Last modified on August 22, 2022

This Privacy Policy describes Our policiesand procedures on the collection, use and disclosure of Your information whenYou use the Service and tells You about Your privacy rights and how the law protectsYou.

We use Your Personal data to provide andimprove the Service. By using the Service, You agree to the collection and useof information in accordance with this Privacy Policy.

Interpretation and Definitions


The words of which the initial letter iscapitalized have meanings defined under the following conditions. The followingdefinitions shall have the same meaning regardless of whether they appear insingular or in plural.


For the purposes of this Privacy Policy:

Account means a unique account createdfor 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 entitythat collects Consumers' personal information and determines the purposes andmeans of the processing of Consumers' personal information, or on behalf ofwhich 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 "theCompany", "We", "Us" or "Our" in thisAgreement) refers to YouShd Inc., 777 Hamilton Avenue, Apt G301, Menlo Park, CA94025.

For the purpose of theGDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA(California Consumer Privacy Act), means a natural person who is a Californiaresident. A resident, as defined in the law, includes (1) every individual whois in the USA for other than a temporary or transitory purpose, and (2) everyindividual who is domiciled in the USA who is outside the USA for a temporaryor transitory purpose.

Cookies are small files that are placedon Your computer, mobile device or any other device by a website, containingthe details of Your browsing history on that website among its many uses.

Country refers to: California, UnitedStates

Data Controller, for the purposes of theGDPR (General Data Protection Regulation), refers to the Company as the legalperson which alone or jointly with others determines the purposes and means ofthe processing of Personal Data.

Device means any device that can accessthe Service such as a computer, a cellphone or a digital tablet.

Do Not Track (DNT) is a concept that hasbeen promoted by US regulatory authorities, in particular the U.S. FederalTrade Commission (FTC), for the Internet industry to develop and implement amechanism for allowing internet users to control the tracking of their onlineactivities across websites.

Facebook Fan Page is a public profilenamed YouShd.fb specifically created by the Company on the Facebook socialnetwork, accessible from

Personal Data is any information thatrelates to an identified or identifiable individual.

For the purposes of GDPR,Personal Data means any information relating to You such as a name, anidentification number, location data, online identifier or to one or morefactors specific to the physical, physiological, genetic, mental, economic,cultural or social identity.

For the purposes of theCCPA, Personal Data means any information that identifies, relates to,describes or is capable of being associated with, or could reasonably belinked, 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 otherwisecommunicating orally, in writing, or by electronic or other means, a Consumer'spersonal information to another business or a third party for monetary or othervaluable consideration.

Service refers to the Website.

Service Provider means any natural orlegal person who processes the data on behalf of the Company. It refers tothird-party companies or individuals employed by the Company to facilitate theService, to provide the Service on behalf of the Company, to perform servicesrelated to the Service or to assist the Company in analyzing how the Service isused. For the purpose of the GDPR, Service Providers are considered DataProcessors.

Third-party Social Media Service refersto any website or any social network website through which a User can log in orcreate an account to use the Service.

Usage Data refers to data collectedautomatically, either generated by the use of the Service or from the Serviceinfrastructure itself (for example, the duration of a page visit).

Website refers to YouShd, accessiblefrom

You means the individual accessing orusing the Service, or the company, or other legal entity on behalf of whichsuch individual is accessing or using the Service, as applicable.

Under GDPR (General DataProtection Regulation), You can be referred to as the Data Subject or as theUser 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 toprovide Us with certain personally identifiable information that can be used tocontact or identify You. Personally identifiable information may include, butis 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 whenusing the Service.

Usage Data may include information such asYour 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 ofYour visit, the time spent on those pages, unique device identifiers and otherdiagnostic data.

When You access the Service by or through amobile device, We may collect certain information automatically, including, butnot limited to, the type of mobile device You use, Your mobile device uniqueID, the IP address of Your mobile device, Your mobile operating system, thetype of mobile Internet browser You use, unique device identifiers and otherdiagnostic data.

