PRIVACY POLICY

General.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE OUR APP OR SITES.

INTRODUCTION

HELLO Labs ("HELLO") is an ecosystem of games, TV shows, live events, and NFTs all under one brand, operated by HELLO Holdings Inc. Doge Dash & Dash of the Dead are a part of the HELLO ecosystem and gaming ecosystem. HELLO Holdings Inc. built the Doge Dash & Dash of the Dead Apps (the ‘Apps‘) as free Apps. Our Apps are provided at no cost and are intended for use ‘as is.‘

This Policy is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if you use our App or our websites, including hello.one, (the "Sites"). If you choose to use our App or Sites, then you agree to the collection and use of information as described in this policy. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, unless otherwise defined in this Privacy Policy.

INFORMATION COLLECTION AND PROCESSING

We collect and use the information described below:

Collection	Description
Contact Information	If you contact us or submit a question via our Sites or App or otherwise inquire about our products or services, we collect your name, email address, and phone number. We process Contact Information to provide our Sites, App, products, and services; to provide support; to ensure the privacy and security of our Sites, App, products, and services; to maintain our databases and back-ups; to manage our relationship with you; to communicate with you; and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our App, Sites, and business; the proper management of our customer relationships and direct marketing; and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Account Information	If you sign up for an account, we will collect your username, password, email address, phone number, and wallet address. We process Account Information to operate our business; to provide our Sites, App, products, and services; to ensure the privacy and security of our Sites, App, products, and services; to maintain our databases and back-ups; to manage our relationship with you; to communicate with you; and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our App, Sites, and business; the proper management of our customer relationships and direct marketing; and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Account Verification Information	To verify your account, we will collect your name, date of birth, address, and identification number (e.g., U.S. taxpayer identification number or number and country of issuance of any other government-issued document). We use Account Verification Information for identity verification purposes. The legal basis for this processing is compliance with a legal obligation to which we are subject and our legitimate interest in ensuring the safety and security of our App, Sites, and business.
Payment Information	To facilitate payments for orders, our payment processing vendor collects your bitcoin wallet information or, where applicable, your credit card information (credit card number, name on card, expiration date, and cvv) and your billing address. We do not receive or store Payment Information, but we will receive information about your order. By submitting your Payment Information, you expressly consent to the sharing of this information with our third-party payment processers and other service providers (including vendors who provide fraud detection services). We process Payment Information to bill and fulfill orders, to process payments, to honor our terms of use and contracts, and to manage the data associated with those purposes. The legal basis for this processing is consent or, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Order Information	When you place an order, we will receive information about the products or NFTs you have ordered. We will also remember your previous orders and associate this information with your Account Information. We process Order Information to operate our business; to provide our Sites, App, products, and services; to ensure the privacy and security of our Sites, App, products, and services; to maintain our databases and back-ups; to manage our relationship with you; to communicate with you; and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our App, Sites, and business; the proper management of our customer relationships and direct marketing; and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Communications and Inquiries	If you contact us, in addition to your Contact Information, we will receive the subject matter of your message and any comments, content, or other information that you choose to provide. We may associate your Communications and Inquiries with your Account Information. We process Communications and Inquiries to operate our business; to provide our Sites, App, products, and services; to provide support; to ensure the privacy and security of our Sites, App, products, and services; to maintain our databases and back-ups; to manage our relationship with you; to communicate with you; and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our App, Sites, and business; the proper management of our customer relationships and direct marketing; and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Cookies and Similar Technologies	The Sites use cookies and similar technologies as described in the "Cookies and Similar Technologies" section of this Policy.
Log Data	When you use our Sites or App, including in a case of an error, we collect data and information (through third-party products) that includes your devices Internet Protocol ("IP") address, device name, operating system version, the configuration of the app, the time and date of your use, and other statistics. We process Log Data to provide the App and Sites; to serve you the content and functionality you request; to ensure the privacy and security of our Sites, App, products, and services; to develop new services; to enhance your experience and provide you with a more personal and interactive experience; and for usage analytics purposes. The legal basis for this processing is our legitimate interests in monitoring and improving our Sites.
Killer Whales Applications	Projects that apply to be on the show ‘Killer Whales‘ (the ‘Show) will be required to fill in a form via the Site, including but not limited to the collecting of data: Personal contact information; name, surname, email, wallet address, and referred or found by information. Project information; name, type, category, tagline, website, description. Social media information: all current and ongoing updates around multiple platforms of social media. At request, applicants may be required to provide further information including, but not limited to additional: Personal, project, cryptocurrency-specific, and technical information. By filling in the online form on the Site and proceeding with the application, you agree and understand that any future claims of copyright infringement based on similarities of content or projects in all aspects is by coincidence and not intended to harm or copy in any way. All data collected through the Site complies with all laws and regulations found within this privacy policy. The information that is requested through the form is to ensure that the applicants have a foundational template and understand what is required of them by being accepted onto the show. Projects that appear on the show are not biased and do not encourage or base themselves as giving or receiving financial advice. All projects, teams, staff (contract or employed), applicants and all other relevant bodies understand that the Show is intended for entertainment purposes ONLY. HELLO Holdings Inc. and its subsidiaries are not responsible for any losses (financial or otherwise) or costs incurred as a result of or production around the Show. All applicants agree that they are a legal representative, owner, or CEO of the project and have full consent from any board, or legal owners of the project. All applicants agree and understand that no costs are covered by the Show, not limited to travel and accommodation, are not included. The Show applications are for a limited period only. Applicants are not guaranteed to appear on the show, and are at the discretion of any production and application stage progress teams.

