,
analytics.js and dc.js) from sharing information with Google Analytics
about visits activity.

For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page: <https://policies.google.com/privacy>

Advertising
~~~~~~~~~~~

We may use Service Providers to show advertisements to You to help support and
maintain Our Service.

* Google AdSense & DoubleClick Cookie

Google, as a third party vendor, uses cookies to serve ads on our Service.
Google’s use of the DoubleClick cookie enables it and its partners to
serve ads to our users based on their visit to our Service or other
websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based
advertising by visiting the Google Ads Settings web page:
<http://www.google.com/ads/preferences/>

* ADX ( Google Ad Manager)

Their Privacy Policy can be viewed at
[https://policies.google.com/privacy?utm_source=admanager.google.com&utm_medium=et&utm_campaign=admanager.google.com%2Fhome%2Fcontact-
us](https://policies.google.com/privacy?utm_source=admanager.google.com&utm_medium=et&utm_campaign=admanager.google.com%2Fhome%2Fcontact-
us)

GDPR Privacy
————

Legal Basis for Processing Personal Data under GDPR
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We may process Personal Data under the following conditions:

* Consent: You have given Your consent for processing Personal Data for one
or more specific purposes.
* Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual
obligations thereof.
* Legal obligations: Processing Personal Data is necessary for compliance
with a legal obligation to which the Company is subject.
* Vital interests: Processing Personal Data is necessary in order to protect
Your vital interests or of another natural person.
* Public interests: Processing Personal Data is related to a task that is
carried out in the public interest or in the exercise of official
authority vested in the Company.
* Legitimate interests: Processing Personal Data is necessary for the
purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis
that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.

Your Rights under the GDPR
~~~~~~~~~~~~~~~~~~~~~~~~~~

The Company undertakes to respect the confidentiality of Your Personal Data
and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the
EU, to:

* Request access to Your Personal Data. The right to access, update or
delete the information We have on You. Whenever made possible, you can
access, update or request deletion of Your Personal Data directly within
Your account settings section. If you are unable to perform these actions
yourself, please contact Us to assist You. This also enables You to
receive a copy of the Personal Data We hold about You.
* Request correction of the Personal Data that We hold about You. You have
the right to have any incomplete or inaccurate information We hold about
You corrected.
* Object to processing of Your Personal Data. This right exists where We are
relying on a legitimate interest as the legal basis for Our processing and
there is something about Your particular situation, which makes You want
to object to our processing of Your Personal Data on this ground. You also
have the right to object where We are processing Your Personal Data for
direct marketing purposes.
* Request erasure of Your Personal Data. You have the right to ask Us to
delete or remove Personal Data when there is no good reason for Us to
continue processing it.
* Request the transfer of Your Personal Data. We will provide to You, or to
a third-party You have chosen, Your Personal Data in a structured,
commonly used, machine-readable format. Please note that this right only
applies to automated information which You initially provided consent for
Us to use or where We used the information to perform a contract with You.
* Withdraw Your consent. You have the right to withdraw Your consent on
using your Personal Data. If You withdraw Your consent, We may not be able
to provide You with access to certain specific functionalities of the
Service.

Exercising of Your GDPR Data Protection Rights
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify Your
identity before responding to such requests. If You make a request, We will
try our best to respond to You as soon as possible.

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

CCPA/CPRA Privacy Notice (California Privacy Rights)
—————————————————-

This privacy notice section for California residents supplements the
information contained in Our Privacy Policy and it applies solely to all
visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We collect information that identifies, relates to, describes, references, is
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular Consumer or Device. The following is a list of
categories of personal information which we may collect or may have been
collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are
those defined in the CCPA/CPRA. This does not mean that all examples of that
category of personal information were in fact collected by Us, but reflects
our good faith belief to the best of Our knowledge that some of that
information from the applicable category may be and may have been collected.
For example, certain categories of personal information would only be
collected if You provided such personal information directly to Us.

* Category A: Identifiers.

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: Personal information categories 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 information, or health insurance information. Some
personal information included in this category may overlap with other
categories.

Collected: Yes.

* Category C: Protected classification characteristics 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 familial genetic information).

Collected: No.

* Category D: Commercial information.

Examples: Records and history of products or services purchased or
considered.

Collected: No.

* 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 voiceprints, iris or retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data.

Collected: No.

* Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: 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 job history or performance evaluations.

Collected: No.

* Category J: Non-public education information (per the Family Educational
Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an
educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records.

Collected: No.

* Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes.

Collected: No.

* Category L: Sensitive personal information.

Examples: Account login and password information, geolocation data.

Collected: Yes.

Under CCPA/CPRA, personal information does not include:

* Publicly available information from government records
* Deidentified or aggregated consumer information
* Information excluded from the CCPA/CPRA’s scope, such as:
* Health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the California
Confidentiality of Medical Information Act (CMIA) or clinical trial data
* Personal Information covered by certain sector-specific privacy laws,
including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley
Act (GLBA) or California Financial Information Privacy Act (FIPA), and
the Driver’s Privacy Protection Act of 1994

Sources of Personal Information
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We obtain the categories of personal information listed above from the
following categories of sources:

* Directly from You. For example, from the forms You complete on our
Service, preferences You express or provide through our Service.
* Indirectly from You. For example, from observing Your activity on our
Service.
* Automatically from You. For example, through cookies We or our Service
Providers set on Your Device as You navigate through our Service.
* From Service Providers. For example, third-party vendors to monitor and
analyze the use of our Service, third-party vendors to provide advertising
on our Service, or other third-party vendors that We use to provide the
Service to You.

