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+import React from "react";
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+import Head from "@docusaurus/Head";
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+import { BlogFooter } from "@site/src/refine-theme/blog-footer";
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+import { CommonHeader } from "@site/src/refine-theme/common-header";
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+import { CommonLayout } from "@site/src/refine-theme/common-layout";
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+import clsx from "clsx";
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+
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+const PrivacyPolicy: React.FC = () => {
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+ return (
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+ <CommonLayout>
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+ <Head title="Privacy Policy | Refine">
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+ <html data-page="privacy_policy" data-customized="true" />
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+ </Head>
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+ <div className="refine-prose">
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+ <CommonHeader hasSticky={true} />
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+
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+ <div className="flex-1 flex flex-col pt-8 lg:pt-16 pb-32 max-w-[800px] w-full mx-auto px-2">
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+ <h1>Privacy Policy</h1>
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+ <p>Last updated: April 04, 2023</p>
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+ <p>
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+ This Privacy Policy describes Our policies and
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+ procedures on the collection, use and disclosure of Your
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+ information when You use the Service and tells You about
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+ Your privacy rights and how the law protects You.
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+ </p>
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+ <p>
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+ We use Your Personal data to provide and improve the
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+ Service. By using the Service, You agree to the
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+ collection and use of information in accordance with
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+ this Privacy Policy.
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+ </p>
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+ <h1>Interpretation and Definitions</h1>
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+ <h2 style={{ marginTop: 0 }}>Interpretation</h2>
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+ <p>
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+ The words of which the initial letter is capitalized
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+ have meanings defined under the following conditions.
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+ The following definitions shall have the same meaning
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+ regardless of whether they appear in singular or in
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+ plural.
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+ </p>
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+ <h2 style={{ marginTop: 0 }}>Definitions</h2>
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+ <p>For the purposes of this Privacy Policy:</p>
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+ <ul>
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+ <li>
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+ <p>
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+ <strong>Account</strong> means a unique account
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+ created for You to access our Service or parts
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+ of our Service.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Affiliate</strong> means an entity that
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+ controls, is controlled by or is under common
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+ control with a party, where "control"
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+ means ownership of 50% or more of the shares,
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+ equity interest or other securities entitled to
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+ vote for election of directors or other managing
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+ authority.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Business</strong>, for the purpose of
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+ CCPA/CPRA, refers to the Company as the legal
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+ entity that collects Consumers’ personal
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+ information and determines the purposes and
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+ means of the processing of Consumers’
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+ personal information, or on behalf of which such
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+ information is collected and that alone, or
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+ jointly with others, determines the purposes and
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+ means of the processing of consumers’
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+ personal information, that does business in the
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+ State of California.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>CCPA</strong> and/or
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+ <strong>CPRA</strong> refers to California
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+ Consumer Privacy Act (the "CCPA") as
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+ amended by the California Privacy Rights Act of
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+ 2020 (the "CPRA").
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Company</strong> (referred to as either
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+ "the Company", "We",
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+ "Us" or "Our" in this
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+ Agreement) refers to Refine Development Inc.,
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+ 256 Chapman Road STE 105-4 Newark, New Castle
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+ 19702.
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+ </p>
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+ <p>
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+ For the purpose of the GDPR, the Company is the
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+ Data Controller.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Consumer</strong>, for the purpose of
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+ the CCPA/CPRA, means a natural person who is a
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+ California resident. A resident, as defined in
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+ the law, includes (1) every individual who is in
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+ the USA for other than a temporary or transitory
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+ purpose, and (2) every individual who is
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+ domiciled in the USA who is outside the USA for
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+ a temporary or transitory purpose.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Cookies</strong> are small files that
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+ are placed on Your computer, mobile device or
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+ any other device by a website, containing the
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+ details of Your browsing history on that website
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+ among its many uses.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Country</strong> refers to: Delaware,
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+ United States
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Data Controller</strong>, for the
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+ purposes of the GDPR (General Data Protection
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+ Regulation), refers to the Company as the legal
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+ person which alone or jointly with others
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+ determines the purposes and means of the
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+ processing of Personal Data.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Device</strong> means any device that
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+ can access the Service such as a computer, a
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+ cellphone or a digital tablet.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Do Not Track</strong> (DNT) is a concept
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+ that has been promoted by US regulatory
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+ authorities, in particular the U.S. Federal
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+ Trade Commission (FTC), for the Internet
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+ industry to develop and implement a mechanism
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+ for allowing internet users to control the
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+ tracking of their online activities across
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+ websites.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>GDPR</strong> refers to EU General Data
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+ Protection Regulation.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Personal Data</strong> is any
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+ information that relates to an identified or
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+ identifiable individual.
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+ </p>
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+ <p>
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+ For the purposes of GDPR, Personal Data means
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+ any information relating to You such as a name,
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+ an identification number, location data, online
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+ identifier or to one or more factors specific to
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+ the physical, physiological, genetic, mental,
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+ economic, cultural or social identity.
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+ </p>
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+ <p>
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+ For the purposes of the CCPA/CPRA, Personal Data
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+ means any information that identifies, relates
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+ to, describes or is capable of being associated
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+ with, or could reasonably be linked, directly or
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+ indirectly, with You.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Service</strong> refers to the Website.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Service Provider</strong> means any
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+ natural or legal person who processes the data
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+ on behalf of the Company. It refers to
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+ third-party companies or individuals employed by
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+ the Company to facilitate the Service, to
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+ provide the Service on behalf of the Company, to
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+ perform services related to the Service or to
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+ assist the Company in analyzing how the Service
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+ is used. For the purpose of the GDPR, Service
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+ Providers are considered Data Processors.
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Usage Data</strong> refers to data
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+ collected automatically, either generated by the
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+ use of the Service or from the Service
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+ infrastructure itself (for example, the duration
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+ of a page visit).
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>Website</strong> refers to refine.new,
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+ accessible from{" "}
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+ <a href="https://refine.new/">
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+ https://refine.new/
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+ </a>
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+ </p>
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+ </li>
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+ <li>
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+ <p>
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+ <strong>You</strong> means the individual
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+ accessing or using the Service, or the company,
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+ or other legal entity on behalf of which such
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+ individual is accessing or using the Service, as
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+ applicable.
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+ </p>
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+ <p>
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+ Under GDPR, You can be referred to as the Data
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+ Subject or as the User as you are the individual
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+ using the Service.
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+ </p>
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+ </li>
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+ </ul>
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+ <h1>Collecting and Using Your Personal Data</h1>
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+ <h2 style={{ marginTop: 0 }}>Types of Data Collected</h2>
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+ <h3>Personal Data</h3>
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+ <p>
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+ While using Our Service, We may ask You to provide Us
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+ with certain personally identifiable information that
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+ can be used to contact or identify You. Personally
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+ identifiable information may include, but is not limited
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+ to:
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+ </p>
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+ <ul>
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+ <li>
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+ <p>Email address</p>
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+ </li>
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+ <li>
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+ <p>First name and last name</p>
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+ </li>
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+ <li>
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+ <p>Usage Data</p>
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+ </li>
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+ </ul>
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+ <h3>Usage Data</h3>
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+ <p>
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+ Usage Data is collected automatically when using the
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+ Service.
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+ </p>
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+ <p>
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+ Usage Data may include information such as Your
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+ Device’s Internet Protocol address (e.g. IP
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+ address), browser type, browser version, the pages of
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+ our Service that You visit, the time and date of Your
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+ visit, the time spent on those pages, unique device
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+ identifiers and other diagnostic data.