No Sensitive Personal Information. We request that you do not provide us with sensitive personal information, including race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal record.

Other Processing Activities. We may also process personal information when necessary for the following:

• The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)

• Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)

• Compliance with federal, state, or local laws (The legal basis for this processing is compliance with a legal obligation to which we are subject.)

• Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate federal, state, or local law (The legal basis for this processing is compliance with a legal obligation to which we are subject.)

• Collection, use, retention, or disclosure of information that is deidentified or aggregated.

• Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.

We may process your personal information in connection with any of the purposes and uses described in this Policy on one or more of the following legal grounds:

• Because it is necessary to perform the tasks you have requested or to comply with your instructions or other contractual obligations between you and us;

• To comply with our legal obligations as well as to keep records of our compliance processes;

• Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;

• Because you have chosen to publish or display your personal information on a public area of the Sites, such as a comment area;

• Because it is necessary to protect your vital interests;

• Because it is necessary in the public interest; or

• Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.

Location of Processing. We are headquartered and have operations in the United States, and personal information may be transferred to, stored, and processed in the United States and other countries in which we or our partners, service providers, or agents maintain facilities. By sending us personal information or using the Sites, you agree and consent to the processing of your personal information in locations such as the United States, which may not offer the levels of protection required in other countries. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information, such as express consent, when transfer is necessary for us to deliver services pursuant to an agreement, or when the transfer is subject to safeguards that assure the protection of the personal information.

Third Party Collection. The Sites and App use third-party services that may collect information used to identify you. Links to the privacy policies of our third-party service providers used by the App are below:

• Sumsub

• Google Play Services

• Google Analytics for Firebase

• Firebase Crashlytics

• Unity

• OpenSea

Cookies and Similar Technologies

First and Third-Party Cookies

Cookies are files with a small amount of data that are commonly used as unique identifiers. These are sent to your browser from the websites that you visit and are stored on your devices internal memory.

This App does not use these "cookies" explicitly. However, the app may use third-party code and libraries that use "cookies" to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

"Session" cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. "Persistent" or "permanent" cookies remain stored on your hard drive until they expire or are deleted by you. Local shared objects (or "flash" cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

Other Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. In addition, UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

What Cookies and Similar Technologies Are in Use and Why Do We Use Them?

We process cookies and similar technologies to provide the Sites, to serve you the content and functionality you request, to ensure the privacy and security of our Sites, to develop new services, to enhance your experience and provide you with a more personal and interactive experience, and for usage analytics purposes. Where required by law, we rely on your express opt-in consent for the use of marketing, performance, and analytic cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Sites and business.