Use of Personal Information
~~~~~~~~~~~~~~~~~~~~~~~~~~~

We may use or disclose personal information We collect for “business purposes”
or “commercial purposes” (as defined under the CCPA/CPRA), which may include
the following examples:

* To operate our Service and provide You with Our Service.
* To provide You with support and to respond to Your inquiries, including to
investigate and address Your concerns and monitor and improve our Service.
* To fulfill or meet the reason You provided the information. For example,
if You share Your contact information to ask a question about our Service,
We will use that personal information to respond to Your inquiry.
* To respond to law enforcement requests and as required by applicable law,
court order, or governmental regulations.
* As described to You when collecting Your personal information or as
otherwise set forth in the CCPA/CPRA.
* For internal administrative and auditing purposes.
* To detect security incidents and protect against malicious, deceptive,
fraudulent or illegal activity, including, when necessary, to prosecute
those responsible for such activities.
* Other one-time uses.

Please note that the examples provided above are illustrative and not intended
to be exhaustive. For more details on how we use this information, please
refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use
the personal information We collected for materially different, unrelated, or
incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We may use or disclose and may have used or disclosed in the last twelve (12)
months the following categories of personal information for business or
commercial purposes:

* Category A: Identifiers

* Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))

* Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the
CCPA/CPRA. This does not mean that all examples of that category of personal
information were in fact disclosed, but reflects our good faith belief to the
best of our knowledge that some of that information from the applicable
category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial
purpose, We enter a contract that describes the purpose and requires the
recipient to both keep that personal information confidential and not use it
for any purpose except performing the contract.

Share of Personal Information
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We may share, and have shared in the last twelve (12) months, Your personal
information identified in the above categories with the following categories
of third parties:

* Service Providers

* Our affiliates

* Our business partners

* Third party vendors to whom You or Your agents authorize Us to disclose
Your personal information in connection with products or services We
provide to You

Sale of Personal Information
~~~~~~~~~~~~~~~~~~~~~~~~~~~~

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting,
releasing, disclosing, disseminating, making available, transferring, or
otherwise communicating orally, in writing, or by electronic or other means, a
Consumer’s personal information by the Business to a third party for valuable
consideration. This means that We may have received some kind of benefit in
return for sharing personal information, but not necessarily a monetary
benefit.

We do not sell personal information as the term sell is commonly understood.
We do allow Service Providers to use Your personal information for the
business purposes described in Our Privacy Policy, for activities such as
advertising, marketing, and analytics, and these may be deemed a sale under
CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following
categories of personal information:

* Category A: Identifiers

* Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))

* Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the
CCPA/CPRA. This does not mean that all examples of that category of personal
information were in fact sold, but reflects our good faith belief to the best
of Our knowledge that some of that information from the applicable category
may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We do not knowingly collect personal information from minors under the age of
16 through our Service, although certain third party websites that we link to
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 usage and instruct their children to never provide
information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less
than 16 years of age, unless We receive affirmative authorization (the “right
to opt-in”) from either the Consumer who is between 13 and 16 years of age, or
the parent or guardian of a Consumer less than 13 years of age. Consumers who
opt-in to the sale of personal information may opt-out of future sales at any
time. To exercise the right to opt-out, You (or Your authorized
representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has
provided Us with personal information, please contact Us with sufficient
detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

The CCPA/CPRA provides California residents with specific rights regarding
their personal information. If You are a resident of California, You have the
following rights:

* The right to notice. You have the right to be notified which categories of
Personal Data are being collected and the purposes for which the Personal
Data is being used.
* The right to know/access. Under CCPA/CPRA, You have the right to request
that We disclose information to You about Our collection, use, sale,
disclosure for business purposes and share of personal information. Once
We receive and confirm Your request, We will disclose to You:
* The categories of personal information We collected about You
* The categories of sources for the personal information We collected
about You
* Our business or commercial purposes for collecting or selling that
personal information
* The categories of third parties with whom We share that personal
information
* The specific pieces of personal information We collected about You
* If we sold Your personal information or disclosed Your personal
information for a business purpose, We will disclose to You:
* The categories of personal information categories sold
* The categories of personal information categories disclosed
* The right to say no to the sale or sharing of Personal Data (opt-out). You
have the right to direct Us to not sell Your personal information. To
submit an opt-out request, please see the “Do Not Sell My Personal
Information” section or contact Us.
* The right to correct Personal Data. You have the right to correct or
rectify any inaccurate personal information about You that We collected.
Once We receive and confirm Your request, We will use commercially
reasonable efforts to correct (and direct our Service Providers to
correct) Your personal information, unless an exception applies.
* The right to limit use and disclosure of sensitive Personal Data. You have
the right to request to limit the use or disclosure of certain sensitive
personal information We collected about You, unless an exception applies.
To submit, please see the “Limit the Use or Disclosure of My Sensitive
Personal Information” section or contact Us.
* The right to delete Personal Data. You have the right to request the
deletion of Your Personal Data under certain circumstances, subject to
certain exceptions. Once We receive and confirm Your request, We will
delete (and direct Our Service Providers to delete) Your personal
information from our records, unless an exception applies. We may deny
Your deletion request if retaining the information is necessary for Us or
Our Service Providers to:
* Complete the transaction for which We collected the personal
information, provide a good or service that You requested, take actions
reasonably anticipated within the context of our ongoing business
relationship with You, or otherwise perform our contract with You.
* Detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible for such
activities.
* Debug products to identify and repair errors that impair existing
intended functionality.
* Exercise free speech, ensure the right of another consumer to exercise
their free speech rights, or exercise another right provided for by law.
* Comply with the California Electronic Communications Privacy Act (Cal.
Penal Code § 1546 et. seq.).
* Engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable
ethics and privacy laws, when the information’s deletion may likely
render impossible or seriously impair the research’s achievement, if You
previously provided informed consent.
* Enable solely internal uses that are reasonably aligned with consumer
expectations based on Your relationship with Us.
* Comply with a legal obligation.
* Make other internal and lawful uses of that information that are
compatible with the context in which You provided it.
* The right not to be discriminated against. You have the right not to be
discriminated against for exercising any of Your consumer’s rights,
including by:
* Denying goods or services to You
* Charging different prices or rates for goods or services, including the
use of discounts or other benefits or imposing penalties
* Providing a different level or quality of goods or services to You
* Suggesting that You will receive a different price or rate for goods or
services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Please see the “Do Not Sell My Personal Information” section and “Limit the
Use or Disclosure of My Sensitive Personal Information” section for more
information on how to opt out and limit the use of sensitive information
collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and
if You are a California resident, You can contact Us:

* By email: [email protected]

Only You, or a person registered with the California Secretary of State that
You authorize to act on Your behalf, may make a verifiable request related to
Your personal information.

Your request to Us must:

* Provide sufficient information that allows Us to reasonably verify You are
the person about whom We collected personal information or an authorized
representative
* Describe Your request with sufficient detail that allows Us to properly
understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information
if We cannot:

* Verify Your identity or authority to make the request
* And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45
days of receiving Your verifiable request. The time period to provide the
required information may be extended once by an additional 45 days when
reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the
verifiable request’s receipt.

For data portability requests, We will select a format to provide Your
personal information that is readily usable and should allow You to transmit
the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

You have the right to opt-out of the sale of Your personal information. Once
We receive and confirm a verifiable consumer request from You, we will stop
selling Your personal information. To exercise Your right to opt-out, please
contact Us.

The Service Providers we partner with (for example, our analytics or
advertising partners) may use technology on the Service that sells personal
information as defined by the CCPA/CPRA law. If you wish to opt out of the use
of Your personal information for interest-based advertising purposes and these
potential sales as defined under CCPA/CPRA law, you may do so by following the
instructions below.

Please note that any opt out is specific to the browser You use. You may need
to opt out on every browser that You use.

Website
*******

If applicable, click “Privacy Preferences”, “Update Privacy Preferences” or
“Do Not Sell My Personal Information” buttons listed on the Service to review
Your privacy preferences and opt out of cookies and other technologies that We
may use. Please note that You will need to opt out from each browser that You
use to access the Service.

Additionally, You can opt out of receiving ads that are personalized as served
by our Service Providers by following our instructions presented on the
Service:

* The NAI’s opt-out platform: <http://www.networkadvertising.org/choices/>
* The EDAA’s opt-out platform <http://www.youronlinechoices.com/>
* The DAA’s opt-out platform:
[http://optout.aboutads.info/?c=2&lang=EN](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 the cookies saved by Your
browser, You will need to opt out again.

Mobile Devices
**************

Your mobile device may give You the ability to opt out of the use of
information about the apps You use in order to serve You ads that are targeted
to Your interests:

* “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on
Android devices
* “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile
device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

If You are a California resident, You have the right to limit the use and
disclosure of Your sensitive personal information to that use which is
necessary to perform the services or provide the goods reasonably expected by
an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are
necessary to provide the Service. For more information on how We use Your
personal information, please see the “Use of Your Personal Data” section or
contact us.

Children’s Privacy
——————

Our Service does not address 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 are aware 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 remove that information from Our
servers.

If We need to rely on consent as a legal basis for processing Your information
and Your country requires consent from a parent, We may require Your parent’s
consent before We collect and use that information.

Links to Other Websites
———————–

Our Service may contain links to other websites that are not operated by Us.
If You click on a third party link, You will be directed to that third party’s
site. We strongly advise You to review the Privacy Policy of every site You
visit.

We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.

Changes to this Privacy Policy
——————————

We may update Our Privacy Policy from time to time. We will notify You of any
changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior
to the change becoming effective and update the “Last updated” date at the top
of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.

If you have any questions about this Privacy Policy, You can contact us:

* By email: [email protected]