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+ </p>
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+ <p>
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+ When You access the Service by or through a mobile
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+ device, We may collect certain information
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+ automatically, including, but not limited to, the type
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+ of mobile device You use, Your mobile device unique ID,
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+ the IP address of Your mobile device, Your mobile
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+ operating system, the type of mobile Internet browser
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+ You use, unique device identifiers and other diagnostic
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+ data.
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+ </p>
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+ <p>
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+ We may also collect information that Your browser sends
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+ whenever You visit our Service or when You access the
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+ Service by or through a mobile device.
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+ </p>
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+ <h3>Tracking Technologies and Cookies</h3>
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+ <p>
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+ We use Cookies and similar tracking technologies to
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+ track the activity on Our Service and store certain
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+ information. Tracking technologies used are beacons,
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+ tags, and scripts to collect and track information and
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+ to improve and analyze Our Service. The technologies We
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+ use may include:
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+ </p>
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+ <ul>
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+ <li>
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+ <strong>Cookies or Browser Cookies.</strong> A
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+ cookie is a small file placed on Your Device. You
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+ can instruct Your browser to refuse all Cookies or
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+ to indicate when a Cookie is being sent. However, if
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+ You do not accept Cookies, You may not be able to
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+ use some parts of our Service. Unless you have
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+ adjusted Your browser setting so that it will refuse
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+ Cookies, our Service may use Cookies.
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+ </li>
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+ <li>
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+ <strong>Web Beacons.</strong> Certain sections of
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+ our Service and our emails may contain small
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+ electronic files known as web beacons (also referred
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+ to as clear gifs, pixel tags, and single-pixel gifs)
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+ that permit the Company, for example, to count users
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+ who have visited those pages or opened an email and
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+ for other related website statistics (for example,
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+ recording the popularity of a certain section and
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+ verifying system and server integrity).
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+ </li>
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+ </ul>
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+ <p>
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+ Cookies can be "Persistent" or
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+ "Session" Cookies. Persistent Cookies remain
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+ on Your personal computer or mobile device when You go
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+ offline, while Session Cookies are deleted as soon as
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+ You close Your web browser. You can learn more about
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+ cookies on{" "}
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+ <a href="https://www.termsfeed.com/blog/cookies/#What_Are_Cookies">
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+ TermsFeed website
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+ </a>{" "}
|
|
|
|
|
+ article.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We use both Session and Persistent Cookies for the
|
|
|
|
|
+ purposes set out below:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>Necessary / Essential Cookies</strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Type: Session Cookies</p>
|
|
|
|
|
+ <p>Administered by: Us</p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Purpose: These Cookies are essential to provide
|
|
|
|
|
+ You with services available through the Website
|
|
|
|
|
+ and to enable You to use some of its features.
|
|
|
|
|
+ They help to authenticate users and prevent
|
|
|
|
|
+ fraudulent use of user accounts. Without these
|
|
|
|
|
+ Cookies, the services that You have asked for
|
|
|
|
|
+ cannot be provided, and We only use these
|
|
|
|
|
+ Cookies to provide You with those services.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Cookies Policy / Notice Acceptance Cookies
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Type: Persistent Cookies</p>
|
|
|
|
|
+ <p>Administered by: Us</p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Purpose: These Cookies identify if users have
|
|
|
|
|
+ accepted the use of cookies on the Website.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>Functionality Cookies</strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Type: Persistent Cookies</p>
|
|
|
|
|
+ <p>Administered by: Us</p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Purpose: These Cookies allow us to remember
|
|
|
|
|
+ choices You make when You use the Website, such
|
|
|
|
|
+ as remembering your login details or language
|
|
|
|
|
+ preference. The purpose of these Cookies is to
|
|
|
|
|
+ provide You with a more personal experience and
|
|
|
|
|
+ to avoid You having to re-enter your preferences
|
|
|
|
|
+ every time You use the Website.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Tracking and Performance Cookies
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Type: Persistent Cookies</p>
|
|
|
|
|
+ <p>Administered by: Third-Parties</p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Purpose: These Cookies are used to track
|
|
|
|
|
+ information about traffic to the Website and how
|
|
|
|
|
+ users use the Website. The information gathered
|
|
|
|
|
+ via these Cookies may directly or indirectly
|
|
|
|
|
+ identify you as an individual visitor. This is
|
|
|
|
|
+ because the information collected is typically
|
|
|
|
|
+ linked to a pseudonymous identifier associated
|
|
|
|
|
+ with the device you use to access the Website.
|
|
|
|
|
+ We may also use these Cookies to test new pages,
|
|
|
|
|
+ features or new functionality of the Website to
|
|
|
|
|
+ see how our users react to them.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ For more information about the cookies we use and your
|
|
|
|
|
+ choices regarding cookies, please visit our Cookies
|
|
|
|
|
+ Policy or the Cookies section of our Privacy Policy.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>Use of Your Personal Data</h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Company may use Personal Data for the following
|
|
|
|
|
+ purposes:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ To provide and maintain our Service
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ , including to monitor the usage of our Service.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>To manage Your Account:</strong> to
|
|
|
|
|
+ manage Your registration as a user of the
|
|
|
|
|
+ Service. The Personal Data You provide can give
|
|
|
|
|
+ You access to different functionalities of the
|
|
|
|
|
+ Service that are available to You as a
|
|
|
|
|
+ registered user.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ For the performance of a contract:
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ the development, compliance and undertaking of
|
|
|
|
|
+ the purchase contract for the products, items or
|
|
|
|
|
+ services You have purchased or of any other
|
|
|
|
|
+ contract with Us through the Service.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>To contact You:</strong> To contact You
|
|
|
|
|
+ by email, telephone calls, SMS, or other
|
|
|
|
|
+ equivalent forms of electronic communication,
|
|
|
|
|
+ such as a mobile application’s push
|
|
|
|
|
+ notifications regarding updates or informative
|
|
|
|
|
+ communications related to the functionalities,
|
|
|
|
|
+ products or contracted services, including the
|
|
|
|
|
+ security updates, when necessary or reasonable
|
|
|
|
|
+ for their implementation.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>To provide You</strong> with news,
|
|
|
|
|
+ special offers and general information about
|
|
|
|
|
+ other goods, services and events which we offer
|
|
|
|
|
+ that are similar to those that you have already
|
|
|
|
|
+ purchased or enquired about unless You have
