Privacy Policy

Last updated: December 30, 2022

This Privacy Policy describes Our policies and procedures onthe collection, use and disclosure of Your information when You use the Serviceand tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve theService. By using the Service, You agree to the collection and use ofinformation in accordance with this Privacy Policy.

Interpretation and Definitions


The words of which the initial letter is capitalized havemeanings defined under the following conditions. The following definitionsshall have the same meaning regardless of whether they appear in singular or inplural.


For the purposes of this Privacy Policy:

Accountmeans a unique account created for You to access our Service or parts of ourService.

Business,for the purpose of the CCPA (California Consumer Privacy Act), refers to theCompany as the legal entity that collects Consumers' personal information anddetermines the purposes and means of the processing of Consumers' personalinformation, or on behalf of which such information is collected and thatalone, or jointly with others, determines the purposes and means of theprocessing of consumers' personal information, that does business in the Stateof California.

Company(referred to as either "the Company", "We", "Us"or "Our" in this Agreement) refers to Nectar, 675 Ponce de Leon AveNE, Suite 9500, Atlanta, Georgia 30308, US.

For the purpose of the GDPR, the Company isthe Data Controller.

Consumer,for the purpose of the CCPA (California Consumer Privacy Act), means a naturalperson who is a California resident. A resident, as defined in the law,includes (1) every individual who is in the USA for other than a temporary ortransitory purpose, and (2) every individual who is domiciled in the USA who isoutside the USA for a temporary or transitory purpose.

Cookiesare small files that are placed on Your computer, mobile device or any otherdevice by a website, containing the details of Your browsing history on thatwebsite among its many uses.

Countryrefers to: Georgia, United States

DataController, for the purposes of the GDPR (General Data ProtectionRegulation), refers to the Company as the legal person which alone or jointlywith others determines the purposes and means of the processing of PersonalData.

Devicemeans any device that can access the Service such as a computer, a cellphone ora digital tablet.

DoNot Track (DNT) is a concept that has been promoted by US regulatoryauthorities, in particular the U.S. Federal Trade Commission (FTC), for theInternet industry to develop and implement a mechanism for allowing internetusers to control the tracking of their online activities across websites.

FacebookFan Page is a public profile named Nectar specifically created by theCompany on the Facebook social network, accessible from

PersonalData is any information that relates to an identified or identifiableindividual.

For the purposes of GDPR, Personal Datameans any information relating to You such as a name, an identification number,location data, online identifier or to one or more factors specific to the physical,physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Datameans any information that identifies, relates to, describes or is capable ofbeing associated with, or could reasonably be linked, directly or indirectly,with You.

Sale,for the purpose of the CCPA (California Consumer Privacy Act), means selling,renting, releasing, disclosing, disseminating, making available, transferring,or otherwise communicating orally, in writing, or by electronic or other means,a Consumer's personal information to another business or a third party formonetary or other valuable consideration.

Servicerefers to the Website.

ServiceProvider means any natural or legal person who processes the data on behalfof the Company. It refers to third-party companies or individuals employed bythe Company to facilitate the Service, to provide the Service on behalf of theCompany, to perform services related to the Service or to assist the Company inanalyzing how the Service is used. For the purpose of the GDPR, ServiceProviders are considered Data Processors.

UsageData refers to data collected automatically, either generated by the use ofthe Service or from the Service infrastructure itself (for example, theduration of a page visit).

Websiterefers to Nectar, accessible from

Youmeans the individual accessing or using the Service, or the company, or otherlegal entity on behalf of which such individual is accessing or using theService, as applicable.

Under GDPR (General Data ProtectionRegulation), You can be referred to as the Data Subject or as the User as youare the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us withcertain personally identifiable information that can be used to contact oridentify You. Personally identifiable information may include, but is notlimited to:

Email address

First name and last name

Phone number

Address, State, Province, ZIP/Postal code,City

Usage Data

Usage Data

Usage Data is collected automatically when using theService.