Please read below for more information about cookies and technologies in use on the Sites:

Google Tag Manager. We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information. Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Sites and to better understand how they find and use the Sites. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions. The information stored is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the "Google Analytics opt-out browser add-on" page located at https://support.google.com/analytics/answer/181881?hl=en. Google Analytics relies on the following cookies:

Cookie	Description	Type	Duration
_ga	Used to distinguish users	Analytics	2 years
gat_UA-*	Used to throttle request rate	Analytics	1 minute
_gid	Used to distinguish users	Analytics	1 day

Shopify. We use Shopify to power our online store, and they are our ecommerce vendor. You can learn more about Shopify’s privacy practices at:

Cookie	Description	Type	Duration
_ab	Used in connection with access to admin.	Necessary	2y
_secure_session_id	Used in connection with navigation through a storefront.	Necessary	24h
_shopify_country	Used in connection with checkout.	Necessary	session
_shopify_m	Used for managing customer privacy settings.	Necessary	1y
_shopify_tm	Used for managing customer privacy settings.	Necessary	30min
_shopify_tw	Used for managing customer privacy settings.	Necessary	2w
_storefront_u	Used to facilitate updating customer account information.	Necessary	1min
_tracking_consent	Tracking preferences.	Necessary	1y
c	Used in connection with checkout.	Necessary	1y
cart	Used in connection with shopping cart.	Necessary	2w
cart_currency	Used in connection with shopping cart.	Necessary	2w
cart_sig	Used in connection with checkout.	Necessary	2w
cart_ts	Used in connection with checkout.	Necessary	2w
cart_ver	Used in connection with shopping cart.	Necessary	2w
checkout	Used in connection with checkout.	Necessary	4w
checkout_token	Used in connection with checkout.	Necessary	1y
dynamic_checkout_shown_on_ca rt	Used in connection with checkout.	Necessary	30min
hide_shopify_pay_for_checkout	Used in connection with checkout.	Necessary	session
hide_shopify_pay_for_checkout	Used in connection with checkout.	Necessary	session
keep_alive	Used in connection with buyer localization.	Necessary	2w
master_device_id	Used in connection with merchant login.	Necessary	2y
previous_step	Used in connection with checkout.	Necessary	1y
remember_me	Used in connection with checkout.	Necessary	1y
secure_customer_sig	Used in connection with customer login.	Necessary	20y
shopify_pay	Used in connection with checkout.	Necessary	1y
shopify_pay_redirect	Used in connection with checkout.	Necessary	30 minutes, 3w or 1y depending on value
storefront_digest	Used in connection with customer login.	Necessary	2y
tracked_start_checkout	Used in connection with checkout.	Necessary	1y
checkout_one_experiment	Used in connection with checkout.	Necessary	session

𝕏 Button. We use 𝕏 Button on the Sites. As a result, certain pages make requests to 𝕏’s servers for you to be able to tweet our webpages using your 𝕏 account. These requests may make your IP address, browser type, operating system, hardware type, internet service provider, pages visited, location, your mobile carrier, and device information (including device and application IDs) visible to 𝕏, who may use it in accordance with their data privacy policy: https://𝕏.com/en/privacy.

reCAPTCHA. We use reCAPTCHA to protect our Sites against common web-based attacks. For more information please visit: https://www.google.com/recaptcha/about. You may view Google’s privacy policy at: https://www.google.com/intl/en/policies/privacy. reCAPTCHA relies on the following cookie:

Cookie	Description	Type	Duration
_GRECAPTCH A	reCAPTCHA sets this necessary cookie when executed for the purpose of providing its risk analysis	Necessary	6 months

Other Third-Party Technologies

Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may choose to not allow certain cookies via the cookies consent banner or set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website technologies. These settings may affect your enjoyment of the full functionality of the Sites. In addition, adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers:

Google Chrome	https://support.google.com/chrome/answer/95647?hl=en
Firefox	https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer	http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Safari	https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265

To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information about how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work, or http://www.networkadvertising.org/choices.