We may also collect information that Yourbrowser sends whenever You visit our Service or when You access the Service byor through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an accountand log in to use the Service through the following Third-party Social MediaServices:

  • Google
  • Facebook
  • Twitter
  • LinkedIn

If You decide to register through orotherwise grant us access to a Third-Party Social Media Service, We may collectPersonal data that is already associated with Your Third-Party Social MediaService's account, such as Your name, Your email address, Your activities orYour contact list associated with that account.

You may also have the option of sharingadditional information with the Company through Your Third-Party Social MediaService's account. If You choose to provide such information and Personal Data,during registration or otherwise, You are giving the Company permission to use,share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar trackingtechnologies to track the activity on Our Service and store certaininformation. Tracking technologies used are beacons, tags, and scripts tocollect and track information and to improve and analyze Our Service. Thetechnologies We use may include:

  •  Cookies or Browser Cookies. A cookie isa small file placed on Your Device. You can instruct Your browser to refuse allCookies or to indicate when a Cookie is being sent. However, if You do notaccept Cookies, You may not be able to use some parts of our Service. Unlessyou have adjusted Your browser setting so that it will refuse Cookies, ourService may use Cookies.
  • Flash Cookies. Certain features of ourService may use local stored objects (or Flash Cookies) to collect and storeinformation about Your preferences or Your activity on our Service. FlashCookies are not managed by the same browser settings as those used for BrowserCookies. For more information on how You can delete Flash Cookies, please read"Where can I change the settings for disabling, or deleting local sharedobjects?" available at flash.
  • Web Beacons. Certain sections of ourService 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 permitthe Company, for example, to count users who have visited those pages or openedan email and for other related website statistics (for example, recording thepopularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or"Session" Cookies. Persistent Cookies remain on Your personalcomputer or mobile device when You go offline, while Session Cookies aredeleted as soon as You close Your web browser. You can learn more about cookieson TermsFeedwebsite article.

We use both Session and Persistent Cookiesfor the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies areessential to provide You with services available through the Website and toenable You to use some of its features. They help to authenticate users andprevent fraudulent use of user accounts. Without these Cookies, the servicesthat You have asked for cannot be provided, and We only use these Cookies toprovide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookiesidentify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookiesallow us to remember choices You make when You use the Website, such asremembering your login details or language preference. The purpose of theseCookies is to provide You with a more personal experience and to avoid Youhaving to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by:Third-Parties

Purpose: These Cookies areused to track information about traffic to the Website and how users use theWebsite. The information gathered via these Cookies may directly or indirectlyidentify you as an individual visitor. This is because the informationcollected is typically linked to a pseudonymous identifier associated with thedevice you use to access the Website. We may also use these Cookies to test newpages, features or new functionality of the Website to see how our users reactto them.

For more information about the cookies weuse and your choices regarding cookies, please visit our Cookies Policy or theCookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for thefollowing purposes:

To provide and maintain our Service,including to monitor the usage of our Service.

To manage Your Account: to manage Yourregistration as a user of the Service. The Personal Data You provide can giveYou access to different functionalities of the Service that are available toYou as a registered user.

For the performance of a contract: thedevelopment, compliance and undertaking of the purchase contract for theproducts, items or services You have purchased or of any other contract with Usthrough 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 orinformative communications related to the functionalities, products orcontracted services, including the security updates, when necessary orreasonable for their implementation.

To provide You with news, special offersand general information about other goods, services and events which we offerthat are similar to those that you have already purchased or enquired aboutunless You have opted not to receive such information.

To manage Your requests: To attend andmanage Your requests to Us.

For business transfers: We may use Yourinformation to evaluate or conduct a merger, divestiture, restructuring,reorganization, dissolution, or other sale or transfer of some or all of Ourassets, whether as a going concern or as part of bankruptcy, liquidation, orsimilar proceeding, in which Personal Data held by Us about our Service usersis among the assets transferred.

For other purposes: We may use Yourinformation for other purposes, such as data analysis, identifying usagetrends, determining the effectiveness of our promotional campaigns and toevaluate and improve our Service, products, services, marketing and yourexperience.