|
|
|
|
|
+ opted not to receive such information.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>To manage Your requests:</strong> To
|
|
|
|
|
+ attend and manage Your requests to Us.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>For business transfers:</strong> We may
|
|
|
|
|
+ use Your information to evaluate or conduct a
|
|
|
|
|
+ merger, divestiture, restructuring,
|
|
|
|
|
+ reorganization, dissolution, or other sale or
|
|
|
|
|
+ transfer of some or all of Our assets, whether
|
|
|
|
|
+ as a going concern or as part of bankruptcy,
|
|
|
|
|
+ liquidation, or similar proceeding, in which
|
|
|
|
|
+ Personal Data held by Us about our Service users
|
|
|
|
|
+ is among the assets transferred.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>For other purposes</strong>: We may use
|
|
|
|
|
+ Your information for other purposes, such as
|
|
|
|
|
+ data analysis, identifying usage trends,
|
|
|
|
|
+ determining the effectiveness of our promotional
|
|
|
|
|
+ campaigns and to evaluate and improve our
|
|
|
|
|
+ Service, products, services, marketing and your
|
|
|
|
|
+ experience.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may share Your personal information in the following
|
|
|
|
|
+ situations:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>With Service Providers:</strong> We may
|
|
|
|
|
+ share Your personal information with Service
|
|
|
|
|
+ Providers to monitor and analyze the use of our
|
|
|
|
|
+ Service, to contact You.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>For business transfers:</strong> We may
|
|
|
|
|
+ share or transfer Your personal information in
|
|
|
|
|
+ connection with, or during negotiations of, any
|
|
|
|
|
+ merger, sale of Company assets, financing, or
|
|
|
|
|
+ acquisition of all or a portion of Our business to
|
|
|
|
|
+ another company.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>With Affiliates:</strong> We may share Your
|
|
|
|
|
+ information with Our affiliates, in which case we
|
|
|
|
|
+ will require those affiliates to honor this Privacy
|
|
|
|
|
+ Policy. Affiliates include Our parent company and
|
|
|
|
|
+ any other subsidiaries, joint venture partners or
|
|
|
|
|
+ other companies that We control or that are under
|
|
|
|
|
+ common control with Us.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>With business partners:</strong> We may
|
|
|
|
|
+ share Your information with Our business partners to
|
|
|
|
|
+ offer You certain products, services or promotions.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>With other users:</strong> when You share
|
|
|
|
|
+ personal information or otherwise interact in the
|
|
|
|
|
+ public areas with other users, such information may
|
|
|
|
|
+ be viewed by all users and may be publicly
|
|
|
|
|
+ distributed outside.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>With Your consent</strong>: We may disclose
|
|
|
|
|
+ Your personal information for any other purpose with
|
|
|
|
|
+ Your consent.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Retention of Your Personal Data
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Company will retain Your Personal Data only for as
|
|
|
|
|
+ long as is necessary for the purposes set out in this
|
|
|
|
|
+ Privacy Policy. We will retain and use Your Personal
|
|
|
|
|
+ Data to the extent necessary to comply with our legal
|
|
|
|
|
+ obligations (for example, if we are required to retain
|
|
|
|
|
+ your data to comply with applicable laws), resolve
|
|
|
|
|
+ disputes, and enforce our legal agreements and policies.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Company will also retain Usage Data for internal
|
|
|
|
|
+ analysis purposes. Usage Data is generally retained for
|
|
|
|
|
+ a shorter period of time, except when this data is used
|
|
|
|
|
+ to strengthen the security or to improve the
|
|
|
|
|
+ functionality of Our Service, or We are legally
|
|
|
|
|
+ obligated to retain this data for longer time periods.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Transfer of Your Personal Data
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Your information, including Personal Data, is processed
|
|
|
|
|
+ at the Company’s operating offices and in any
|
|
|
|
|
+ other places where the parties involved in the
|
|
|
|
|
+ processing are located. It means that this information
|
|
|
|
|
+ may be transferred to — and maintained on — computers
|
|
|
|
|
+ located outside of Your state, province, country or
|
|
|
|
|
+ other governmental jurisdiction where the data
|
|
|
|
|
+ protection laws may differ than those from Your
|
|
|
|
|
+ jurisdiction.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Your consent to this Privacy Policy followed by Your
|
|
|
|
|
+ submission of such information represents Your agreement
|
|
|
|
|
+ to that transfer.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Company will take all steps reasonably necessary to
|
|
|
|
|
+ ensure that Your data is treated securely and in
|
|
|
|
|
+ accordance with this Privacy Policy and no transfer of
|
|
|
|
|
+ Your Personal Data will take place to an organization or
|
|
|
|
|
+ a country unless there are adequate controls in place
|
|
|
|
|
+ including the security of Your data and other personal
|
|
|
|
|
+ information.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>Delete Your Personal Data</h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You have the right to delete or request that We assist
|
|
|
|
|
+ in deleting the Personal Data that We have collected
|
|
|
|
|
+ about You.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Our Service may give You the ability to delete certain
|
|
|
|
|
+ information about You from within the Service.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You may update, amend, or delete Your information at any
|
|
|
|
|
+ time by signing in to Your Account, if you have one, and
|
|
|
|
|
+ visiting the account settings section that allows you to
|
|
|
|
|
+ manage Your personal information. You may also contact
|
|
|
|
|
+ Us to request access to, correct, or delete any personal
|
|
|
|
|
+ information that You have provided to Us.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Please note, however, that We may need to retain certain
|
|
|
|
|
+ information when we have a legal obligation or lawful
|
|
|
|
|
+ basis to do so.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Disclosure of Your Personal Data
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <h3>Business Transactions</h3>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If the Company is involved in a merger, acquisition or
|
|
|
|
|
+ asset sale, Your Personal Data may be transferred. We
|
|
|
|
|
+ will provide notice before Your Personal Data is
|
|
|
|
|
+ transferred and becomes subject to a different Privacy
|
|
|
|
|
+ Policy.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h3>Law enforcement</h3>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Under certain circumstances, the Company may be required
|
|
|
|
|
+ to disclose Your Personal Data if required to do so by
|
|
|
|
|
+ law or in response to valid requests by public
|
|
|
|
|
+ authorities (e.g. a court or a government agency).
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h3>Other legal requirements</h3>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Company may disclose Your Personal Data in the good
|
|
|
|
|
+ faith belief that such action is necessary to:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>Comply with a legal obligation</li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Protect and defend the rights or property of the
|
|
|
|
|
+ Company
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Prevent or investigate possible wrongdoing in
|
|
|
|
|
+ connection with the Service
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Protect the personal safety of Users of the Service
|
|
|
|
|
+ or the public
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>Protect against legal liability</li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Security of Your Personal Data
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The security of Your Personal Data is important to Us,
|
|
|
|
|
+ but remember that no method of transmission over the
|
|
|
|
|
+ Internet, or method of electronic storage is 100%
|
|
|
|
|
+ secure. While We strive to use commercially acceptable
|
|
|
|
|
+ means to protect Your Personal Data, We cannot guarantee
|
|
|
|
|
+ its absolute security.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>
|
|
|
|
|
+ Detailed Information on the Processing of Your Personal
|
|
|
|
|
+ Data
|
|
|
|
|
+ </h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Service Providers We use may have access to Your
|
|
|
|
|
+ Personal Data. These third-party vendors collect, store,
|
|
|
|
|
+ use, process and transfer information about Your
|
|
|
|
|
+ activity on Our Service in accordance with their Privacy
|
|
|
|
|
+ Policies.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>Analytics</h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may use third-party Service providers to monitor and
|
|
|
|
|
+ analyze the use of our Service.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>Google Analytics</strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Google Analytics is a web analytics 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 collected data to
|
|
|
|
|
+ contextualize and personalize the ads of its own
|
|
|
|
|
+ advertising network.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You can opt-out of having made your activity on
|
|
|
|
|
+ the Service available to Google Analytics by
|
|
|
|
|
+ installing the Google Analytics opt-out browser
|
|
|
|
|
+ add-on. The add-on prevents the Google Analytics
|
|
|
|
|
+ JavaScript (ga.js, analytics.js and dc.js) from
|
|
|
|
|
+ sharing information with Google Analytics about
|
|
|
|
|
+ visits activity.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ For more information on the privacy practices of
|
|
|
|
|
+ Google, please visit the Google Privacy &
|
|
|
|