Usage Data may include information such as Your Device'sInternet Protocol address (e.g. IP address), browser type, browser version, thepages of our Service that You visit, the time and date of Your visit, the timespent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device,We may collect certain information automatically, including, but not limitedto, the type of mobile device You use, Your mobile device unique ID, the IPaddress of Your mobile device, Your mobile operating system, the type of mobileInternet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sendswhenever You visit our Service or when You access the Service by or through amobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to trackthe activity on Our Service and store certain information. Tracking technologiesused are beacons, tags, and scripts to collect and track information and toimprove and analyze Our Service. The technologies We use may include:

·      Cookiesor Browser Cookies. A cookie is a small file placed on Your Device. You caninstruct Your browser to refuse all Cookies or to indicate when a Cookie isbeing sent. However, if You do not accept Cookies, You may not be able to usesome parts of our Service. Unless you have adjusted Your browser setting sothat it will refuse Cookies, our Service may use Cookies.

·      WebBeacons. Certain sections of our Service and our emails may contain smallelectronic files known as web beacons (also referred to as clear gifs, pixeltags, and single-pixel gifs) that permit the Company, for example, to countusers who have visited those pages or opened an email and for other relatedwebsite statistics (for example, recording the popularity of a certain sectionand verifying system and server integrity).

Cookies can be "Persistent" or "Session"Cookies. Persistent Cookies remain on Your personal computer or mobile devicewhen You go offline, while Session Cookies are deleted as soon as You closeYour web browser. You can learn more about cookies on TermsFeedwebsite article.

We use both Session and Persistent Cookies for the purposesset out below:

Necessary/ Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential toprovide You with services available through the Website and to enable You touse some of its features. They help to authenticate users and preventfraudulent use of user accounts. Without these Cookies, the services that Youhave asked for cannot be provided, and We only use these Cookies to provide Youwith those services.

CookiesPolicy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if usershave accepted the use of cookies on the Website.


Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to rememberchoices You make when You use the Website, such as remembering your logindetails or language preference. The purpose of these Cookies is to provide Youwith a more personal experience and to avoid You having to re-enter yourpreferences every time You use the Website.

Trackingand Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to trackinformation about traffic to the Website and how users use the Website. Theinformation gathered via these Cookies may directly or indirectly identify youas an individual visitor. This is because the information collected istypically linked to a pseudonymous identifier associated with the device you useto access the Website. We may also use these Cookies to test new pages,features or new functionality of the Website to see how our users react tothem.

Targetingand Advertising Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies track your browsinghabits to enable Us to show advertising which is more likely to be of interestto You. These Cookies use information about your browsing history to group Youwith other users who have similar interests. Based on that information, andwith Our permission, third party advertisers can place Cookies to enable themto show adverts which We think will be relevant to your interests while You areon third party websites.

For more information about the cookies we use and yourchoices regarding cookies, please visit our Cookies Policy or the Cookiessection of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the followingpurposes:

·      Toprovide and maintain our Service, including to monitor the usage of ourService.

·      To manageYour Account: to manage Your registration as a user of the Service. ThePersonal Data You provide can give You access to different functionalities ofthe Service that are available to You as a registered user.

·      For theperformance of a contract: the development, compliance and undertaking ofthe purchase contract for the products, items or services You have purchased orof any other contract with Us through the Service.

·      Tocontact You: To contact You by email, telephone calls, SMS, or otherequivalent forms of electronic communication, such as a mobile application'spush notifications regarding updates or informative communications related tothe functionalities, products or contracted services, including the securityupdates, when necessary or reasonable for their implementation.

·      Toprovide You with news, special offers and general information about othergoods, services and events which we offer that are similar to those that youhave already purchased or enquired about unless You have opted not to receivesuch information.

·      To manageYour requests: To attend and manage Your requests to Us.