We may share Your personal information inthe following situations:

  • With Service Providers: We may shareYour personal information with Service Providers to monitor and analyze the useof our Service, to contact You.
  • For business transfers: We may share ortransfer Your personal information in connection with, or during negotiationsof, any merger, sale of Company assets, financing, or acquisition of all or aportion of Our business to another company.
  • With Affiliates: We may share Yourinformation with Our affiliates, in which case we will require those affiliatesto honor this Privacy Policy. Affiliates include Our parent company and anyother subsidiaries, joint venture partners or other companies that We controlor that are under common control with Us.
  • With business partners: We may shareYour information with Our business partners to offer You certain products,services or promotions.
  • With other users: when You sharepersonal information or otherwise interact in the public areas with otherusers, such information may be viewed by all users and may be publiclydistributed outside. If You interact with other users or register through aThird-Party Social Media Service, Your contacts on the Third-Party Social MediaService may see Your name, profile, pictures and description of Your activity.Similarly, other users will be able to view descriptions of Your activity,communicate with You and view Your profile.
  • With Your consent: We may disclose Yourpersonal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Dataonly for as long as is necessary for the purposes set out in this PrivacyPolicy. We will retain and use Your Personal Data to the extent necessary tocomply with our legal obligations (for example, if we are required to retainyour data to comply with applicable laws), resolve disputes, and enforce ourlegal agreements and policies.

The Company will also retain Usage Data forinternal analysis purposes. Usage Data is generally retained for a shorterperiod of time, except when this data is used to strengthen the security or toimprove the functionality of Our Service, or We are legally obligated to retainthis 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 wherethe parties involved in the processing are located. It means that thisinformation may be transferred to — and maintained on — computers locatedoutside of Your state, province, country or other governmental jurisdictionwhere the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policyfollowed by Your submission of such information represents Your agreement tothat transfer.

The Company will take all steps reasonablynecessary to ensure that Your data is treated securely and in accordance with thisPrivacy Policy and no transfer of Your Personal Data will take place to anorganization or a country unless there are adequate controls in place includingthe 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 willprovide notice before Your Personal Data is transferred and becomes subject toa different Privacy Policy.

Law enforcement

Under certain circumstances, the Companymay be required to disclose Your Personal Data if required to do so by law orin response to valid requests by public authorities (e.g. a court or agovernment agency).

Other legal requirements

The Company may disclose Your Personal Datain the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rightsor property of the Company
  • Prevent or investigate possiblewrongdoing in connection with the Service
  • Protect the personal safety ofUsers of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data isimportant to Us, but remember that no method of transmission over the Internet,or method of electronic storage is 100% secure. While We strive to usecommercially acceptable means to protect Your Personal Data, We cannotguarantee its absolute security.

Detailed Information on the Processing ofYour Personal Data

The Service Providers We use may haveaccess to Your Personal Data. These third-party vendors collect, store, use,process and transfer information about Your activity on Our Service inaccordance with their Privacy Policies.


We may use third-party Service providers tomonitor and analyze the use of our Service.

Google Analytics

Google Analytics is a webanalytics service offered by Google that tracks and reports website traffic.Google uses the data collected to track and monitor the use of our Service.This data is shared with other Google services. Google may use the collecteddata to contextualize and personalize the ads of its own advertising network.

You can opt-out of havingmade your activity on the Service available to Google Analytics by installingthe Google Analytics opt-out browser add-on. The add-on prevents the GoogleAnalytics JavaScript (ga.js, analytics.js and dc.js) from sharing informationwith Google Analytics about visits activity.

For more information on theprivacy practices of Google, please visit the Google Privacy & Terms webpage:

Email Marketing

We may use Your Personal Data to contactYou with newsletters, marketing or promotional materials and other informationthat may be of interest to You. You may opt-out of receiving any, or all, ofthese communications from Us by following the unsubscribe link or instructionsprovided in any email We send or by contacting Us.

