California Privacy Notice

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information under the California Consumer Privacy Act of 2018 ("CCPA").  This notice describes your CCPA rights and explains how to exercise those rights, and such be read in conjunction with our Privacy Policy. 

Your Rights: 

Restrict: You have the right to request that we restrict the processing of your Personal Information if 

  1. you are concerned about the accuracy of your Personal Information;  
  2. you believe your Personal Information has been unlawfully processed;  
  3. you need us to maintain the Personal Information solely for the purpose of a legal claim; or  
  4. we are in the process of considering your objection in relation to processing on the basis of legitimate interests. 

“Opt-out” of processing: You have the right to opt-out of the processing of your Personal Information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your Personal Information. Note that this will limit our ability to provide you with our services, and in certain cases you may not be able to use our Services, as the processing of your Personal Information is necessary for the performance of our Services. 

Data portability: You may have the right to request a copy of the Personal Information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this Personal Information to a third party.  

Deletion: You may have a right to request that we delete the Personal Information we hold about you at any time, and we will take reasonable steps to delete your Personal Information from our current records. If you ask us to delete your Personal Information, we will let you know how the deletion affects your use of our website, Mobile Apps or Services. There may be exceptions to this right for specific reasons which, if applicable, we will set out for you in response to your request. Some examples of exceptions include but are not limited to: 

  • when we need to keep data to meet legal obligations,  
  • to detect fraud,  
  • to investigate reports of abuse or other Terms of Service violations,  
  • to fix security issues,  
  • to comply with any other legal obligation. 

If you terminate or delete your account, we will either delete your Personal Information within forty-five (45) days of the deletion of your account or anonymise your information in a way that cannot be identified back to you.  

Right to know: You have the right to know certain information about our data practices in the preceding twelve (12) months. In particular, you have the right to request the following from us: 

  • The categories of Personal Information we have collected about you; 
  • The categories of sources from which the Personal Information was collected; 
  • The categories of Personal Information about you we disclosed for a business purpose or sold; 
  • The categories of third parties to whom the Personal Information was disclosed for a business purpose or sold; 
  • The business or commercial purpose for collecting or selling the Personal Information; and 
  • The specific pieces of Personal Information we have collected about you. 

You have the right to make two (2) free requests in any twelve (12)-month period. We will respond to your request within forty-five (45) days, and in more difficult cases we may extend our response time by another forty-five (45) days.  

Right to non-discrimination: You have the right not to receive discriminatory treatment for exercising these rights. We will not deny Services, charge a different price, or provide a different level or quality of services just because you exercised your rights under the CCPA. However, please note that the exercise of these rights (such as in the case of a deletion request), may limit our ability to provide you with our services, and in certain cases you may not be able to use our Services. 

Exercising Your Rights 

You can exercise any of your rights as described in the section above at any time. 

To make such a request, please send an email to [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 request related to your Personal Information. You may also make a request on behalf of your minor child.  

We will only fulfill these requests once we have verified you as being able to make these requests. As such your request should:  

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. 
  • Provide sufficient detail that allows us to properly understand, evaluate, and respond to the request. 
  • Provide sufficient contact information so we may reach you if we require additional information to complete your request.  

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. 

We endeavor to respond to a verified request within forty-five (45) days of its receipt.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.  Any disclosures we provide will only cover the twelve (12)month period preceding the verifiable consumer request’s receipt.   

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

California Notice of Collection 

In the past twelve (12) months, we have collected the following categories of Personal Information enumerated in the California Consumer Privacy Act: 

  1. Identifiers, such as name, email address, phone number account name, IP address, and an ID or number assigned to your account. 
  2. Customer records, such as billing and shipping address, and credit or debit card data. 
  3. Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws. 
  4. Commercial information, such as products or services history and purchases. 
  5. Internet activity, such as your interactions with our service. 
  6. Geolocation data. 
  7. Inferences, such as information about your interests, preferences, and favorites. 

For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section of our Privacy Policy. We collect and use these categories of Personal Information for the business purposes described in the “How We Use This Information” section, including to provide and manage our Service. 

Protected Health Information Exemption 

Information we collect that is considered Protected Health Information (PHI) pursuant to the Health Insurance Portability and Accountability Act of 1996 is exempt from CCPA under section 1798.145(c)(1)(a). 

California Online Privacy Protection Act Notice 

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to “Do Not Track Signals”; and whether third parties collect personally identifiable information about users when they visit us. 

  1. We do not track users who do not interact with its sharing functionality across the web, and therefore do not use “do not track” signals. 
  2. We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate member consent. 

Other California Privacy Rights 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year. 

Additional Disclosures for California Compliance (US) 

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes. 

Note that as a general rule we do not sell Personal Information we have collected about you to any third parties or provide them for their own marketing purposes.  

If any such instances exist, we will email you a list of categories of Personal Information we revealed to other organisations for their marketing purposes in the last calendar year, along with names and addresses. Not all Personal Information shared in this way is covered by Section 1798.83 of the California Civil Code. 

To make such a request, please contact us using the details provided in this privacy Notice. You may make this type of request once every calendar year.  

Changes to Our Privacy Notices 

We reserve the right to amend this privacy Notice at any time and as needed. When we make changes to this privacy Notice, we will post the updated Notice on our Website and update the Notice’s effective date. Your continued use of our website, mobile app and/or Services following the posting of changes constitutes your acceptance of such changes. 

Contact Information 

If you have any questions or comments about this Notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: 

[email protected]