·      Todeliver targeted advertising to You: We may use Your information to developand display content and advertising (and work with third-party vendors who doso) tailored to Your interests and/or location and to measure itseffectiveness.

·      Forbusiness transfers: We may use Your information to evaluate or conduct amerger, divestiture, restructuring, reorganization, dissolution, or other saleor transfer of some or all of Our assets, whether as a going concern or as partof bankruptcy, liquidation, or similar proceeding, in which Personal Data heldby Us about our Service users is among the assets transferred.

·      For otherpurposes: We may use Your information for other purposes, such as dataanalysis, identifying usage trends, determining the effectiveness of ourpromotional campaigns and to evaluate and improve our Service, products,services, marketing and your experience.

We may share Your personal information in the followingsituations:

·      WithService Providers: We may share Your personal information with ServiceProviders to monitor and analyze the use of our Service, to show advertisementsto You to help support and maintain Our Service, to advertise on third partywebsites to You after You visited our Service, to contact You.

·      Forbusiness transfers: We may share or transfer Your personal information inconnection with, or during negotiations of, any merger, sale of Company assets,financing, or acquisition of all or a portion of Our business to anothercompany.

·      WithAffiliates: We may share Your information with Our affiliates, in whichcase we will require those affiliates to honor this Privacy Policy. Affiliatesinclude Our parent company and any other subsidiaries, joint venture partnersor other companies that We control or that are under common control with Us.

·      Withbusiness partners: We may share Your information with Our business partnersto offer You certain products, services or promotions.

·      Withother users: when You share personal information or otherwise interact inthe public areas with other users, such information may be viewed by all usersand may be publicly distributed outside.

·      With Yourconsent: We may disclose Your personal information for any other purposewith Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as longas is necessary for the purposes set out in this Privacy Policy. We will retainand use Your Personal Data to the extent necessary to comply with our legalobligations (for example, if we are required to retain your data to comply withapplicable laws), resolve disputes, and enforce our legal agreements andpolicies.

The Company will also retain Usage Data for internalanalysis purposes. Usage Data is generally retained for a shorter period oftime, except when this data is used to strengthen the security or to improvethe functionality of Our Service, or We are legally obligated to retain thisdata for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed atthe Company's operating offices and in any other places where the partiesinvolved in the processing are located. It means that this information may betransferred to — and maintained on — computers located outside of Your state,province, country or other governmental jurisdiction where the data protectionlaws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Yoursubmission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary toensure that Your data is treated securely and in accordance with this PrivacyPolicy and no transfer of Your Personal Data will take place to an organizationor a country unless there are adequate controls in place including the securityof Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist indeleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certaininformation about You from within the Service.

You may update, amend, or delete Your information at anytime by signing in to Your Account, if you have one, and visiting the accountsettings section that allows you to manage Your personal information. You mayalso contact Us to request access to, correct, or delete any personalinformation that You have provided to Us.

Please note, however, that We may need to retain certaininformation when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or assetsale, Your Personal Data may be transferred. We will provide notice before YourPersonal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required todisclose Your Personal Data if required to do so by law or in response to validrequests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the goodfaith belief that such action is necessary to:

·      Comply with a legal obligation

·      Protect and defend the rights or property of theCompany

·      Prevent or investigate possible wrongdoing inconnection with the Service

·      Protect the personal safety of Users of theService or the public

·      Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, butremember that no method of transmission over the Internet, or method ofelectronic storage is 100% secure. While We strive to use commerciallyacceptable means to protect Your Personal Data, We cannot guarantee itsabsolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to YourPersonal Data. These third-party vendors collect, store, use, process andtransfer information about Your activity on Our Service in accordance withtheir Privacy Policies.


We may use third-party Service providers to monitor andanalyze the use of our Service.


Google Analytics is a web analytics serviceoffered by Google that tracks and reports website traffic. Google uses the datacollected to track and monitor the use of our Service. This data is shared withother Google services. Google may use the collected data to contextualize andpersonalize the ads of its own advertising network.