We may use Email Marketing Service Providersto manage and send emails to You.


Mailchimp is an emailmarketing sending service provided by The Rocket Science Group LLC.

For more information on theprivacy practices of Mailchimp, please visit their Privacy policy:

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under thefollowing conditions:

  • Consent: You have given Your consent forprocessing Personal Data for one or more specific purposes.
  •  Performance of a contract: Provision ofPersonal Data is necessary for the performance of an agreement with You and/orfor any pre-contractual obligations thereof.
  • Legal obligations: Processing PersonalData is necessary for compliance with a legal obligation to which the Companyis subject.
  • Vital interests: Processing PersonalData is necessary in order to protect Your vital interests or of anothernatural person.
  • Public interests: Processing PersonalData is related to a task that is carried out in the public interest or in theexercise of official authority vested in the Company.
  • Legitimate interests: ProcessingPersonal Data is necessary for the purposes of the legitimate interests pursuedby the Company.

In any case, the Company will gladly helpto clarify the specific legal basis that applies to the processing, and inparticular whether the provision of Personal Data is a statutory or contractualrequirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect theconfidentiality of Your Personal Data and to guarantee You can exercise Yourrights.

You have the right under this PrivacyPolicy, 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. Whenevermade possible, you can access, update or request deletion of Your Personal Datadirectly within Your account settings section. If you are unable to perform theseactions yourself, please contact Us to assist You. This also enables You toreceive 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 informationWe hold about You corrected.
  •  Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest asthe legal basis for Our processing and there is something about Your particularsituation, which makes You want to object to our processing of Your PersonalData on this ground. You also have the right to object where We are processingYour 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 nogood 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, YourPersonal Data in a structured, commonly used, machine-readable format. Pleasenote that this right only applies to automated information which You initiallyprovided consent for Us to use or where We used the information to perform acontract with You.
  • Withdraw Your consent. You have theright to withdraw Your consent on using your Personal Data. If You withdrawYour consent, We may not be able to provide You with access to certain specificfunctionalities 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 Youto verify Your identity before responding to such requests. If You make arequest, We will try our best to respond to You as soon as possible.

You have the right to complain to a DataProtection Authority about Our collection and use of Your Personal Data. Formore information, if You are in the European Economic Area (EEA), pleasecontact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of YourPersonal Data collected while using the Service. As operator of the FacebookFan Page,the Company and the operator of the social network Facebook are JointControllers.

The Company has entered into agreementswith Facebook that define the terms for use of the Facebook Fan Page, amongother things. These terms are mostly based on the Facebook Terms of Service:

Visit the Facebook Privacy Policy more information about how Facebook manages Personal data or contactFacebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function inconnection with the operation of the Facebook Fan Page and on the basis of theGDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookieon the device of the user visiting Our Facebook Fan Page. Each Cookie containsa unique identifier code and remains active for a period of two years, exceptwhen it is deleted before the end of this period.

Facebook receives, records and processesthe information stored in the Cookie, especially when the user visits theFacebook services, services that are provided by other members of the FacebookFan Page and services by other companies that use Facebook services.

For more information on the privacypractices of Facebook, please visit Facebook Privacy Policy here:

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 ofCalifornia.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, orcould reasonably be linked, directly or indirectly, with a particular Consumeror Device. The following is a list of categories of personal information whichwe may collect or may have been collected from California residents within thelast twelve (12) months.

Please note that the categories andexamples provided in the list below are those defined in the CCPA. This doesnot mean that all examples of that category of personal information were infact collected by Us, but reflects our good faith belief to the best of ourknowledge that some of that information from the applicable category may be andmay have been collected. For example, certain categories of personalinformation would only be collected if You provided such personal informationdirectly to Us.

Category A: Identifiers.

Examples: A real name,alias, postal address, unique personal identifier, online identifier, Internet Protocoladdress, email address, account name, driver's license number, passport number,or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the CaliforniaCustomer 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 stateidentification card number, insurance policy number, education, employment, employmenthistory, bank account number, credit card number, debit card number, or anyother financial information, medical information, or health insuranceinformation. Some personal information included in this category may overlapwith other categories.