|
+ Terms web page:{" "}
|
|
|
|
|
+ <a href="https://policies.google.com/privacy">
|
|
|
|
|
+ https://policies.google.com/privacy
|
|
|
|
|
+ </a>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>Email Marketing</h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may use Your Personal Data to contact You with
|
|
|
|
|
+ newsletters, marketing or promotional materials and
|
|
|
|
|
+ other information that may be of interest to You. You
|
|
|
|
|
+ may opt-out of receiving any, or all, of these
|
|
|
|
|
+ communications from Us by following the unsubscribe link
|
|
|
|
|
+ or instructions provided in any email We send or by
|
|
|
|
|
+ contacting Us.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may use Email Marketing Service Providers to manage
|
|
|
|
|
+ and send emails to You.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>Intercom</strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Their Privacy Policy can be viewed at{" "}
|
|
|
|
|
+ <a href="https://www.intercom.com/legal/privacy">
|
|
|
|
|
+ https://www.intercom.com/legal/privacy
|
|
|
|
|
+ </a>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h1>GDPR Privacy</h1>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Legal Basis for Processing Personal Data under GDPR
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may process Personal Data under the following
|
|
|
|
|
+ conditions:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Consent:</strong> You have given Your
|
|
|
|
|
+ consent for processing Personal Data for one or more
|
|
|
|
|
+ specific purposes.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Performance of a contract:</strong>{" "}
|
|
|
|
|
+ Provision of Personal Data is necessary for the
|
|
|
|
|
+ performance of an agreement with You and/or for any
|
|
|
|
|
+ pre-contractual obligations thereof.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Legal obligations:</strong> Processing
|
|
|
|
|
+ Personal Data is necessary for compliance with a
|
|
|
|
|
+ legal obligation to which the Company is subject.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Vital interests:</strong> Processing
|
|
|
|
|
+ Personal Data is necessary in order to protect Your
|
|
|
|
|
+ vital interests or of another natural person.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Public interests:</strong> Processing
|
|
|
|
|
+ Personal Data is related to a task that is carried
|
|
|
|
|
+ out in the public interest or in the exercise of
|
|
|
|
|
+ official authority vested in the Company.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Legitimate interests:</strong> Processing
|
|
|
|
|
+ Personal Data is necessary for the purposes of the
|
|
|
|
|
+ legitimate interests pursued by the Company.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ In any case, the Company will gladly help to clarify the
|
|
|
|
|
+ specific legal basis that applies to the processing, and
|
|
|
|
|
+ in particular whether the provision of Personal Data is
|
|
|
|
|
+ a statutory or contractual requirement, or a requirement
|
|
|
|
|
+ necessary to enter into a contract.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>Your Rights under the GDPR</h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Company undertakes to respect the confidentiality of
|
|
|
|
|
+ Your Personal Data and to guarantee You can exercise
|
|
|
|
|
+ Your rights.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You have the right under this Privacy Policy, and by law
|
|
|
|
|
+ if You are within the EU, to:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Request access to Your Personal Data.
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ The right to access, update or delete the
|
|
|
|
|
+ information We have on You. Whenever made possible,
|
|
|
|
|
+ you can access, update or request deletion of Your
|
|
|
|
|
+ Personal Data directly within Your account settings
|
|
|
|
|
+ section. If you are unable to perform these actions
|
|
|
|
|
+ yourself, please contact Us to assist You. This also
|
|
|
|
|
+ enables You to receive a copy of the Personal Data
|
|
|
|
|
+ We hold about You.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Request correction of the Personal Data that We
|
|
|
|
|
+ hold about You.
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ You have the right to have any incomplete or
|
|
|
|
|
+ inaccurate information We hold about You corrected.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Object to processing of Your Personal Data.
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ This right exists where We are relying on a
|
|
|
|
|
+ legitimate interest as the legal basis for Our
|
|
|
|
|
+ processing and there is something about Your
|
|
|
|
|
+ particular situation, which makes You want to object
|
|
|
|
|
+ to our processing of Your Personal Data on this
|
|
|
|
|
+ ground. You also have the right to object where We
|
|
|
|
|
+ are processing Your Personal Data for direct
|
|
|
|
|
+ marketing purposes.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Request erasure of Your Personal Data.
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ You have the right to ask Us to delete or remove
|
|
|
|
|
+ Personal Data when there is no good reason for Us to
|
|
|
|
|
+ continue processing it.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Request the transfer of Your Personal Data.
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ We will provide to You, or to a third-party You have
|
|
|
|
|
+ chosen, Your Personal Data in a structured, commonly
|
|
|
|
|
+ used, machine-readable format. Please note that this
|
|
|
|
|
+ right only applies to automated information which
|
|
|
|
|
+ You initially provided consent for Us to use or
|
|
|
|
|
+ where We used the information to perform a contract
|
|
|
|
|
+ with You.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Withdraw Your consent.</strong> You have the
|
|
|
|
|
+ right to withdraw Your consent on using your
|
|
|
|
|
+ Personal Data. If You withdraw Your consent, We may
|
|
|
|
|
+ not be able to provide You with access to certain
|
|
|
|
|
+ specific functionalities of the Service.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Exercising of Your GDPR Data Protection Rights
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You may exercise Your rights of access, rectification,
|
|
|
|
|
+ cancellation and opposition by contacting Us. Please
|
|
|
|
|
+ note that we may ask You to verify Your identity before
|
|
|
|
|
+ responding to such requests. If You make a request, We
|
|
|
|
|
+ will try our best to respond to You as soon as possible.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You have the right to complain to a Data Protection
|
|
|
|
|
+ Authority about Our collection and use of Your Personal
|
|
|
|
|
+ Data. For more information, if You are in the European
|
|
|
|
|
+ Economic Area (EEA), please contact Your local data
|
|
|
|
|
+ protection authority in the EEA.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>CCPA/CPRA Privacy Notice</h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ This privacy notice section for California residents
|
|
|
|
|
+ supplements the information contained in Our Privacy
|
|
|
|
|
+ Policy and it applies solely to all visitors, users, and
|
|
|
|
|
+ others who reside in the State of California.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Categories of Personal Information Collected
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We collect information that identifies, relates to,
|
|
|
|
|
+ describes, references, is capable of being associated
|
|
|
|
|
+ with, or could reasonably be linked, directly or
|
|
|
|
|
+ indirectly, with a particular Consumer or Device. The
|
|
|
|
|
+ following is a list of categories of personal
|
|
|
|
|
+ information which we may collect or may have been
|
|
|
|
|
+ collected from California residents within the last
|
|
|
|
|
+ twelve (12) months.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Please note that the categories and examples provided in
|
|
|
|
|
+ the list below are those defined in the CCPA/CPRA. This
|
|
|
|
|
+ does not mean that all examples of that category of
|
|
|
|
|
+ personal information were in fact collected by Us, but
|
|
|
|
|
+ reflects our good faith belief to the best of Our
|
|
|
|
|
+ knowledge that some of that information from the
|
|
|
|
|
+ applicable category may be and may have been collected.
|
|
|
|
|
+ For example, certain categories of personal information
|
|
|
|
|
+ would only be collected if You provided such personal
|
|
|
|
|
+ information directly to Us.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>Category A: Identifiers.</strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: A real name, alias, postal address,
|
|
|
|
|
+ unique personal identifier, online identifier,
|
|
|
|
|
+ Internet Protocol address, email address,
|
|
|
|
|
+ account name, driver’s license number,
|
|
|
|
|
+ passport number, or other similar identifiers.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: Yes.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category B: Personal information categories
|
|
|
|
|
+ listed in the California Customer Records
|
|
|
|
|
+ statute (Cal. Civ. Code § 1798.80(e)).
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: A name, signature, Social Security
|
|
|
|
|
+ number, physical characteristics or description,
|
|
|
|
|
+ address, telephone number, passport number,
|
|
|
|
|
+ driver’s license or state identification
|
|
|
|
|
+ card number, insurance policy number, education,
|
|
|
|
|
+ employment, employment history, bank account
|
|
|
|
|
+ number, credit card number, debit card number,
|
|
|
|
|
+ or any other financial information, medical
|
|
|
|
|
+ information, or health insurance information.
|
|
|
|
|
+ Some personal information included in this
|
|
|
|
|
+ category may overlap with other categories.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: Yes.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category C: Protected classification
|
|
|
|
|
+ characteristics under California or federal
|
|
|
|
|
+ law.