You can opt-out of having made youractivity on the Service available to Google Analytics by installing the GoogleAnalytics opt-out browser add-on. The add-on prevents the Google AnalyticsJavaScript (ga.js, analytics.js and dc.js) from sharing information with GoogleAnalytics about visits activity.

For more information on the privacy practicesof Google, please visit the Google Privacy & Terms web page:


We may use Service Providers to show advertisements to Youto help support and maintain Our Service.

GoogleAdSense & DoubleClick Cookie

Google, as a third party vendor, usescookies to serve ads on our Service. Google's use of the DoubleClick cookieenables it and its partners to serve ads to our users based on their visit toour Service or other websites on the Internet.

You may opt out of the use of the DoubleClickCookie for interest-based advertising by visiting the Google Ads Settings webpage:

Email Marketing

We may use Your Personal Data to contact You withnewsletters, marketing or promotional materials and other information that maybe of interest to You. You may opt-out of receiving any, or all, of thesecommunications from Us by following the unsubscribe link or instructionsprovided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage andsend emails to You.


Their Privacy Policy can be viewed at

Behavioral Remarketing

The Company uses remarketing services to advertise to Youafter You accessed or visited our Service. We and Our third-party vendors usecookies and non-cookie technologies to help Us recognize Your Device andunderstand how You use our Service so that We can improve our Service toreflect Your interests and serve You advertisements that are likely to be ofmore interest to You.

These third-party vendors collect, store, use, process andtransfer information about Your activity on Our Service in accordance withtheir Privacy Policies and to enable Us to:

·      Measure and analyze traffic and browsingactivity on Our Service

·      Show advertisements for our products and/orservices to You on third-party websites or apps

·      Measure and analyze the performance of Ouradvertising campaigns

Some of these third-party vendors may use non-cookietechnologies that may not be impacted by browser settings that block cookies.Your browser may not permit You to block such technologies. You can use thefollowing third-party tools to decline the collection and use of informationfor the purpose of serving You interest-based advertising:

·      The NAI's opt-out platform:

·      The EDAA's opt-out platform

·      The DAA's opt-out platform:

You may opt-out of all personalized advertising by enablingprivacy features on Your mobile device such as Limit Ad Tracking (iOS) and OptOut of Ads Personalization (Android). See Your mobile device Help system formore information.

We may share information, such as hashed email addresses (ifavailable) or other online identifiers collected on Our Service with thesethird-party vendors. This allows Our third-party vendors to recognize anddeliver You ads across devices and browsers. To read more about thetechnologies used by these third-party vendors and their cross-devicecapabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

GoogleAds (AdWords)

Google Ads (AdWords) remarketing service isprovided by Google Inc.

You can opt-out of Google Analytics forDisplay Advertising and customise the Google Display Network ads by visitingthe Google Ads Settings page:

Google also recommends installing theGoogle Analytics Opt-out Browser Add-on - for your web browser. Google Analytics Opt-out Browser Add-on providesvisitors with the ability to prevent their data from being collected and usedby Google Analytics.

For more information on the privacypractices of Google, please visit the Google Privacy & Terms web page:


Facebook remarketing service is provided byFacebook Inc.

You can learn more about interest-basedadvertising from Facebook by visiting this page:

To opt-out from Facebook's interest-basedads, follow these instructions from Facebook:

Facebook adheres to the Self-RegulatoryPrinciples for Online Behavioural Advertising established by the DigitalAdvertising Alliance. You can also opt-out from Facebook and otherparticipating companies through the Digital Advertising Alliance in the USA,the Digital Advertising Alliance of Canada in Canada or the EuropeanInteractive Digital Advertising Alliance in Europe,or opt-out using your mobile device settings.

