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  • LAST
    UPDATED
    ON
    JANUARY
    21,
    2024

close up of a hasselblad front lens element

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. This Privacy Policy was generated by

TermsFeed
Privacy
Policy
Template
.

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.

"Business"
, for the purpose of the CCPA (California Consumer Privacy Act), 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.

"Company"
(referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Luigi Fieni Imagery. For the purpose of the GDPR, the Company is the Data Controller.

"Country"
refers to Germany.

"Consumer"
, for the purpose of the CCPA (California Consumer Privacy Act), 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.

"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.

"Do
Not
Track"
 (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

"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, 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.

"Sale"
, for the purpose of the CCPA (California Consumer Privacy Act), means 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 to another business or a third party for monetary or other valuable consideration.

"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 Luigi Fieni Imagery, accessible from
https://www.luigifieni.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 (General Data Protection Regulation), 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
  • Address,
    State,
    Province,
    ZIP/Postal
    code,
    City
  • 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
do
not
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.

we
do
not
use
either Session and Persistent Cookies for the purposes set out below:

Necessary
/
Essential
Cookies

Type: Session Cookies
Administered by: NOT APPLICABLE
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: NOT APPLICABLE
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality
Cookies

Type: Persistent Cookies
Administered by: NOT APPLICABLE
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: NOT APPLICABLE
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.

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.

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, for payment processing, 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.

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.

https://www.hostinger.de

Email
Marketing

We
may
use
Your
Personal
Data
to
contact
You
with
newsletters,
marketing
or
promotional
materials
and
other
information
that
may
be
of
interest
to
You.
You
may
opt-out
of
receiving
any,
or
all,
of
these
communications
from
Us
by
following
the
unsubscribe
link
or
instructions
provided
in
any
email
We
send
or
by
contacting
Us.

art@luigifieni.com

Payments

We
may
provide
paid
products
and/or
services
within
the
Service.
In
that
case,
we
may
use
third-party
services
for
payment
processing
(e.g.
payment
processors).

We
will
not
store
or
collect
Your
payment
card
details.
That
information
is
provided
directly
to
Our
third-party
payment
processors
whose
use
of
Your
personal
information
is
governed
by
their
Privacy
Policy.
These
payment
processors
adhere
to
the
standards
set
by
PCI-DSS
as
managed
by
the
PCI
Security
Standards
Council,
which
is
a
joint
effort
of
brands
like
Visa,
Mastercard,
American
Express
and
Discover.
PCI-DSS
requirements
help
ensure
the
secure
handling
of
payment
information.

https://www.paypal.com

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
Privacy

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.
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: Yes.

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.

Under
CCPA,
personal
information
does
not
include:

  • Publicly
    available
    information
    from
    government
    records
  • Deidentified
    or
    aggregated
    consumer
    information
  • Information
    excluded
    from
    the
    CCPA'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, or from Your purchases on 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 for payment processing, or other third-party vendors that We use to provide the Service to You.

Use
of
Personal
Information
for
Business
Purposes
or
Commercial
Purposes

We
may
use
or
disclose
personal
information
We
collect
for
"business
purposes"
or
"commercial
purposes"
(as
defined
under
the
CCPA),
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.
If
You
provide
Your
personal
information
to
purchase
a
product
or
service,
We
will
use
that
information
to
process
Your
payment
and
facilitate
delivery.

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.

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.

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
for
Business
Purposes
or
Commercial
Purposes

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
D:
Commercial
information

Category
F:
Internet
or
other
similar
network
activity

Please
note
that
the
categories
listed
above
are
those
defined
in
the
CCPA.
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.

Sale
of
Personal
Information

As
defined
in
the
CCPA,
"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
any
personal
information.

Share
of
Personal
Information

We
may
share
Your
personal
information
identified
in
the
above
categories
with
the
following
categories
of
third
parties:

Service
Providers

Payment
processors

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
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.

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

The
CCPA
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
request.
 Under CCPA, 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
    purpose
    for
    collecting
    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

The
right
to
say
no
to
the
sale
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 contact Us. However, please keep in mind that we do not sell any personal data.

The
right
to
delete
Personal
Data.
 You have the right to request the deletion of Your Personal Data, 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
Data
Protection
Rights

In
order
to
exercise
any
of
Your
rights
under
the
CCPA,
and
if
You
are
a
California
resident,
You
can
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
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.
However,
We
do
not
sell
Your
personal
information.

The
Service
Providers
we
partner
with
(for
example,
our
internet
hosting
provider)
may
use
technology
on
the
Service
that
sells
personal
information
as
defined
by
the
CCPA
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
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

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
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.

"Do
Not
Track"
Policy
as
Required
by
California
Online
Privacy
Protection
Act
(CalOPPA)

Our
Service
does
not
respond
to
Do
Not
Track
signals.

However,
some
third
party
websites
do
keep
track
of
Your
browsing
activities.
If
You
are
visiting
such
websites,
You
can
set
Your
preferences
in
Your
web
browser
to
inform
websites
that
You
do
not
want
to
be
tracked.
You
can
enable
or
disable
DNT
by
visiting
the
preferences
or
settings
page
of
Your
web
browser.

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.

Your
California
Privacy
Rights
(California's
Shine
the
Light
law)

Under
California
Civil
Code
Section
1798
(California's
Shine
the
Light
law),
California
residents
with
an
established
business
relationship
with
us
can
request
information
once
a
year
about
sharing
their
Personal
Data
with
third
parties
for
the
third
parties'
direct
marketing
purposes.

If
you'd
like
to
request
more
information
under
the
California
Shine
the
Light
law,
and
if
You
are
a
California
resident,
You
can
contact
Us
using
the
contact
information
provided
below.

California
Privacy
Rights
for
Minor
Users
(California
Business
and
Professions
Code
Section
22581)

California
Business
and
Professions
Code
Section
22581
allows
California
residents
under
the
age
of
18
who
are
registered
users
of
online
sites,
services
or
applications
to
request
and
obtain
removal
of
content
or
information
they
have
publicly
posted.

To
request
removal
of
such
data,
and
if
You
are
a
California
resident,
You
can
contact
Us
using
the
contact
information
provided
below,
and
include
the
email
address
associated
with
Your
account.

Be
aware
that
Your
request
does
not
guarantee
complete
or
comprehensive
removal
of
content
or
information
posted
online
and
that
the
law
may
not
permit
or
require
removal
in
certain
circumstances.

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.

Contact
Us

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