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Age (40 years or older), race, color,
|
|
|
|
|
+ ancestry, national origin, citizenship, religion
|
|
|
|
|
+ or creed, marital status, medical condition,
|
|
|
|
|
+ physical or mental disability, sex (including
|
|
|
|
|
+ gender, gender identity, gender expression,
|
|
|
|
|
+ pregnancy or childbirth and related medical
|
|
|
|
|
+ conditions), sexual orientation, veteran or
|
|
|
|
|
+ military status, genetic information (including
|
|
|
|
|
+ familial genetic information).
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category D: Commercial information.
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Records and history of products or
|
|
|
|
|
+ services purchased or considered.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category E: Biometric information.
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Genetic, physiological, behavioral,
|
|
|
|
|
+ and biological characteristics, or activity
|
|
|
|
|
+ patterns used to extract a template or other
|
|
|
|
|
+ identifier or identifying information, such as,
|
|
|
|
|
+ fingerprints, faceprints, and voiceprints, iris
|
|
|
|
|
+ or retina scans, keystroke, gait, or other
|
|
|
|
|
+ physical patterns, and sleep, health, or
|
|
|
|
|
+ exercise data.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category F: Internet or other similar
|
|
|
|
|
+ network activity.
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Interaction with our Service or
|
|
|
|
|
+ advertisement.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: Yes.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>Category G: Geolocation data.</strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Examples: Approximate physical location.</p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>Category H: Sensory data.</strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Audio, electronic, visual, thermal,
|
|
|
|
|
+ olfactory, or similar information.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category I: Professional or
|
|
|
|
|
+ employment-related information.
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Current or past job history or
|
|
|
|
|
+ performance evaluations.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category J: Non-public education information
|
|
|
|
|
+ (per the Family Educational Rights and
|
|
|
|
|
+ Privacy Act (20 U.S.C. Section 1232g, 34
|
|
|
|
|
+ C.F.R. Part 99)).
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Education records directly related to
|
|
|
|
|
+ a student maintained by an educational
|
|
|
|
|
+ institution or party acting on its behalf, such
|
|
|
|
|
+ as grades, transcripts, class lists, student
|
|
|
|
|
+ schedules, student identification codes, student
|
|
|
|
|
+ financial information, or student disciplinary
|
|
|
|
|
+ records.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category K: Inferences drawn from other
|
|
|
|
|
+ personal information.
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Profile reflecting a person’s
|
|
|
|
|
+ preferences, characteristics, psychological
|
|
|
|
|
+ trends, predispositions, behavior, attitudes,
|
|
|
|
|
+ intelligence, abilities, and aptitudes.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: No.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ Category L: Sensitive personal information.
|
|
|
|
|
+ </strong>
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Examples: Account login and password
|
|
|
|
|
+ information, geolocation data.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Collected: Yes.</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Under CCPA/CPRA, personal information does not include:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Publicly available information from government
|
|
|
|
|
+ records
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>Deidentified or aggregated consumer information</li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Information excluded from the CCPA/CPRA’s
|
|
|
|
|
+ scope, such as:
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Health or medical information covered by the
|
|
|
|
|
+ Health Insurance Portability and
|
|
|
|
|
+ Accountability Act of 1996 (HIPAA) and the
|
|
|
|
|
+ California Confidentiality of Medical
|
|
|
|
|
+ Information Act (CMIA) or clinical trial
|
|
|
|
|
+ data
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Personal Information covered by certain
|
|
|
|
|
+ sector-specific privacy laws, including the
|
|
|
|
|
+ Fair Credit Reporting Act (FRCA), the
|
|
|
|
|
+ Gramm-Leach-Bliley Act (GLBA) or California
|
|
|
|
|
+ Financial Information Privacy Act (FIPA),
|
|
|
|
|
+ and the Driver’s Privacy Protection
|
|
|
|
|
+ Act of 1994
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Sources of Personal Information
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We obtain the categories of personal information listed
|
|
|
|
|
+ above from the following categories of sources:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Directly from You</strong>. For example,
|
|
|
|
|
+ from the forms You complete on our Service,
|
|
|
|
|
+ preferences You express or provide through our
|
|
|
|
|
+ Service.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Indirectly from You</strong>. For example,
|
|
|
|
|
+ from observing Your activity on our Service.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>Automatically from You</strong>. For
|
|
|
|
|
+ example, through cookies We or our Service Providers
|
|
|
|
|
+ set on Your Device as You navigate through our
|
|
|
|
|
+ Service.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>From Service Providers</strong>. For
|
|
|
|
|
+ example, third-party vendors to monitor and analyze
|
|
|
|
|
+ the use of our Service, or other third-party vendors
|
|
|
|
|
+ that We use to provide the Service to You.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Use of Personal Information
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may use or disclose personal information We collect
|
|
|
|
|
+ for "business purposes" or "commercial
|
|
|
|
|
+ purposes" (as defined under the CCPA/CPRA), which
|
|
|
|
|
+ may include the following examples:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ To operate our Service and provide You with Our
|
|
|
|
|
+ Service.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ To provide You with support and to respond to Your
|
|
|
|
|
+ inquiries, including to investigate and address Your
|
|
|
|
|
+ concerns and monitor and improve our Service.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ To fulfill or meet the reason You provided the
|
|
|
|
|
+ information. For example, if You share Your contact
|
|
|
|
|
+ information to ask a question about our Service, We
|
|
|
|
|
+ will use that personal information to respond to
|
|
|
|
|
+ Your inquiry.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ To respond to law enforcement requests and as
|
|
|
|
|
+ required by applicable law, court order, or
|
|
|
|
|
+ governmental regulations.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ As described to You when collecting Your personal
|
|
|
|
|
+ information or as otherwise set forth in the
|
|
|
|
|
+ CCPA/CPRA.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ For internal administrative and auditing purposes.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ To detect security incidents and protect against
|
|
|
|
|
+ malicious, deceptive, fraudulent or illegal
|
|
|
|
|
+ activity, including, when necessary, to prosecute
|
|
|
|
|
+ those responsible for such activities.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>Other one-time uses.</li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Please note that the examples provided above are
|
|
|
|
|
+ illustrative and not intended to be exhaustive. For more
|
|
|
|
|
+ details on how we use this information, please refer to
|
|
|
|
|
+ the "Use of Your Personal Data" section.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If We decide to collect additional categories of
|
|
|
|
|
+ personal information or use the personal information We
|
|
|
|
|
+ collected for materially different, unrelated, or
|
|
|
|
|
+ incompatible purposes We will update this Privacy
|
|
|
|
|
+ Policy.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Disclosure of Personal Information
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may use or disclose and may have used or disclosed in
|
|
|
|
|
+ the last twelve (12) months the following categories of
|
|
|
|
|
+ personal information for business or commercial
|
|
|
|
|
+ purposes:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>Category A: Identifiers</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Category B: Personal information categories
|
|
|
|
|