For more information on the privacy practicesof Facebook, please visit Facebook's Data Policy:

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

·      Consent:You have given Your consent for processing Personal Data for one or morespecific purposes.

·      Performanceof a contract: Provision of Personal Data is necessary for the performanceof an agreement with You and/or for any pre-contractual obligations thereof.

·      Legalobligations: Processing Personal Data is necessary for compliance with alegal obligation to which the Company is subject.

·      Vitalinterests: Processing Personal Data is necessary in order to protect Yourvital interests or of another natural person.

·      Publicinterests: Processing Personal Data is related to a task that is carriedout in the public interest or in the exercise of official authority vested inthe Company.

·      Legitimateinterests: Processing Personal Data is necessary for the purposes of thelegitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify thespecific legal basis that applies to the processing, and in particular whetherthe provision of Personal Data is a statutory or contractual requirement, or arequirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality ofYour Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law ifYou are within the EU, to:

·      Requestaccess to Your Personal Data. The right to access, update or delete theinformation We have on You. Whenever made possible, you can access, update orrequest deletion of Your Personal Data directly within Your account settingssection. If you are unable to perform these actions yourself, please contact Usto assist You. This also enables You to receive a copy of the Personal Data Wehold about You.

·      Requestcorrection of the Personal Data that We hold about You. You have the rightto have any incomplete or inaccurate information We hold about You corrected.

·      Object toprocessing of Your Personal Data. This right exists where We are relying ona legitimate interest as the legal basis for Our processing and there issomething about Your particular situation, which makes You want to object toour processing of Your Personal Data on this ground. You also have the right toobject where We are processing Your Personal Data for direct marketingpurposes.

·      Requesterasure of Your Personal Data. You have the right to ask Us to delete orremove Personal Data when there is no good reason for Us to continue processingit.

·      Requestthe transfer of Your Personal Data. We will provide to You, or to a third-partyYou have chosen, Your Personal Data in a structured, commonly used,machine-readable format. Please note that this right only applies to automatedinformation which You initially provided consent for Us to use or where We usedthe information to perform a contract with You.

·      WithdrawYour consent. You have the right to withdraw Your consent on using yourPersonal Data. If You withdraw Your consent, We may not be able to provide Youwith access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification,cancellation and opposition by contacting Us. Please note that we may ask 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 Data ProtectionAuthority about Our collection and use of Your Personal Data. For moreinformation, if You are in the European Economic Area (EEA), please contactYour local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Datacollected while using the Service. As operator of the Facebook Fan Page,the Company and the operator of the social network Facebook are JointControllers.

The Company has entered into agreements with Facebook thatdefine the terms for use of the Facebook Fan Page, among other things. Theseterms 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 in connection with theoperation of the Facebook Fan Page and on the basis of the GDPR, in order toobtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device ofthe user visiting Our Facebook Fan Page. Each Cookie contains a uniqueidentifier code and remains active for a period of two years, except when it isdeleted before the end of this period.

Facebook receives, records and processes the informationstored in the Cookie, especially when the user visits the Facebook services,services that are provided by other members of the Facebook Fan Page andservices by other companies that use Facebook services.

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

CCPA Privacy

This privacy notice section for California residents supplementsthe information contained in Our Privacy Policy and it applies solely to allvisitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to,describes, references, is capable of being associated with, or could reasonablybe linked, directly or indirectly, with a particular Consumer or Device. Thefollowing is a list of categories of personal information which we may collector may have been collected from California residents within the last twelve(12) months.

Please note that the categories and examples provided in thelist below are those defined in the CCPA. This does not mean that all examplesof that category of personal information were in fact collected by Us, butreflects our good faith belief to the best of our knowledge that some of thatinformation from the applicable category may be and may have been collected.For example, certain categories of personal information would only be collectedif You provided such personal information directly to Us.

CategoryA: Identifiers.

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

Collected: Yes.