How do we disclose or share the information described in this Policy? Where permitted by applicable law, we may share the information described above in the following contexts:

Category	Description
Blockchain	Transaction information related to your use of the App, Sites, and services may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when block chain data is combined with other data. Because blockchains are decentralized or third-party networks that are not controlled or operated by us or our affiliates, we are not able to erase, modify, or alter personal data from such networks.
Affiliates	We may share your information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.
Acquisitions and Similar Transactions	We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets. If our business is acquired by or merged with another company, your information may be transferred to the new owners.
Disclosures with Your Consent	We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your information in this context with your consent.
Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants)	We may disclose information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts.
Third Parties	We may provide information about you to third parties that may offer products and services specifically requested by you.
Service Providers	We may share information with our service providers that need access to information to provide operational or other support services on our behalf. We may employ third-party companies and individuals due to the following reasons: To facilitate our App, Sites, and services; To provide the App, Sites, and service on our behalf; To perform services; To perform identity verification; and To assist us in analyzing how our App, Sites, and services are used.
Professional Advisors	We may share your information with our and our affiliates’ insurers and professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.
Deidentified or Aggregated Data	We may disclose aggregated information or de-identified information that does not identify any specific individual, such as groupings of demographic data or customer preferences.

HOW LONG DO WE STORE AND USE YOUR INFORMATION?

We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements.

We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.

SECURITY

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods.

But, remember, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the App or the Sites. Your use of the App and the Sites is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION

Please use the "Contact Us" details provided at the end of this Policy or other methods described below to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law.

Email Opt-Out. We may send you emails about our services and other updates. If you no longer wish to receive communications from us via email, you may opt-out by clicking the "unsubscribe" link at the bottom of our emails or by contacting us at via the "Contact Us" details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Please note that registered users cannot opt out of receiving transactional e-mails related to their account.

Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the "Contact Us" details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the "Contact Us" details provided at the end of this Policy.

Individual Rights. You may have certain rights relating to your personal data under local data protection laws, and we discuss the rights provided in various jurisdictions below. We honor individuals’ rights where required under applicable law, and, depending on the applicable laws, these rights may include the right to:

• Access your personal information;

• more about how we process your personal information;

• Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;

• Erase or delete your personal information;

• Restrict our processing of your personal information;

• Transfer your personal information to another controller, to the extent possible;

• Object to certain processing of your personal information;

• Opt-out of certain disclosures of your personal information to third parties;

• If you’re under the age of 16, or such other applicable age of consent, opt-in to certain disclosures of your personal information to third parties;

• Not be discriminated against for exercising your rights described above;

• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and

• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

All requests should be sent to the contact details noted in the "Contact Us" section of this Policy or as otherwise described below. Your personal information may be processed in responding to these rights.

California Residents

All terms used in this section shall have the meanings given in the California Consumer Privacy Act ("CCPA"), when applicable.

CCPA Notice at Collection. We collect and process personal information as described in the "Information Collection and Processing" section of this Policy. The relevant CCPA categories for this information are listed below. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.

Category	CCPA Categories
Contact Information	For purposes of the CCPA, Contact Information includes the following categories of personal information: Identifiers Personal Information Under California’s Customer Records Statute
Account Information	For purposes of the CCPA, Account Information includes the following categories of personal information: Identifiers Personal Information Under California’s Customer Records Statute
Account Verification Information	For purposes of the CCPA, Account Verification Information includes the following categories of personal information: Identifiers Personal Information Under California’s Customer Records Statute
Payment Information	For purposes of the CCPA, Payment Information includes the following categories of personal information: Identifiers Personal Information Under California’s Customer Records Statute
Payment Information	For purposes of the CCPA, Payment Information includes the following categories of personal information: Identifiers Personal Information Under California’s Customer Records Statute
Order Information	For purposes of the CCPA, Order Information includes the following categories of personal information: Commercial Information
Communications and Inquiries	For purposes of the CCPA, Communications and Inquiries includes the following categories of personal information: Identifiers Personal Information Under California’s Customer Records Statute Commercial Information Audio, Electronic, Visual, or Similar Information
Cookies and Similar Technologies	For purposes of the CCPA, Cookies and Similar Technologies includes the following categories of personal information: Identifiers Internet or Other Electronic Network Activity Information
Log Data	For purposes of the CCPA, Device and Usage Information includes the following categories of personal information: Identifiers Internet or Other Electronic Network Activity Information

Data Practices During Last 12 Months. The information below describes our data practices during the last twelve months:

• Personal Information Collected: We have collected the categories of personal information listed below during the preceding 12 months:

  • Identifiers

  • Personal Information Under California’s Customer Records Statute o Commercial Information

  • Internet or Other Electronic Network Activity Information

  • Audio, Electronic, Visual, or Similar Information

• Categories of Sources: We have collected the personal information identified in this Policy from you and public sources.