Collected: Yes.

Category C: Protected classification characteristics underCalifornia or federal law.

Examples: Age (40 years orolder), 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 childbirthand related medical conditions), sexual orientation, veteran or militarystatus, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records andhistory of products or services purchased or considered.

Collected: No.

Category E: Biometric information.

Examples: Genetic,physiological, behavioral, and biological characteristics, or activity patternsused to extract a template or other identifier or identifying information, suchas, 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 withour Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximatephysical 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 pastjob history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the FamilyEducational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part99)).

Examples: Educationrecords directly related to a student maintained by an educational institutionor 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: Profilereflecting a person's preferences, characteristics, psychological trends,predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does notinclude:

  • Publicly available informationfrom government records
  • Deidentified or aggregatedconsumer information
  • Information excluded from theCCPA's scope, such as:
  • Health or medical informationcovered by the Health Insurance

·       Personal Information covered bycertain sector-specific privacy laws, including the Fair Credit Reporting Act(FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial InformationPrivacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personalinformation listed above from the following categories of sources:

  • Directly from You. For example, from theforms You complete on our Service, preferences You express or provide throughour Service.
  • Indirectly from You. For example, fromobserving Your activity on our Service.
  • Automatically from You. For example,through cookies We or our Service Providers set on Your Device as You navigatethrough our Service.
  • From Service Providers. For example,third-party vendors to monitor and analyze the use of our Service, or otherthird-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or CommercialPurposes

We may use or disclose personal informationWe collect for "business purposes" or "commercial purposes"(as defined under the CCPA), which may include the following examples:

  •  To operate our Service andprovide You with our Service.
  • To provide You with support andto respond to Your inquiries, including to investigate and address Yourconcerns and monitor and improve our Service.
  • To fulfill or meet the reasonYou provided the information. For example, if You share Your contactinformation to ask a question about our Service, We will use that personalinformation to respond to Your inquiry.
  • To respond to law enforcementrequests and as required by applicable law, court order, or governmentalregulations.
  • As described to You whencollecting Your personal information or as otherwise set forth in the CCPA.
  • For internal administrative andauditing purposes.
  • To detect security incidentsand protect against malicious, deceptive, fraudulent or illegal activity,including, when necessary, to prosecute those responsible for such activities.

Please note that the examples providedabove are illustrative and not intended to be exhaustive. For more details onhow we use this information, please refer to the "Use of Your PersonalData" section.

If We decide to collect additionalcategories of personal information or use the personal information We collectedfor materially different, unrelated, or incompatible purposes We will updatethis Privacy Policy.

Disclosure of Personal Information for Business Purposesor Commercial Purposes

We may use or disclose and may have used ordisclosed in the last twelve (12) months the following categories of personalinformation for business or commercial purposes:

Category A: Identifiers

Category B: Personal informationcategories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e))

Category F: Internet orother similar network activity

Please note that the categories listedabove are those defined in the CCPA. This does not mean that all examples ofthat category of personal information were in fact disclosed, but reflects ourgood faith belief to the best of our knowledge that some of that informationfrom the applicable category may be and may have been disclosed.

When We disclose personal information for abusiness purpose or a commercial purpose, We enter a contract that describesthe purpose and requires the recipient to both keep that personal informationconfidential 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 communicatingorally, in writing, or by electronic or other means, a consumer's personalinformation by the business to a third party for valuable consideration. Thismeans that We may have received some kind of benefit in return for sharingpersonal information, but not necessarily a monetary benefit.

Please note that the categories listedbelow are those defined in the CCPA. This does not mean that all examples ofthat category of personal information were in fact sold, but reflects our goodfaith belief to the best of our knowledge that some of that information fromthe applicable category may be and may have been shared for value in return.

