These terms were last updated on 5/25/22.
Welcome to the Privacy Policy of Warmly, Inc. ("Warmly", "we", "us", or "our"). Warmly operates the https://warmly.ai, https://warmlyai.com and https://getwarmly.com websites.
As a data-driven company, we care deeply about privacy and data security. We may update this Privacy Policy from time to time. If we do, we will update the "last updated" date at the top of the page. If we make material changes to this Privacy Policy, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
What does this Privacy Policy apply to?
This Privacy Policy applies to our websites: https://www.warmly.ai, https://getwarmly.com and all sub-domains (“Site”), all software (including integrations with third-party software) and services we offer through our Site (“Services”), and email, text, or other electronic messages between you and us. It applies to any information that relates to an identifiable individual (“Personal Information”), which we describe in more detail below. This Privacy Policy does not apply to information collected on sites, applications, destinations, or services linked to from our website.
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By accessing or using the Site and/or the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not want your Personal Information to be processed as described in this Privacy Policy, please do not use our Site or our Services.
Note to Enterprise Customers: If you are an enterprise customer of Warmly and wish to enter into a separate data processing agreement with Warmly in order to comply with your obligations under applicable data protection laws, please contact us at [email protected].
Contact Us
If you wish to ask us any questions about this policy, or to exercise any of your rights described in this Privacy Policy, you can email us at [email protected].
Collection and Use
We use the information described in this subsection for the purposes identified below, including without limitation auditing, security, debugging, internal research and development, maintaining the quality and safety of our Services, and service performance purposes. For example, we use information to measure web traffic and usage activity on our Site for purposes of improving and enhancing the functionality of our Site, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions on our Site. Cookies also allow our servers to remember your account information for future visits and to provide personalized and streamlined information across related pages on our Site. In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technology to identify the fact that you have visited our Site or seen one of our advertisements.
Information we collect directly from you
We collect Personal Information you provide to us:
- Registration and profile and virtual business card information. When you register for an account, we collect your username, password and email address. Once you register for an account, you may also be able to create a profile and virtual business card that other users can see. Your profile and virtual business card may include information you choose to add such as your profile photo, job title and other work-related information, your approximate location, links to your profiles on various social networks, and other preferences and information. We use this information to administer your account, provide you with the relevant services and information, communicate with you regarding your account, the Service, and for customer support purposes.
- Billing information. If you make a payment to Warmly, we require you to provide your billing details, such as a name, address, email address and, in some instances, financial information corresponding to your selected method of payment. If you provide a billing address, we will regard that as the location of the account holder.
- Account settings. You can set various preferences and personal details on pages like your account settings page.
- Calendar Information. We offer enhanced functionality to users who opt in to providing us with access to their calendar application, as described in more detail in the Warmly Privacy Policy – Calendar Supplement. Please note that our enterprise customers may choose to permit or restrict calendar integration access at the enterprise level. Please contact [email protected] for more information.
- CRM information. We offer enhanced functionality to organizations who opt in to providing us with access to their CRM Application. Please note that our enterprise customers may choose to permit or restrict CRM integration access at the enterprise level. Please contact [email protected] for more information.
- Feedback or Contact Us. When you provide us feedback or contact us via email, other electronic communications, or our Site, we will collect your name and email address, as well as any other content included in your communication, in order to send you a reply and to act on the feedback or information you have provided to us.
- Support. We also collect other types of Personal Information that you provide to us voluntarily, such as any information you provide to us if you contact us regarding support for our Services in order for us to respond to your support request or provide to us in person at an event (either manually or electronically).
- Other data you intentionally share. We also collect Personal Information at such other points on our Services that state that Personal Information is being collected so that we may provide the features or functionality for which we collected the Personal Information and for other purposes described in this Privacy Policy. We may also collect your Personal Information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial.
- Linking Information. To the extent we are able to do so, we may link your non-personally identifiable information with your personally identifiable information and we may also link information collected online with information we collect offline or information collected online by third parties.
Information we collect about you indirectly or passively when you interact with us
- Usage data. We collect usage data about you whenever you interact with our Services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps. Personal Information gathered through tracking technologies may include internet or other electronic network activity information for the purposes of cross-device tracking for targeted advertising, the date and time of visits, the pages viewed, links to/from any page, and time spent at a site.
- Device data. We collect data from the device and application you use to access our Services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.
- Referral data. If you arrive at our Site from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
- Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs. You may consider visiting aboutcookies.org, which provides helpful information about cookies. If you wish to limit, block or delete cookies from our website – or any other website – you can use your browser to do this. Each browser is different so check the ‘Help’ menu of your particular browser or the browser settings for your mobile device to learn how to change your cookie preferences. If you do this, however, certain features of our website may not work correctly or cannot be provided to you.