CategoryB: Personal information categories listed in the California Customer Recordsstatute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, SocialSecurity number, physical characteristics or description, address, telephonenumber, passport number, driver's license or state identification card number,insurance policy number, education, employment, employment history, bankaccount number, credit card number, debit card number, or any other financialinformation, medical information, or health insurance information. Somepersonal information included in this category may overlap with othercategories.

Collected: Yes.

CategoryC: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race,color, ancestry, national origin, citizenship, religion or creed, maritalstatus, medical condition, physical or mental disability, sex (includinggender, gender identity, gender expression, pregnancy or childbirth and relatedmedical conditions), sexual orientation, veteran or military status, geneticinformation (including familial genetic information).

Collected: No.

CategoryD: Commercial information.

Examples: Records and history of productsor services purchased or considered.

Collected: No.

CategoryE: Biometric information.

Examples: Genetic, physiological,behavioral, and biological characteristics, or activity patterns used toextract a template or other identifier or identifying information, such as,fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

CategoryF: Internet or other similar network activity.

Examples: Interaction with our Service oradvertisement.

Collected: Yes.

CategoryG: Geolocation data.

Examples: Approximate physical location.

Collected: No.

CategoryH: Sensory data.

Examples: Audio, electronic, visual,thermal, olfactory, or similar information.

Collected: No.

CategoryI: Professional or employment-related information.

Examples: Current or past job history orperformance evaluations.

Collected: No.

CategoryJ: Non-public education information (per the Family Educational Rights andPrivacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directlyrelated to a student maintained by an educational institution or party actingon its behalf, such as grades, transcripts, class lists, student schedules,student identification codes, student financial information, or studentdisciplinary records.

Collected: No.

CategoryK: Inferences drawn from other personal information.

Examples: Profile reflecting a person'spreferences, characteristics, psychological trends, predispositions, behavior,attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

·      Publicly available information from governmentrecords

·      Deidentified or aggregated consumer information

·      Information excluded from the CCPA's scope, suchas:

·      Health or medical information covered by theHealth Insurance Portability and Accountability Act of 1996 (HIPAA) and theCalifornia Confidentiality of Medical Information Act (CMIA) or clinical trialdata

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

Sources of Personal Information

We obtain the categories of personal information listedabove from the following categories of sources:

·      Directlyfrom You. For example, from the forms You complete on our Service,preferences You express or provide through our Service.

·      Indirectlyfrom You. For example, from observing Your activity on our Service.

·      Automaticallyfrom You. For example, through cookies We or our Service Providers set onYour Device as You navigate through our Service.

·      FromService Providers. For example, third-party vendors to monitor and analyzethe use of our Service, third-party vendors to provide advertising on ourService, third-party vendors to deliver targeted advertising to You, or otherthird-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

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

·      To operate our Service and provide You with ourService.

·      To provide You with support and to respond toYour inquiries, including to investigate and address Your concerns and monitorand improve our Service.

·      To fulfill or meet the reason You provided theinformation. For example, if You share Your contact information to ask aquestion about our Service, We will use that personal information to respond toYour inquiry.

·      To respond to law enforcement requests and asrequired by applicable law, court order, or governmental regulations.

·      As described to You when collecting Yourpersonal information or as otherwise set forth in the CCPA.

·      For internal administrative and auditingpurposes.

·      To detect security incidents and protect againstmalicious, deceptive, fraudulent or illegal activity, including, whennecessary, to prosecute those responsible for such activities.

Please note that the examples provided above areillustrative and not intended to be exhaustive. For more details on how we usethis information, please refer to the "Use of Your Personal Data"section.

If We decide to collect additional categories of personalinformation or use the personal information We collected for materiallydifferent, unrelated, or incompatible purposes We will update this PrivacyPolicy.