We may sell and may have sold in the lasttwelve (12) months the following categories of personal information:

Category A: Identifiers

Category B: Personalinformation categories listed in the California Customer Records statute (Cal.Civ. Code § 1798.80(e))

Category F: Internet orother similar network activity

Share of Personal Information

We may share Your personal informationidentified in the above categories with the following categories of thirdparties:

Service Providers

Our affiliates

Our business partners

Third party vendors to whomYou or Your agents authorize Us to disclose Your personal information inconnection with products or services We provide to You

Sale of Personal Information of Minors Under 16 Years ofAge

We do not knowingly collect personalinformation from minors under the age of 16 through our Service, althoughcertain third party websites that we link to may do so. These third-partywebsites have their own terms of use and privacy policies and we encourageparents and legal guardians to monitor their children's Internet usage andinstruct their children to never provide information on other websites withouttheir permission.

We do not sell the personal information ofConsumers We actually know are less than 16 years of age, unless We receiveaffirmative authorization (the "right to opt-in") from either theConsumer who is between 13 and 16 years of age, or the parent or guardian of aConsumer less than 13 years of age. Consumers who opt-in to the sale ofpersonal information may opt-out of future sales at any time. To exercise theright to opt-out, You (or Your authorized representative) may submit a requestto Us by contacting Us.

If You have reason to believe that a childunder the age of 13 (or 16) has provided Us with personal information, pleasecontact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents withspecific rights regarding their personal information. If You are a resident ofCalifornia, You have the following rights:

  •   The right to notice. You have the rightto be notified which categories of Personal Data are being collected and thepurposes for which the Personal Data is being used.
  • The right to request. Under CCPA, Youhave the right to request that We disclose information to You about Ourcollection, use, sale, disclosure for business purposes and share of personalinformation. Once We receive and confirm Your request, We will disclose to You:
  • The categories of personalinformation We collected about You
  • The categories of sources forthe personal information We collected about You
  • Our business or commercialpurpose for collecting or selling that personal information
  • The categories of third partieswith whom We share that personal information
  • The specific pieces of personalinformation We collected about You
  • If we sold Your personalinformation or disclosed Your personal information for a business purpose, Wewill disclose to You:
  • The categories of personalinformation categories sold
  • The categories of personalinformation categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personalinformation. To submit an opt-out request please contact Us.
  • The right to delete Personal Data. Youhave the right to request the deletion of Your Personal Data, subject tocertain exceptions. Once We receive and confirm Your request, We will delete(and direct Our Service Providers to delete) Your personal information from ourrecords, unless an exception applies. We may deny Your deletion request if retainingthe information is necessary for Us or Our Service Providers to:
  • Complete the transaction forwhich We collected the personal information, provide a good or service that Yourequested, take actions reasonably anticipated within the context of our ongoingbusiness relationship with You, or otherwise perform our contract with You.
  • Detect security incidents,protect against malicious, deceptive, fraudulent, or illegal activity, orprosecute those responsible for such activities.
  • Debug products to identify andrepair errors that impair existing intended functionality.
  • Exercise free speech, ensurethe right of another consumer to exercise their free speech rights, or exerciseanother right provided for by law.
  • Comply with the CaliforniaElectronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public orpeer-reviewed scientific, historical, or statistical research in the publicinterest that adheres to all other applicable ethics and privacy laws, when theinformation's deletion may likely render impossible or seriously impair theresearch's achievement, if You previously provided informed consent.
  • Enable solely internal usesthat are reasonably aligned with consumer expectations based on Yourrelationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawfuluses of that information that are compatible with the context in which Youprovided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercisingany of Your consumer's rights, including by:
  • Denying goods or services toYou
  • Charging different prices orrates for goods or services, including the use of discounts or other benefitsor imposing penalties
  • Providing a different level orquality of goods or services to You
  • Suggesting that You willreceive a different price or rate for goods or services or a different level orquality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rightsunder the CCPA, and if You are a California resident, You can contact Us:

Only You, or a person registered with theCalifornia Secretary of State that You authorize to act on Your behalf, maymake a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient informationthat allows Us to reasonably verify You are the person about whom We collectedpersonal information or an authorized representative
  • Describe Your request withsufficient detail that allows Us to properly understand, evaluate, and respondto it

We cannot respond to Your request orprovide You with the required information if We cannot:

  • Verify Your identity orauthority to make the request
  • And confirm that the personalinformation relates to You

We will disclose and deliver the requiredinformation free of charge within 45 days of receiving Your verifiable request.The time period to provide the required information may be extended once by anadditional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only coverthe 12-month period preceding the verifiable request's receipt.