+ listed in the California Customer Records
|
|
|
|
|
+ statute (Cal. Civ. Code § 1798.80(e))
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Category F: Internet or other similar network
|
|
|
|
|
+ activity
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Please note that the categories listed above are those
|
|
|
|
|
+ defined in the CCPA/CPRA. This does not mean that all
|
|
|
|
|
+ examples of that category of personal information were
|
|
|
|
|
+ in fact disclosed, but reflects our good faith belief to
|
|
|
|
|
+ the best of our knowledge that some of that information
|
|
|
|
|
+ from the applicable category may be and may have been
|
|
|
|
|
+ disclosed.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ When We disclose personal information for a business
|
|
|
|
|
+ purpose or a commercial purpose, We enter a contract
|
|
|
|
|
+ that describes the purpose and requires the recipient to
|
|
|
|
|
+ both keep that personal information confidential and not
|
|
|
|
|
+ use it for any purpose except performing the contract.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Share of Personal Information
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may share, and have shared in the last twelve (12)
|
|
|
|
|
+ months, Your personal information identified in the
|
|
|
|
|
+ above categories with the following categories of third
|
|
|
|
|
+ parties:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>Service Providers</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>Our affiliates</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>Our business partners</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Third party vendors to whom You or Your agents
|
|
|
|
|
+ authorize Us to disclose Your personal
|
|
|
|
|
+ information in connection with products or
|
|
|
|
|
+ services We provide to You
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Sale of Personal Information
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ As defined in the CCPA/CPRA, "sell" and
|
|
|
|
|
+ "sale" mean selling, renting, releasing,
|
|
|
|
|
+ disclosing, disseminating, making available,
|
|
|
|
|
+ transferring, or otherwise communicating orally, in
|
|
|
|
|
+ writing, or by electronic or other means, a
|
|
|
|
|
+ Consumer’s personal information by the Business to
|
|
|
|
|
+ a third party for valuable consideration. This means
|
|
|
|
|
+ that We may have received some kind of benefit in return
|
|
|
|
|
+ for sharing personal information, but not necessarily a
|
|
|
|
|
+ monetary benefit.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We do not sell personal information as the term sell is
|
|
|
|
|
+ commonly understood. We do allow Service Providers to
|
|
|
|
|
+ use Your personal information for the business purposes
|
|
|
|
|
+ described in Our Privacy Policy, for activities such as
|
|
|
|
|
+ advertising, marketing, and analytics, and these may be
|
|
|
|
|
+ deemed a sale under CCPA/CPRA.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may sell and may have sold in the last twelve (12)
|
|
|
|
|
+ months the following categories of personal information:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>Category A: Identifiers</p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Category B: Personal information categories
|
|
|
|
|
+ listed in the California Customer Records
|
|
|
|
|
+ statute (Cal. Civ. Code § 1798.80(e))
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Category F: Internet or other similar network
|
|
|
|
|
+ activity
|
|
|
|
|
+ </p>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Please note that the categories listed above are those
|
|
|
|
|
+ defined in the CCPA/CPRA. This does not mean that all
|
|
|
|
|
+ examples of that category of personal information were
|
|
|
|
|
+ in fact sold, but reflects our good faith belief to the
|
|
|
|
|
+ best of Our knowledge that some of that information from
|
|
|
|
|
+ the applicable category may be and may have been shared
|
|
|
|
|
+ for value in return.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Sale of Personal Information of Minors Under 16 Years of
|
|
|
|
|
+ Age
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We do not knowingly collect personal information from
|
|
|
|
|
+ minors under the age of 16 through our Service, although
|
|
|
|
|
+ certain third party websites that we link to may do so.
|
|
|
|
|
+ These third-party websites have their own terms of use
|
|
|
|
|
+ and privacy policies and We encourage parents and legal
|
|
|
|
|
+ guardians to monitor their children’s Internet
|
|
|
|
|
+ usage and instruct their children to never provide
|
|
|
|
|
+ information on other websites without their permission.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We do not sell the personal information of Consumers We
|
|
|
|
|
+ actually know are less than 16 years of age, unless We
|
|
|
|
|
+ receive affirmative authorization (the "right to
|
|
|
|
|
+ opt-in") from either the Consumer who is between 13
|
|
|
|
|
+ and 16 years of age, or the parent or guardian of a
|
|
|
|
|
+ Consumer less than 13 years of age. Consumers who opt-in
|
|
|
|
|
+ to the sale of personal information may opt-out of
|
|
|
|
|
+ future sales at any time. To exercise the right to
|
|
|
|
|
+ opt-out, You (or Your authorized representative) may
|
|
|
|
|
+ submit a request to Us by contacting Us.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If You have reason to believe that a child under the age
|
|
|
|
|
+ of 13 (or 16) has provided Us with personal information,
|
|
|
|
|
+ please contact Us with sufficient detail to enable Us to
|
|
|
|
|
+ delete that information.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Your Rights under the CCPA/CPRA
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The CCPA/CPRA provides California residents with
|
|
|
|
|
+ specific rights regarding their personal information. If
|
|
|
|
|
+ You are a resident of California, You have the following
|
|
|
|
|
+ rights:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>The right to notice.</strong> You have the
|
|
|
|
|
+ right to be notified which categories of Personal
|
|
|
|
|
+ Data are being collected and the purposes for which
|
|
|
|
|
+ the Personal Data is being used.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>The right to know/access.</strong> Under
|
|
|
|
|
+ CCPA/CPRA, You have the right to request that We
|
|
|
|
|
+ disclose information to You about Our collection,
|
|
|
|
|
+ use, sale, disclosure for business purposes and
|
|
|
|
|
+ share of personal information. Once We receive and
|
|
|
|
|
+ confirm Your request, We will disclose to You:
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The categories of personal information We
|
|
|
|
|
+ collected about You
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The categories of sources for the personal
|
|
|
|
|
+ information We collected about You
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Our business or commercial purposes for
|
|
|
|
|
+ collecting or selling that personal
|
|
|
|
|
+ information
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The categories of third parties with whom We
|
|
|
|
|
+ share that personal information
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The specific pieces of personal information
|
|
|
|
|
+ We collected about You
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ If we sold Your personal information or
|
|
|
|
|
+ disclosed Your personal information for a
|
|
|
|
|
+ business purpose, We will disclose to You:
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The categories of personal
|
|
|
|
|
+ information categories sold
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The categories of personal
|
|
|
|
|
+ information categories disclosed
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ The right to say no to the sale or sharing of
|
|
|
|
|
+ Personal Data (opt-out).
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ You have the right to direct Us to not sell Your
|
|
|
|
|
+ personal information. To submit an opt-out request,
|
|
|
|
|
+ please see the "Do Not Sell My Personal
|
|
|
|
|
+ Information" section or contact Us.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>The right to correct Personal Data.</strong>{" "}
|
|
|
|
|
+ You have the right to correct or rectify any any
|
|
|
|
|
+ inaccurate personal information about You that We
|
|
|
|
|
+ collected. Once We receive and confirm Your request,
|
|
|
|
|
+ We will use commercially reasonable efforts to
|
|
|
|
|
+ correct (and direct our Service Providers to
|
|
|
|
|
+ correct) Your personal information, unless an
|
|
|
|
|
+ exception applies.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ The right to limit use and disclosure of
|
|
|
|
|
+ sensitive Personal Data.