- Web Beacons (tracking pixels). Web beacons (also known as tracking pixels) are bits of data that count the number of users who access a website or open an email and can also allow us to see if a cookie has been activated. Web beacons used on web pages or in emails allow us to see how successful an article has been, or whether an email message was successfully delivered and read in a marketing campaign. We also use web beacons to learn if you have clicked on any links contained in emails. We may use this information to help us identify which emails are more interesting to you.
- Information from third parties. We may collect your Personal Information or data from third parties if you give permission to those third parties to share your information with us. For example, you have the option of registering and signing into Warmly with a third- party authentication provider. If you do this, the authentication of your logon details is handled by that third-party authenticator.
• Single Sign-On. We may use single sign-on ("SSO") to allow a user to authenticate their account using one set of login information, including through Google. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties, which may include, for example, your name, username, email address, language preference, and profile picture. We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, customer support, changes, or updates to features of the Site, technical and security notices).
• Social Media. When you interact with our Site through various social media, such as when you click on the social media icon on the Site, follow us on a social media Site, or post a comment to one of our pages, we may receive information from the social network such as your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
• Information from Other Sources. We may obtain information from other sources, including through publicly available sources, third-party information providers, customers, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Privacy Policy governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
- Analytics Services. We use third-party analytics services, such as Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses Cookies to collect information such as how often users visit the Services, what pages they visit, and what other sites they used prior to coming to the Services. We use the information we get from Google Analytics only to improve our Services. We do not combine the information generated through the use of Google Analytics with other Personal Information you may provide to us from time to time. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Services, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You may also download the Google Analytics opt-out browser add on, available at https://tools.google.com/dlpage/gaoptout.
How We Use The Personal Information We Collect
In addition to the uses described above, we may use the information we collect from you:
- to provide Services to you; including enriching information for your meetings and displaying your network;
- to operate and improve our Services and products;
- to understand you and your preferences to enhance your experience and enjoyment using our Services;
- to improve the content of our Site or our Services;
- to customize the content and layout of our Site or our Services for individual users;
- to respond to your comments and questions and provide customer service;
- to provide and deliver products and services you request;
- to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- to send you targeted messages about new contests, promotions, rewards, upcoming events, and other news about products and services offered by us;
- to use third-party service providers to send and distribute e-mail and to perform other marketing and support functions on our behalf or otherwise to assist us in providing our Services to you;
- to link or combine it with other Personal Information we get from third parties, to help understand your needs and provide you with better service;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
-for our own business and commercial purposes;
- for identity management, security, and auditing;
- for any other purpose for which you provide it; or
- in any other way we may describe when you provide the information.
We may create anonymized data (data that is not associated with or linked to your personally identifiable information) records from Personal Information by excluding information (such as your name, email address, personal identification numbers) that makes the data personally identifiable to you. We use this anonymized data to analyze request and usage patterns so that we may enhance the content of our Services and improve Services navigation. We reserve the right to use anonymized data for any purpose and to disclose anonymized data to third parties in our sole discretion.
Sharing and Transfers
Except as disclosed in this Privacy Policy, we do not share, rent, or sell Personal Information you have given us to any third party. This section describes the subset of Personal Information we share with partners, customers, and service providers, or for legal, corporate, or compliance purposes.
Service Providers and Similar Third Parties
We may provide your Personal Information to service providers or contractors to perform functions on our behalf, including, but not limited to, communicating news; web hosting; information technology and related infrastructure (such as cloud computing); performing Site or Services development or maintenance; providing functionality or other services for our Site and our Services; security and other auditing; sending postal mail, email or other communications; customer service; removing outdated and repetitive information from our lists; analyzing our data; developing, enhancing, marketing or providing any of our Services; processing payments; order fulfillment; or assisting us with other marketing and support functions. These third party providers are required not to use your Personal Information other than to provide the services requested by us.
Other Sharing
We may also disclose your Personal Information:
- to a person who in our reasonable judgment is seeking the information as an agent of the individual or company;
- if, in our reasonable judgment, it is necessary enforce compliance with our internal policies, terms of use, or the agreement for our Services;
- to protect the rights, property, and safety of Warmly and our agents, customers, or others;
- in situations where sharing or disclosing your information is required in order to provide you with information that you have requested;
- in connection with a legal action or other proceeding, including without limitation, in response to a court order or a subpoena;
- in response to a law enforcement agency’s request;
- to comply with applicable law;
- in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company;
- to another entity as part of a merger, bankruptcy, insolvency, receivership, a sale of assets or all or part of a business, or any other corporate change or re-organization; or
- to a third party or parties, where you consent to such disclosure or disclosure is required or permitted by law.
