1. Information We Collect
We collect information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Customer or device (“personal information”). In particular, we have collected the following categories of personal information from our Customers within the last twelve (12) months and will collect the following categories of personal information:
Category A. Identifiers
Examples: A unique personal identifier, online identifier, email address, or other similar identifiers.
Category B. Commercial information
Examples: Records of services purchased, or other purchasing histories.
Category C. Internet or other similar network
Examples: Information on a Customer’s interaction with an application.
We obtain your personal information listed above directly or indirectly from you in our relationship with you, including, but not limited to, when you (i) make your personal account, (ii) apply to use the Service, (iii) access or use the Service, and (iv) communicate with us for inquiry about the Service.
2. Use of Personal Information
We may use the Categories A through C of personal information from the list above, for one or more of the following business purposes indicated below:
- to provide the Services and enable Customers’ efficient use of the Services;
- to process details regarding Customers’ use of the Services;
- to process and administer Customers’ personal account and registrations of the Service;
- to provide various services correspondence to the Customers (including to notify the Customers of changes to the Services);
- to process details of personal information that the Customers voluntarily provide on the Services;
- to perform, monitor and enforce contracts concluded between the Customers and the Company;
- to conduct research, analysis, develop our products;
- to provide notification of information related to the Service and our other products; and
- to serve advertisements to the Customers on our applications based on the use of the Services and/or on third-party sites and applications.
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.
3. Sharing or Disclosure of Personal Information
We may share or disclose your personal information to a third party for business purposes or commercial purposes. When we disclose personal information to service providers for business purposes or commercial purposes, we enter a contract that describes such purposes and requires the service providers to both keep that personal information confidential and not use it for any purpose except for performing the contract.
In the preceding twelve (12) months, we have shared or disclosed the following categories of personal information from the above list to the following categories of third parties for business purposes or commercial purposes:
- Service providers related to the investigation of a bug in the application: Category A and C
4. Sales of Personal Information
We have not sold any personal information in the preceding twelve (12) months.
5. Children and Parents
As used in this Section, the “child” or “children” means under the age of 13, and the term “parent” includes legal guardians.
Our Services are intended for general audience. We do not knowingly collect, use or share any personal information about children without verifiable parental consent or as permitted by law. If you are a parent and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.
Once a user indicates that he or she is under the age of 13, we will not collect any personal information from that user except certain limited information permitted by the law. For example, we may ask for the name and online contact information of a child user’s parent in order to provide notice and obtain a parental consent. In addition, we may collect certain information permitted by the law to support and protect the security, integrity and operation of our Services.
If a child states that his/her age is under 13, we will seek consent from the child’s parent before collecting personal information from the child; except we may collect and use certain information from the child for limited purposes without obtaining parental consent where permitted to do so by law.
Parents can review the personal information we have collected from their child and request them to be deleted. Parents can also revoke their previously provided consent to collection or use of the child’s personal information. If you are a parent and wish to review, modify, or delete your child’s personal information, or withdraw consent, you can submit a request to us by contacting us in the manner set forth in Section 7 (Contact Us).
6. Your Rights and Choices under the Applicable Law
Depending on your jurisdiction, in accordance with applicable law, you may have several rights on our processing of your Personal Data, which may include, to request access to, correction, or deletion of your Personal Data. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us.
If you are a California resident, the California Consumer Privacy Act of 2018 (the “CCPA”) provides consumers who are residents of California with specific rights regarding personal information. The following of this Section describes your CCPA rights and explains how to exercise those rights.
（1）Access Right to Specific Information
You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your personal information over the past twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose to you the following information:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting or selling that personal information;
- The categories of third parties with whom we share or sell that personal information;
- The categories of personal information sold by each third party who sold personal information;
- The categories of personal information disclosed for business purposes or commercial purposes; and
- The specific pieces of personal information we collected about you.
Please note that we have not sold any personal information in the preceding twelve (12) months.
（2）Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights 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 legal obligations; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We have not sold and will not sell any personal information collected from Customers.
We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
（5）Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 7 (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 consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e.g. a copy of your passport, residence certificate, etc.); and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.
If you have any questions or comments about this Policy, the ways in which we collect and use your information described above, or wish to exercise your rights described in the Section 6 (Your Rights and Choices under the Applicable Law), please do not hesitate to contact us at:
- [e-mail address:] firstname.lastname@example.org