• Business and Commercial Purposes for Collecting: We have collected the categories of personal information listed above for the following purposes:

  • To operate our business

  • To provide our Sites, App, products, and services

  • To provide support

  • To ensure the privacy and security of our Sites, App, products, and services

  • To maintain our databases and back-ups

  • To manage our relationship with you

  • To communicate with you

  • To keep records of our communications with you

  • To bill and fulfill orders

  • To process payments

  • To honor our terms of use and contracts and to manage the data associated with those purposes

  • To serve you the content and functionality you request

  • To develop new services

  • To enhance your experience and provide you with a more personal and interactive experience

  • Usage analytics purposes

  • Identity verification purposes

• Personal Information Sold: We have not sold categories of personal information during the preceding 12 months.

• Personal Information Disclosed for a Business Purpose: We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months. We have disclosed each category of personal information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (e.g., accountants, attorneys); (3) service providers (e.g., data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.

  • Identifiers

  • Personal Information Under California’s Customer Records Statute

  • Commercial Information

  • Internet or Other Electronic Network Activity Information

  • Audio, Electronic, Visual, or Similar Information

No Financial Incentive. We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.

Do Not Sell My Personal Information. Under the CCPA, you have the right to direct us to stop selling your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell personal information as defined under applicable law.

CCPA Requests to Know and Requests to Delete. California consumers have the right to request that we (1) disclose what personal information we collect, use, disclose, and sell, and (2) delete certain personal information that we have collected or maintain. However, there are exceptions. By way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold.

Request to Know. As a California resident, you have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold and the categories of third parties to whom the personal information was sold; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling personal information; and (7) the categories of third parties with whom we share personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request.

Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Submission Process. You may submit a request to know or to delete via email to [e-mail]. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.

Verification Process. We are required to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you couldl be required to provide your name, address, and telephone number. We will inform you if we cannot verify your identity.

• If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.

• If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.

• If we cannot verify the identity of the person making a request to delete, we may deny the request.

• If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our App or Sites may make any changes to their information at any time by contacting us at [e-mail].

Nevada Residents

You may submit a verified request to us at [e-mail] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request. We will respond to your request in accordance with Nevada law.

EU/EEA Residents

Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.

Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

Right to Erasure. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Restrict Processing. You have the right to restrict the processing of your data when (1) the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.

Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Right to Complain. If you believe we have not processed your personal information in accordance with applicable law, we encourage you to contact us at [e-mail]. You may also have the right to make a complaint to an applicable Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities for residents of the EU or EEA is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

LINKS TO OTHER SITES

This Policy only applies to our Sites, App, and services, and it does not apply to any third-party websites or applications.

The Sites and App may contain links to other sites. If you click on a third-party link, you will be directed to that site. Because of the dynamic media capabilities of the App and the Sites, it may not be clear to you which links are to external, third-party resources. You can check the URL to confirm that you have left our Sites or App. Note that these external sites are not operated by us, and these third parties have their own privacy policies. Therefore, we strongly advise you to review the Privacy Policy of these websites.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the App or the Sites.

Your use of Google Pay or Apple Pay is subject to the terms and conditions, including the privacy policies, of Google and Apple, respectively.

CHILDREN’S PRIVACY

Our App, Sites, and services are not directed at anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 years of age. No one under the age of 13 may access, browse, or use the App or the Sites or provide any information to or on the App or the Sites. If you are under 13, please do not use or provide any information on the App or the Sites (including, for example, your name, telephone number, email address, or username).

In the case we discover that a child under 13 has provided us with personal information without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do the necessary actions.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. Should this Policy change, we will post all changes to this Policy on this page. Any such changes, updates, or modifications will be effective immediately upon posting.

Thus, you are advised to review this page periodically for any changes. Your continued use of the App or the Sites after the "Last Updated" date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, you should not use the App or the Sites.

This policy was last updated as of the date listed at the top of this page.

CONTACT US

For more information, or if you have any questions about our Privacy Policy, do not hesitate to contact us at [e-mail].