During the course of our business we may also share with third parties aggregated demographic and/or statistical information that is not personally identifiable.
Third-Party Advertising
We may also participate in some digital advertising networks ("Ad Networks") with which we share certain information collected through cookies and other tracking technologies and receive back similar information from other participants in the Ad Networks, as well as analytics about the information we share with the Ad Networks. Ad Networks place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.
Personal Information We Process on Customers’ Behalf
Information Collected By Customers Or On Customers’ Behalf
Our Customers, through the use of our Services, provide us the Personal Information of individuals contained in their address book. This information can include the email addresses, names, job titles and more our Customers’ contacts (“Service Data”). We collect on our Customers’ behalf updated Personal Information on those individuals from their social media profiles or other third-party sources (including, but not limited to, current email address, job titles, and employer information) (also, “Service Data”) and provide those to our Customers for their use. Please note that, while Customers may provide us with Service Data that we store and process and we collect Service Data that we store, process, and provide to our Customers, we are not responsible for the privacy and data security practices of those Customers and you should look to their privacy and data security policies for information and those Customers to address your questions or concerns.
How We Use Service Data
We process Service Data through the functionality of our Services in accordance with the instructions provided to us by Customers when they use that functionality.
Sharing of Service Data
We provide access to Service Data to our Customers on whose behalf we have collected it (in addition to the Service Data which our Customers originally provided to us) and we may share Service Data as otherwise set out in this Privacy Policy.
Protection of Information
Warmly considers the security of all the information and data within our control to be a top priority, and consistent with this we implement commercially reasonable technical and organizational safeguards to protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, such information or data. However, no security system is impenetrable, and unanticipated system failures or the efforts of malicious actors are an unfortunate reality on the internet. Therefore, we cannot guarantee that the information and data within our control, including Personal Information, is absolutely secure.
Our Policy Towards Children
Warmly does not direct our services towards individuals under the age of 18. We do not knowingly collect Personal Information from individuals under the age of 18. If we become aware that we have collected Personal Information from individuals under the age of 18, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law). If you become aware that Warmly has improperly collected information from individuals under the age of 18, please contact us immediately at [email protected].
How We Respond to Do Not Track Signals
Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. Because we do not track our visitors to provide targeted advertising, we do not alter our practices when we receive a Do Not Track signal from a visitor’s browser. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.
Additional Notice to Residents of the European Economic Area (EEA) and Switzerland
Legal Bases for Collection and Processing of Information as Controller
Our collection and processing of your Personal Information is supported by a number of legal bases. Set out below are the most relevant ones. Please note that while we may rely on one legal basis for a particular activity, if that is no longer applicable or available then we may be able to rely on another basis.
With Your Consent. We collect and process some of your Personal Information because we obtain your consent. When we want to use cookies to collect Personal Information from you for performance or marketing reasons, for example, we obtain your consent by displaying a banner when you first visit our Site (or, if you have deleted your cookies, when you next visit) that discloses the reasons we use cookies to collect information and links to this Privacy Policy which in turn contains more detailed information about our collection, third-party collection, and opt-out information. You must accept the use of those cookies or you may not visit or use our Site.
To Fulfill a Contract. We collect and process some of your Personal Information because we need to do so either to enter into or fulfill a contract we have with you. For example, we process your Personal Information when we provide Services to you that you have purchased on our Site.
For a Legitimate Interest. We may process your Personal Information where we or a third party have a legitimate interest in doing so. For example, we have a legitimate interest in understanding how people are using our Services, both to improve them and to market them more effectively. Therefore, we may use your Personal Information to understand and analyze your use of our Services. When we rely on our legitimate interest, we will carry out a balancing test between our legitimate interests and your privacy rights. Our legitimate interests include: understanding how our audience interacts with our content, our marketing and promotions, and our Services; learning about our audience in order to improve our Services for them; developing, delivering, and maintaining relevant and engaging content and promotional information; supporting the dissemination of information on topics of interest to individuals and the community; supporting individuals’ rights to receive information; and conducting our business activities and achieving our business goals.
To Comply with Legal Obligations. We will process your Personal Information when necessary to comply with legal and regulatory obligations or defend claims. For example, we may share your Personal Information in response to a court order, subpoena, or law enforcement agency's request.
