Agoyu Platform Privacy Policy

Last modified: September 1, 2020

Introduction

Agoyu, LLC, a Puerto Rico limited liability company ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the Platform and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy applies to the Platform, which includes all sites, mobile applications, and other online services made available by us.  

IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM

This policy applies to information we collect:

  • On this Platform.
  • On Mobile Applications.
  • In email, text, and other electronic messages between you and this Platform.
  • Through mobile and desktop applications you download from this Platform, which provide dedicated non-browser-based interaction between you and this Platform.
  • When you interact with our advertising and applications on third-party Platforms and services, if those applications or advertising include links to this policy.
  • It does not apply to information collected by:
  • Us offline or through any other means, including on any other Platform operated by Company or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using this Platform, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Platform. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Platform or through any of its features, register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of this Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Platform, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted or identified online or offline ("personal information");
  • That is about you but individually does not identify you, such as move date, moving location, and shipment weight; and/or
  • About your internet connection, location, the equipment you use to access our Platform, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our participating movers, service providers and business partners.

Information You Provide to Us 

The information we collect on or through our Platform may include:

  • Information that you provide by filling in forms on our Platform. This includes information provided at the time of requesting a mover estimate, registering to use our Platform, posting material (including mover reviews), or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Platform.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes or customer satisfaction purposes.
  • Details of transactions you carry out through our Platform and of the fulfillment of your orders and moves. You may be required to provide financial information before placing an order through our Platform.
  • Your search queries on the Platform.
  • Information regarding your move, including where you are moving from and to, the type of goods and household items that you are moving and the size thereof, along with other information related to your move.
  • Location information (including real time).

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Platform, or transmitted to other users of the Platform, movers or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

We may collect information about you or others through our affiliates or through non-affiliated third parties. For example, you may be able to access the Platform through a social networking account, such as Facebook. If you access the Platform through your Facebook account, you may allow us to have access to certain information in your Facebook profile. This may include your name, profile picture, gender, networks, user IDs, list of friends, location, date of birth, email address, photos, videos, people you follow and/or who follow you, and/or your posts or "likes." Social networking sites, such as Facebook, have their own policies for handling your information. For a description of how these sites may use and disclose your information, including any information you make public, please consult the sites' privacy policies. We have no control over how any third-party site uses or discloses the personal information it collects about you.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
  • Information about your computer and internet connection, mobile device, including your IP address, operating system, browser type, hardware type, operating system, network, and service providers.

We also may use these technologies to collect information about your online activities over time and across third-party Platforms or other online services (behavioral tracking).

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Platform according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Platform.

The technologies we may use for this automatic data collection might include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
  • Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Platform and our e-mails 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 Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity).
  • GPS.   If you install our mobile app, we may ask you to grant us access to your mobile device's geolocation data. If you grant such permission, we may collect information about your precise geolocation, and we may use that information to improve the Platform, including providing you with location-based features. To deliver customized content and advertising, we may share your location information with our agents, vendors, or advertisers. If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details. If you disable certain functions, you may be unable to use certain parts of the Platform.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Platform may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Platforms and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Platform and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us or any of our participating movers, including for billing and collection.
  • To notify you about changes to our Platform or any products or services we offer or provide through it.
  • To allow you to participate in interactive features on our Platform.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To our participating movers and their affiliates.
  • To a buyer or other successor in the event of 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 information held by us about our Platform users is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • To provide information about users to third parties for academic and research purposes.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's Platform. If you disable or refuse cookies, please note that some parts of the Platform may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email with your request to [email protected].
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product service experience or other transaction.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by visiting the Network Advertising Initiative's Consumer Opt-Out Link (https://optout.networkadvertising.org/?c=1)  and/or the Digital Advertising Alliance's Consumer Opt-Out Link (https://optout.aboutads.info/?) to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google Display Network ads, you can visit the Google Ads Settings page (https://adssettings.google.com/authenticated). Please note that to the extent advertising technology is integrated into the Platform, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's Platforms, accessible by the above links. We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: [email protected].

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Platform and visiting your account profile page.

You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by our terms of use.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see the below California Supplement.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using commercially standard practices and technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards or mover reviews. The information you share in public areas may be viewed by any user of the Platform.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

The Platform may contain links to other platforms or resources over which we do not have any control. Such links do not constitute an endorsement by us of those external platforms or resources. You acknowledge that we are providing these links to you only as a convenience, and further agree that we are not responsible for the content of such external platforms and resources or the protection and privacy of information you provide while visiting such external platforms and resources.

Our computer systems are currently based in the United States, so your personal data will be processed by us in the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. If you engage in a transaction on the Platform as a visitor from outside the United States, by using the Platform, you agree to this Policy and you consent to the transfer of all such information to the United States, which may not offer a level of protection equivalent to that required in Canada, the European Union or certain other countries, and to the processing of that information as described in this Policy.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Platform home page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Platform home page and by email. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at [email protected].  To register a complaint or concern, please email us at [email protected].


Agoyu Platform Privacy Supplement for California Residents

Effective Date: September 1, 2020

Last Reviewed on: September 1, 2020

This Privacy Notice for California Residents supplements the information contained in Agoyu’s Platform Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.


Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Our Platform launched in September 2020 and as a result we have a limited operating history.  As of the date of this Privacy Addendum we have collected the following categories of personal information from California consumers within the last twelve (12) months:

[PERSONAL INFORMATION][/PERSONAL INFORMATION]

We may obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Platform.
  • As described in our Privacy Policy at “Information We Collect About You and How We Collect It”.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, 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. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Platform, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Platform, products, and services.
  • 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.
  • 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 information held by us  about our users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.


Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business 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. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To our participating movers and their affiliates.
  • To a buyer or other successor in the event of 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 information held by us about our Platform users is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have not disclosed the following categories of personal information for a business purpose:

Category C: Protected classification characteristics under California or federal law.

Category E: Biometric information.

Category H: Sensory data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • See categories listed above.

Sales of Personal Information

In the preceding twelve (12) months as of the date of this Policy, we had not sold personal information.

 
Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) to:

1.      Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2.      Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.      Debug products to identify and repair errors that impair existing intended functionality.

4.      Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.      Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6.      Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7.      Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8.      Comply with a legal obligation.

9.      Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.


Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through any password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.


Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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


Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at [email protected].

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at [email protected].

 You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.


Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.


Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].


Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Platform and update the notice's effective date. Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes.


Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in the Platform Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact by emailing at [email protected].