Disclosure of Personal Information for Business Purposes or CommercialPurposes

We may use or disclose and may have used or disclosed in thelast twelve (12) months the following categories of personal information forbusiness or commercial purposes:

Category A: Identifiers

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

Category F: Internet or other similar networkactivity

Please note that the categories listed above are thosedefined in the CCPA. This does not mean that all examples of that category ofpersonal information were in fact disclosed, but reflects our good faith beliefto the best of our knowledge that some of that information from the applicablecategory may be and may have been disclosed.

When We disclose personal information for a business purposeor a commercial purpose, We enter a contract that describes the purpose andrequires the recipient to both keep that personal information confidential andnot use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and"sale" mean selling, renting, releasing, disclosing, disseminating,making available, transferring, or otherwise communicating orally, in writing,or by electronic or other means, a consumer's personal information by thebusiness to a third party for valuable consideration. This means that We mayhave received some kind of benefit in return for sharing personal information,but not necessarily a monetary benefit.

Please note that the categories listed below are thosedefined in the CCPA. This does not mean that all examples of that category ofpersonal information were in fact sold, but reflects our good faith belief tothe best of our knowledge that some of that information from the applicablecategory may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) monthsthe following categories of personal information:

Category A: Identifiers

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

Category F: Internet or other similar networkactivity

Share of Personal Information

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

Service Providers

Our affiliates

Our business partners

Third party vendors to whom You or Youragents authorize Us to disclose Your personal information in connection withproducts or services We provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minorsunder the age of 16 through our Service, although certain third party websitesthat we link to may do so. These third-party websites have their own terms ofuse and privacy policies and we encourage parents and legal guardians tomonitor their children's Internet usage and instruct their children to neverprovide information on other websites without their permission.

We do not sell the personal information of Consumers Weactually know are less than 16 years of age, unless We receive affirmativeauthorization (the "right to opt-in") from either the Consumer who isbetween 13 and 16 years of age, or the parent or guardian of a Consumer lessthan 13 years of age. Consumers who opt-in to the sale of personal informationmay 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 contactingUs.

If You have reason to believe that a child under the age of13 (or 16) has provided Us with personal information, please contact Us withsufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rightsregarding their personal information. If You are a resident of California, Youhave the following rights:

·      The rightto notice. You have the right to be notified which categories of PersonalData are being collected and the purposes for which the Personal Data is beingused.

·      The rightto request. Under CCPA, You have the right to request that We discloseinformation to You about Our collection, use, sale, disclosure for businesspurposes and share of personal information. Once We receive and confirm Yourrequest, We will disclose to You:

·      The categories of personal information Wecollected about You

·      The categories of sources for the personalinformation We collected about You

·      Our business or commercial purpose forcollecting or selling that personal information

·      The categories of third parties with whom Weshare that personal information

·      The specific pieces of personal information Wecollected about You

·      If we sold Your personal information ordisclosed Your personal information for a business purpose, We will disclose toYou:

·      The categories of personal informationcategories sold

·      The categories of personal informationcategories disclosed

·      The rightto say no to the sale of Personal Data (opt-out). You have the right todirect Us to not sell Your personal information. To submit an opt-out requestplease contact Us.

·      The rightto delete Personal Data. You have the right to request the deletion of YourPersonal Data, subject to certain exceptions. Once We receive and confirm Yourrequest, We will delete (and direct Our Service Providers to delete) Yourpersonal information from our records, unless an exception applies. We may denyYour deletion request if retaining the information is necessary for Us or OurService Providers to:

·      Complete the transaction for which We collectedthe personal information, provide a good or service that You requested, takeactions reasonably anticipated within the context of our ongoing businessrelationship with You, or otherwise perform our contract with You.

·      Detect security incidents, protect againstmalicious, deceptive, fraudulent, or illegal activity, or prosecute thoseresponsible for such activities.

·      Debug products to identify and repair errorsthat impair existing intended functionality.

·      Exercise free speech, ensure the right ofanother consumer to exercise their free speech rights, or exercise anotherright provided for by law.