Retention of Information
We will only keep your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it (and whether we can achieve those purposes through other means), and the applicable legal requirements. The retention of Service Data is determined by our Customers that collect it from you or on whose behalf we collect it through the use of our Services.
In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.
Upon expiration of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
Access, Correction and Deletion of Information We Collect
For Personal Information that we hold about you, you may have the right (subject to exceptions allowed by law) to:
- request access to your Personal Information;
- request we correct any inaccurate Personal Information;
- request we delete any Personal Information;
- restrict the processing of Personal Information;
- object to the processing of Personal Information; and/or
- receive a copy of your Personal Information in a structured and commonly used machine-readable format or have such Personal Information transmitted to another company.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
Modifying Profile and Virtual Business Card Information. If you have an account for our Service, you have the ability to modify certain information in your profile/virtual business card (e.g., your contact information) through the account setting page or a similar option provided on the Service. If you have any questions about modifying or updating any information in your account, please contact us at the email address provided below.
Modifying Service Data. If we store, use, or process your Service Data, please contact the Customer that collected your Service Data if you would like to access, correct, or delete your Service Data, restrict or object to processing of your Service Data, or receive a copy of your Service Data. We will work with the Customer on whose behalf we store, use, or process your Service Data to respond to your request within a reasonable time.
Email Communications. From time to time, we may send you emails regarding updates to our Service, products or services, notices about our organization, or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Transfer of Information
We are located in the United States and your Personal Information that we collect is processed and stored in the United States. We rely on derogations for specific situations as set forth in Article 49 of the General Data Protection Regulation (“GDPR”) and on contractual clauses in our agreements. In particular, we collect and transfer to the United States Personal Information with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Given the lack of a finding of “adequacy”, there may be a risk that the supervisory authority and/or data processing principles and/or data subject rights in the United States might not be sufficiently appropriate or comprehensive safeguards from the perspective of the EU. We strive, however, to apply suitable safeguards to protect the privacy and security of your Personal Information and only to use it consistent with your relationship with us and the practices described in this Privacy Notice. Our vendors and others with whom we share your personal information in accordance with this Policy are either certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks or we use contractual clauses in our agreements with them that are designed to protect the privacy and security of your Personal Information.
Additional Notice to Residents of California
Information We Collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (for purposes of this Additional Notice to Residents of California section, “personal information”) of various types and from various sources in the course of your engagement with us and our services. Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information excluded from the scope of the CCPA including personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, California Financial Information Privacy Act, or the Driver's Privacy Protection Act of 1994. Set forth below are the categories of personal information that we collected in the past 12 months, why we collect it, and the categories of sources from whom we collect it.
You may be entitled to additional privacy notices depending on where you are located. Please see the appropriate subsection below that may apply to you.
A. Identifiers (examples: real name, postal address, internet protocol address, email address, driver’s license number)
Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (examples: name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.)
Categories of Sources
- You, your agent, or our Customers
- Social Media sites and other third-party sources
C. Characteristics of protected classifications under California or federal law (examples: Age (40 years or older), race, color, religion, marital status, sex)
Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources
D. Commercial information (Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources
F. Internet or other similar network activity (examples: browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement)
Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources
I. Professional or employment-related information (examples: employment history. Some personal information included in this category may overlap with other categories.)
Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources
All personal information collected by us under the various categories listed above is collected for a variety of business purposes as set forth below.
Business Purposes for collection of all categories of personal information:
- to provide Services which you have requested from us- to verify your identity- to fulfill or meet the reason for which the information is provided
- to process payments
- to send you targeted messages, publications, news, and information about events, special offers, promotions and benefits
- to improve the content of our Sites or Services, to enhance users’ experiences when visiting our Sites or using our Services, and to customize the content and layout of Sites for each individual user
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections
- For testing, research, analysis and product development
- As necessary or appropriate to protect the rights, property or safety of us, our Customers or others
- 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, or any other transaction in which personal information held by us is among the assets transferred or constitutes relevant information for evaluation of the transaction
- As described to you when collecting your personal information or as otherwise set forth in the CCPA
Sharing of Personal Information
We may disclose your personal information to a third party for a business purpose. We have disclosed to third parties the following categories of personal information for a business purpose in the past 12 months:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category C: Characteristics of protected classifications under California or federal law (age)
We disclosed personal information for a business purpose to the following categories of third parties in the past 12 months:
• Our Customers
• Service providers
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with Services we provide to you
Your California Privacy Rights
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer 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 purpose for collecting or sharing 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 (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and.
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
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:
1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at:
• [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 consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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.
• 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. 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.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Questions?
If you have any questions that this Privacy Policy could not answer, please contact us at [email protected].