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ You have the right to request to limit the use or
|
|
|
|
|
+ disclosure of certain sensitive personal information
|
|
|
|
|
+ We collected about You, unless an exception applies.
|
|
|
|
|
+ To submit, please see the "Limit the Use or
|
|
|
|
|
+ Disclosure of My Sensitive Personal
|
|
|
|
|
+ Information" section or contact Us.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>The right to delete Personal Data.</strong>{" "}
|
|
|
|
|
+ You have the right to request the deletion of Your
|
|
|
|
|
+ Personal Data under certain circumstances, subject
|
|
|
|
|
+ to certain exceptions. Once We receive and confirm
|
|
|
|
|
+ Your request, We will delete (and direct Our Service
|
|
|
|
|
+ Providers to delete) Your personal information from
|
|
|
|
|
+ our records, unless an exception applies. We may
|
|
|
|
|
+ deny Your deletion request if retaining the
|
|
|
|
|
+ information is necessary for Us or Our Service
|
|
|
|
|
+ Providers to:
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Complete the transaction for which We
|
|
|
|
|
+ collected the personal information, provide
|
|
|
|
|
+ a good or service that You requested, take
|
|
|
|
|
+ actions reasonably anticipated within the
|
|
|
|
|
+ context of our ongoing business relationship
|
|
|
|
|
+ with You, or otherwise perform our contract
|
|
|
|
|
+ with You.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Detect security incidents, protect against
|
|
|
|
|
+ malicious, deceptive, fraudulent, or illegal
|
|
|
|
|
+ activity, or prosecute those responsible for
|
|
|
|
|
+ such activities.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Debug products to identify and repair errors
|
|
|
|
|
+ that impair existing intended functionality.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Exercise free speech, ensure the right of
|
|
|
|
|
+ another consumer to exercise their free
|
|
|
|
|
+ speech rights, or exercise another right
|
|
|
|
|
+ provided for by law.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Comply with the California Electronic
|
|
|
|
|
+ Communications Privacy Act (Cal. Penal Code
|
|
|
|
|
+ § 1546 et. seq.).
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Engage in public or peer-reviewed
|
|
|
|
|
+ scientific, historical, or statistical
|
|
|
|
|
+ research in the public interest that adheres
|
|
|
|
|
+ to all other applicable ethics and privacy
|
|
|
|
|
+ laws, when the information’s deletion
|
|
|
|
|
+ may likely render impossible or seriously
|
|
|
|
|
+ impair the research’s achievement, if
|
|
|
|
|
+ You previously provided informed consent.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Enable solely internal uses that are
|
|
|
|
|
+ reasonably aligned with consumer
|
|
|
|
|
+ expectations based on Your relationship with
|
|
|
|
|
+ Us.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>Comply with a legal obligation.</li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Make other internal and lawful uses of that
|
|
|
|
|
+ information that are compatible with the
|
|
|
|
|
+ context in which You provided it.
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ <strong>
|
|
|
|
|
+ The right not to be discriminated against.
|
|
|
|
|
+ </strong>{" "}
|
|
|
|
|
+ You have the right not to be discriminated against
|
|
|
|
|
+ for exercising any of Your consumer’s rights,
|
|
|
|
|
+ including by:
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>Denying goods or services to You</li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Charging different prices or rates for goods
|
|
|
|
|
+ or services, including the use of discounts
|
|
|
|
|
+ or other benefits or imposing penalties
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Providing a different level or quality of
|
|
|
|
|
+ goods or services to You
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Suggesting that You will receive a different
|
|
|
|
|
+ price or rate for goods or services or a
|
|
|
|
|
+ different level or quality of goods or
|
|
|
|
|
+ services
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Exercising Your CCPA/CPRA Data Protection Rights
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Please see the "Do Not Sell My Personal
|
|
|
|
|
+ Information" section and "Limit the Use or
|
|
|
|
|
+ Disclosure of My Sensitive Personal Information"
|
|
|
|
|
+ section for more information on how to opt out and limit
|
|
|
|
|
+ the use of sensitive information collected.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Additionally, in order to exercise any of Your rights
|
|
|
|
|
+ under the CCPA/CPRA, and if You are a California
|
|
|
|
|
+ resident, You can contact Us:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>By email: info@refine.dev</li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Only You, or a person registered with the California
|
|
|
|
|
+ Secretary of State that You authorize to act on Your
|
|
|
|
|
+ behalf, may make a verifiable request related to Your
|
|
|
|
|
+ personal information.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>Your request to Us must:</p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Provide sufficient information that allows Us to
|
|
|
|
|
+ reasonably verify You are the person about whom We
|
|
|
|
|
+ collected personal information or an authorized
|
|
|
|
|
+ representative
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Describe Your request with sufficient detail that
|
|
|
|
|
+ allows Us to properly understand, evaluate, and
|
|
|
|
|
+ respond to it
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We cannot respond to Your request or provide You with
|
|
|
|
|
+ the required information if We cannot:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ Verify Your identity or authority to make the
|
|
|
|
|
+ request
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ And confirm that the personal information relates to
|
|
|
|
|
+ You
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We will disclose and deliver the required information
|
|
|
|
|
+ free of charge within 45 days of receiving Your
|
|
|
|
|
+ verifiable request. The time period to provide the
|
|
|
|
|
+ required information may be extended once by an
|
|
|
|
|
+ additional 45 days when reasonably necessary and with
|
|
|
|
|
+ prior notice.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Any disclosures We provide will only cover the 12-month
|
|
|
|
|
+ period preceding the verifiable request’s receipt.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ For data portability requests, We will select a format
|
|
|
|
|
+ to provide Your personal information that is readily
|
|
|
|
|
+ usable and should allow You to transmit the information
|
|
|
|
|
+ from one entity to another entity without hindrance.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Do Not Sell My Personal Information
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ As defined in the CCPA/CPRA, "sell" and
|
|
|
|
|
+ "sale" mean selling, renting, releasing,
|
|
|
|
|
+ disclosing, disseminating, making available,
|
|
|
|
|
+ transferring, or otherwise communicating orally, in
|
|
|
|
|
+ writing, or by electronic or other means, a
|
|
|
|
|
+ Consumer’s personal information by the Business to
|
|
|
|
|
+ a third party for valuable consideration. This means
|
|
|
|
|
+ that We may have received some kind of benefit in return
|
|
|
|
|
+ for sharing personal information, but not necessarily a
|
|
|
|
|
+ monetary benefit.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We do not sell personal information as the term sell is
|
|
|
|
|
+ commonly understood. We do allow Service Providers to
|
|
|
|
|
+ use Your personal information for the business purposes
|
|
|
|
|
+ described in Our Privacy Policy, for activities such as
|
|
|
|
|
+ advertising, marketing, and analytics, and these may be
|
|
|
|
|
+ deemed a sale under CCPA/CPRA.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You have the right to opt-out of the sale of Your
|
|
|
|
|
+ personal information. Once We receive and confirm a
|
|
|
|
|
+ verifiable consumer request from You, we will stop
|
|
|
|
|
+ selling Your personal information. To exercise Your
|
|
|
|
|
+ right to opt-out, please contact Us.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The Service Providers we partner with (for example, our
|
|
|
|
|
+ analytics or advertising partners) may use technology on
|
|
|
|
|
+ the Service that sells personal information as defined
|
|
|
|
|
+ by the CCPA/CPRA law. If you wish to opt out of the use
|
|
|
|
|
+ of Your personal information for interest-based
|
|
|
|
|
+ advertising purposes and these potential sales as
|
|
|
|
|
+ defined under CCPA/CPRA law, you may do so by following
|
|
|
|
|
+ the instructions below.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Please note that any opt out is specific to the browser
|
|
|
|
|
+ You use. You may need to opt out on every browser that
|
|
|
|
|
+ You use.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h3>Website</h3>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If applicable, click "Privacy Preferences",
|
|
|
|
|
+ "Update Privacy Preferences" or "Do Not
|
|
|
|
|
+ Sell My Personal Information" buttons listed on the
|
|
|
|
|
+ Service to review your privacy preferences and opt out
|
|
|
|
|
+ of cookies and other technologies that We may use.