·      Comply with the California Electronic CommunicationsPrivacy Act (Cal. Penal Code § 1546 et. seq.).

·      Engage in public or peer-reviewed scientific,historical, or statistical research in the public interest that adheres to allother applicable ethics and privacy laws, when the information's deletion maylikely render impossible or seriously impair the research's achievement, if Youpreviously provided informed consent.

·      Enable solely internal uses that are reasonablyaligned with consumer expectations based on Your relationship with Us.

·      Comply with a legal obligation.

·      Make other internal and lawful uses of thatinformation that are compatible with the context in which You provided it.

·      The rightnot to be discriminated against. You have the right not to be discriminatedagainst for exercising any of Your consumer's rights, including by:

·      Denying goods or services to You

·      Charging different prices or rates for goods orservices, including the use of discounts or other benefits or imposingpenalties

·      Providing a different level or quality of goodsor services to You

·      Suggesting that You will receive a differentprice or rate for goods or services or a different level or quality of goods orservices

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, andif You are a California resident, You can contact Us:

·      By email:

Only You, or a person registered with the CaliforniaSecretary of State that You authorize to act on Your behalf, may make averifiable request related to Your personal information.

Your request to Us must:

·      Provide sufficient information that allows Us toreasonably verify You are the person about whom We collected personalinformation or an authorized representative

·      Describe Your request with sufficient detailthat allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with therequired information if We cannot:

·      Verify Your identity or authority to make therequest

·      And confirm that the personal informationrelates to You

We will disclose and deliver the required information freeof charge within 45 days of receiving Your verifiable request. The time periodto provide the required information may be extended once by an additional 45days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-monthperiod preceding the verifiable request's receipt.

For data portability requests, We will select a format toprovide Your personal information that is readily usable and should allow Youto transmit the information from one entity to another entity withouthindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personalinformation. Once We receive and confirm a verifiable consumer request fromYou, we will stop selling Your personal information. To exercise Your right toopt-out, please contact Us.

The Service Providers we partner with (for example, ouranalytics or advertising partners) may use technology on the Service that sellspersonal information as defined by the CCPA law. If you wish to opt out of theuse of Your personal information for interest-based advertising purposes andthese potential sales as defined under CCPA law, you may do so by following theinstructions below.

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


You can opt out of receiving ads that are personalized asserved by our Service Providers by following our instructions presented on theService:

·      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 Your computer that isunique to the browser You use to opt out. If you change browsers or delete thecookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out ofthe use of information about the apps You use in order to serve You ads thatare targeted to Your interests:

·      "Opt out of Interest-Based Ads" or"Opt out of Ads Personalization" on Android devices

·      "Limit Ad Tracking" on iOS devices

You can also stop the collection of location informationfrom Your mobile device by changing the preferences on Your mobile device.

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

Our Service does not respond to Do Not Track signals.

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

Children's Privacy

Our Service does not address anyone under the age of 13. Wedo not knowingly collect personally identifiable information from anyone underthe age of 13. If You are a parent or guardian and You are aware that Yourchild has provided Us with Personal Data, please contact Us. If We become awarethat We have collected Personal Data from anyone under the age of 13 withoutverification of parental consent, We take steps to remove that information fromOur servers.

If We need to rely on consent as a legal basis forprocessing Your information and Your country requires consent from a parent, Wemay require Your parent's consent before We collect and use that information.

Your California Privacy Rights (California's Shine the Lightlaw)

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

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

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

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

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

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

Links to Other Websites

Our Service may contain links to other websites that are notoperated by Us. If You click on a third party link, You will be directed tothat third party's site. We strongly advise You to review the Privacy Policy ofevery site You visit.

We have no control over and assume no responsibility for thecontent, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We willnotify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice onOur Service, prior to the change becoming effective and update the "Lastupdated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodicallyfor any changes. Changes to this Privacy Policy are effective when they areposted on this page.

Contact Us

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

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