For data portability requests, We willselect a format to provide Your personal information that is readily usable andshould allow You to transmit the information from one entity to another entitywithout hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the saleof Your personal information. Once We receive and confirm a verifiable consumerrequest from You, we will stop selling Your personal information. To exerciseYour right to opt-out, please contact Us.

The Service Providers we partner with (forexample, our analytics or advertising partners) may use technology on theService that sells personal information as defined by the CCPA law. If you wishto opt out of the use of Your personal information for interest-basedadvertising purposes and these potential sales as defined under CCPA law, youmay do so by following the instructions below.

Please note that any opt out is specific tothe browser You use. You may need to opt out on every browser that You use.


You can opt out of receiving ads that arepersonalized as served by our Service Providers by following our instructionspresented on the Service:

  • The NAI's opt-out platform:
  • The EDAA's opt-out platform
  • The DAA's opt-out platform:

The opt out will place a cookie on Yourcomputer that is unique to the browser You use to opt out. If you changebrowsers or delete the cookies saved by your browser, You will need to opt outagain.

Mobile Devices

Your mobile device may give You the abilityto opt out of the use of information about the apps You use in order to serveYou ads that are targeted to Your interests:

  • "Opt out of Interest-BasedAds" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking"on iOS devices

You can also stop the collection oflocation information from Your mobile device by changing the preferences onYour mobile device.

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

Our Service does not respond to Do NotTrack signals.

However, some third party websites do keeptrack of Your browsing activities. If You are visiting such websites, You canset Your preferences in Your web browser to inform websites that You do notwant to be tracked. You can enable or disable DNT by visiting the preferencesor settings page of Your web browser.

Children's Privacy

Our Service does not address anyone underthe age of 13. We do not knowingly collect personally identifiable informationfrom anyone under the age of 13. If You are a parent or guardian and You areaware that Your child has provided Us with Personal Data, please contact Us. IfWe become aware that We have collected Personal Data from anyone under the ageof 13 without verification of parental consent, We take steps to remove thatinformation from Our servers.

If We need to rely on consent as a legalbasis for processing Your information and Your country requires consent from aparent, We may require Your parent's consent before We collect and use thatinformation.

Your California Privacy Rights (California'sShine the Light law)

Under California Civil Code Section 1798(California's Shine the Light law), California residents with an establishedbusiness relationship with us can request information once a year about sharingtheir Personal Data with third parties for the third parties' direct marketingpurposes.

If you'd like to request more informationunder 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 CodeSection 22581 allows California residents under the age of 18 who areregistered users of online sites, services or applications to request andobtain removal of content or information they have publicly posted.

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

Be aware that Your request does notguarantee complete or comprehensive removal of content or information postedonline and that the law may not permit or require removal in certaincircumstances.

Links to Other Websites

Our Service may contain links to otherwebsites that are not operated by Us. If You click on a third party link, Youwill be directed to that third party's site. We strongly advise You to reviewthe Privacy Policy of every site You visit.

We have no control over and assume noresponsibility for the content, privacy policies or practices of any thirdparty sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from timeto time. We will notify You of any changes by posting the new Privacy Policy onthis page.

We will let You know via email and/or aprominent notice on Our Service, prior to the change becoming effective andupdate the "Last updated" date at the top of this Privacy Policy.

You are advised to review this PrivacyPolicy periodically for any changes. Changes to this Privacy Policy areeffective when they are posted on this page.

Contact Us

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

·       By email: [email protected]

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