|
|
|
|
|
+ Please note that You will need to opt out from each
|
|
|
|
|
+ browser that You use to access the Service.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Additionally, You can opt out of receiving ads that are
|
|
|
|
|
+ personalized as served by our Service Providers by
|
|
|
|
|
+ following our instructions presented on the Service:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The NAI’s opt-out platform:{" "}
|
|
|
|
|
+ <a href="http://www.networkadvertising.org/choices/">
|
|
|
|
|
+ http://www.networkadvertising.org/choices/
|
|
|
|
|
+ </a>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The EDAA’s opt-out platform{" "}
|
|
|
|
|
+ <a href="http://www.youronlinechoices.com/">
|
|
|
|
|
+ http://www.youronlinechoices.com/
|
|
|
|
|
+ </a>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ The DAA’s opt-out platform:{" "}
|
|
|
|
|
+ <a href="http://optout.aboutads.info/?c=2&lang=EN">
|
|
|
|
|
+ http://optout.aboutads.info/?c=2&lang=EN
|
|
|
|
|
+ </a>
|
|
|
|
|
+ </li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ The opt out will place a cookie on Your computer that is
|
|
|
|
|
+ unique to the browser You use to opt out. If you change
|
|
|
|
|
+ browsers or delete the cookies saved by your browser,
|
|
|
|
|
+ You will need to opt out again.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h3>Mobile Devices</h3>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Your mobile device may give You the ability to opt out
|
|
|
|
|
+ of the use of information about the apps You use in
|
|
|
|
|
+ order to serve You ads that are targeted to Your
|
|
|
|
|
+ interests:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>
|
|
|
|
|
+ "Opt out of Interest-Based Ads" or
|
|
|
|
|
+ "Opt out of Ads Personalization" on
|
|
|
|
|
+ Android devices
|
|
|
|
|
+ </li>
|
|
|
|
|
+ <li>"Limit Ad Tracking" on iOS devices</li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You can also stop the collection of location information
|
|
|
|
|
+ from Your mobile device by changing the preferences on
|
|
|
|
|
+ Your mobile device.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h2 style={{ marginTop: 0 }}>
|
|
|
|
|
+ Limit the Use or Disclosure of My Sensitive Personal
|
|
|
|
|
+ Information
|
|
|
|
|
+ </h2>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If You are a California resident, You have the right to
|
|
|
|
|
+ limit the use and disclosure of Your sensitive personal
|
|
|
|
|
+ information to that use which is necessary to perform
|
|
|
|
|
+ the services or provide the goods reasonably expected by
|
|
|
|
|
+ an average Consumer who requests such services or goods.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We collect, use and disclose sensitive personal
|
|
|
|
|
+ information in ways that are necessary to provide the
|
|
|
|
|
+ Service. For more information on how We use Your
|
|
|
|
|
+ personal information, please see the "Use of Your
|
|
|
|
|
+ Personal Data" section or contact us.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>
|
|
|
|
|
+ "Do Not Track" Policy as Required by
|
|
|
|
|
+ California Online Privacy Protection Act (CalOPPA)
|
|
|
|
|
+ </h1>
|
|
|
|
|
+ <p>Our Service does not respond to Do Not Track signals.</p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ However, some third party websites do keep track of Your
|
|
|
|
|
+ browsing activities. If You are visiting such websites,
|
|
|
|
|
+ You can set Your preferences in Your web browser to
|
|
|
|
|
+ inform websites that You do not want to be tracked. You
|
|
|
|
|
+ can enable or disable DNT by visiting the preferences or
|
|
|
|
|
+ settings page of Your web browser.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>
|
|
|
|
|
+ Your California Privacy Rights (California’s Shine
|
|
|
|
|
+ the Light law)
|
|
|
|
|
+ </h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Under California Civil Code Section 1798
|
|
|
|
|
+ (California’s Shine the Light law), California
|
|
|
|
|
+ residents with an established business relationship with
|
|
|
|
|
+ us can request information once a year about sharing
|
|
|
|
|
+ their Personal Data with third parties for the third
|
|
|
|
|
+ parties’ direct marketing purposes.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If you’d like to request more information under
|
|
|
|
|
+ the California Shine the Light law, and if You are a
|
|
|
|
|
+ California resident, You can contact Us using the
|
|
|
|
|
+ contact information provided below.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>
|
|
|
|
|
+ California Privacy Rights for Minor Users (California
|
|
|
|
|
+ Business and Professions Code Section 22581)
|
|
|
|
|
+ </h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ California Business and Professions Code Section 22581
|
|
|
|
|
+ allows California residents under the age of 18 who are
|
|
|
|
|
+ registered users of online sites, services or
|
|
|
|
|
+ applications to request and obtain removal of content or
|
|
|
|
|
+ information they have publicly posted.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ To request removal of such data, and if You are a
|
|
|
|
|
+ California resident, You can contact Us using the
|
|
|
|
|
+ contact information provided below, and include the
|
|
|
|
|
+ email address associated with Your account.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Be aware that Your request does not guarantee complete
|
|
|
|
|
+ or comprehensive removal of content or information
|
|
|
|
|
+ posted online and that the law may not permit or require
|
|
|
|
|
+ removal in certain circumstances.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>Children’s Privacy</h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Our Service does not address anyone under the age of 13.
|
|
|
|
|
+ We do not knowingly collect personally identifiable
|
|
|
|
|
+ information from anyone under the age of 13. If You are
|
|
|
|
|
+ a parent or guardian and You are aware that Your child
|
|
|
|
|
+ has provided Us with Personal Data, please contact Us.
|
|
|
|
|
+ If We become aware that We have collected Personal Data
|
|
|
|
|
+ from anyone under the age of 13 without verification of
|
|
|
|
|
+ parental consent, We take steps to remove that
|
|
|
|
|
+ information from Our servers.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If We need to rely on consent as a legal basis for
|
|
|
|
|
+ processing Your information and Your country requires
|
|
|
|
|
+ consent from a parent, We may require Your
|
|
|
|
|
+ parent’s consent before We collect and use that
|
|
|
|
|
+ information.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>Links to Other Websites</h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ Our Service may contain links to other websites that are
|
|
|
|
|
+ not operated by Us. If You click on a third party link,
|
|
|
|
|
+ You will be directed to that third party’s site.
|
|
|
|
|
+ We strongly advise You to review the Privacy Policy of
|
|
|
|
|
+ every site You visit.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We have no control over and assume no responsibility for
|
|
|
|
|
+ the content, privacy policies or practices of any third
|
|
|
|
|
+ party sites or services.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>Changes to this Privacy Policy</h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We may update Our Privacy Policy from time to time. We
|
|
|
|
|
+ will notify You of any changes by posting the new
|
|
|
|
|
+ Privacy Policy on this page.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ We will let You know via email and/or a prominent notice
|
|
|
|
|
+ on Our Service, prior to the change becoming effective
|
|
|
|
|
+ and update the "Last updated" date at the top
|
|
|
|
|
+ of this Privacy Policy.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ You are advised to review this Privacy Policy
|
|
|
|
|
+ periodically for any changes. Changes to this Privacy
|
|
|
|
|
+ Policy are effective when they are posted on this page.
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <h1>Contact Us</h1>
|
|
|
|
|
+ <p>
|
|
|
|
|
+ If you have any questions about this Privacy Policy, You
|
|
|
|
|
+ can contact us:
|
|
|
|
|
+ </p>
|
|
|
|
|
+ <ul>
|
|
|
|
|
+ <li>By email: info@refine.dev</li>
|
|
|
|
|
+ </ul>
|
|
|
|
|
+ </div>
|
|
|
|
|
+ <BlogFooter />
|
|
|
|
|
+ </div>
|
|
|
|
|
+ </CommonLayout>
|
|
|
|
|
+ );
|
|
|
|
|
+};
|
|
|
|
|
+
|
|
|
|
|
+export default PrivacyPolicy;
|
Stefan Pejcic