From 391610b58fa2a6b1d574f98b8d6279372012b677 Mon Sep 17 00:00:00 2001 From: James Surine Date: Sat, 23 Mar 2024 18:36:52 -0500 Subject: [PATCH] add privacy policy --- ANKHPrivacyPolicy.html | 3007 ++++++++++++++++++++++++++++++++++++++++ 1 file changed, 3007 insertions(+) create mode 100644 ANKHPrivacyPolicy.html diff --git a/ANKHPrivacyPolicy.html b/ANKHPrivacyPolicy.html new file mode 100644 index 0000000..f7301a7 --- /dev/null +++ b/ANKHPrivacyPolicy.html @@ -0,0 +1,3007 @@ + + + + + +
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PRIVACY + NOTICE
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Last updated March + 23, 2024
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Thank + you for choosing to be part of our community. + We are committed to protecting your personal information and your + right to privacy. If you have any questions or concerns about this + privacy notice or our practices with regard to your personal + information, please contact us at james.surine@gmail.com.
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This privacy notice describes how we + might use your information if you: +
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  • Download + and use our application + ANKH
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  • Engage + with us in other related ways including any sales, + marketing, or events
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In + this privacy notice, if we refer to: +
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  • "App," + we are referring to any application of ours that + references or links to this policy, including any listed + above
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  • "Services," + we are referring to our App, and other related + services, including any sales, marketing, or events
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The + purpose of this privacy notice is to explain to you in the + clearest way possible what information we collect, how we + use it, and what rights you have in relation to it. If + there are any terms in this privacy notice that you do not + agree with, please discontinue use of our Services + immediately.
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Please read this + privacy notice carefully, as it will help you + understand what we do with the information that we + collect.
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TABLE OF CONTENTS
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1. + WHAT INFORMATION DO WE COLLECT?
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Personal + information you disclose to us
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In + Short: We + collect personal information that you provide to + us.
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We + collect personal information that you voluntarily provide + to us when you express an interest in + obtaining information about us or our products and + Services, when you participate in activities on the App + or otherwise when you contact us.
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The + personal information that we collect depends on the + context of your interactions with us and the App, the choices you make and the + products and features you use. The personal information + we collect may include the following:
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Personal + Information Provided by You. We collect usage + data; and other similar + information.
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All + personal information that you provide to us must be true, + complete and accurate, and you must notify us of any + changes to such personal information.
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Information + automatically collected
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In + Short: Some + information such as your Internet Protocol + (IP) address and device characteristics is + collected automatically when you use our App.
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We + automatically collect certain information when you use the + App. + This information does not reveal your specific identity + (like your name or contact information) but may include + device and usage information, such as your IP address, + device characteristics, operating system, language + preferences, device name, country, location, information + about how and when you use our App + and other technical information. This information is + primarily needed to maintain the security and operation of + our App, + and for internal analytics and reporting purposes.
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The + information we collect includes:
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  • Log + and Usage Data. Log and usage data is + service-related, diagnostic, usage and performance + information our servers automatically collect when you + access or use our App + and which we record in log files. Depending on how you + interact with us, this log data may include your IP + address, device information and settings and information + about your activity in the App (such as the + date/time stamps associated with your usage and other + actions you take such as which features you use), device + event information (such as system activity, error + reports (sometimes called 'crash dumps') and hardware + settings).
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  • Device + Data. We collect device data such as information + about your computer, phone, VR headset or other device + you use to access the App. + Depending on the device used, this device data may + include information such as your IP address (or proxy + server), device and application identification numbers, + location, hardware model Internet service provider + and/or mobile carrier, operating system and system + configuration information.
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  • Location + Data. We collect location data such as + information about your device's location, which can be + either precise or imprecise. How much information we + collect depends on the type and settings of the device + you use to access the App. + You can opt out of allowing us to collect this + information either by refusing access to the information + or by disabling your Location setting on your device. + Note however, if you choose to opt out, you may not be + able to use certain aspects of the Services.
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2. + WILL YOUR INFORMATION BE SHARED WITH ANYONE?
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In + Short: We only share information + with your consent, to comply with laws, to provide you + with services, to protect your rights, or to fulfill + business obligations.
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We + may process or share your data that we hold based on the + following legal basis:
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  • Consent: + We may process your data if you have given us specific + consent to use your personal information for a specific + purpose.
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  • Legitimate + Interests: We may process your data when it + is reasonably necessary to achieve our legitimate + business interests.
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  • Performance + of a Contract: Where we have entered into a + contract with you, we may process your personal + information to fulfill the terms of our contract.
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  • Legal + Obligations: We may disclose your information + where we are legally required to do so in order to + comply with applicable law, governmental requests, a + judicial proceeding, court order, or legal process, such + as in response to a court order or a subpoena (including + in response to public authorities to meet national + security or law enforcement requirements).
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  • Vital + Interests: We may disclose your information + where we believe it is necessary to investigate, + prevent, or take action regarding potential violations + of our policies, suspected fraud, situations involving + potential threats to the safety of any person and + illegal activities, or as evidence in litigation in + which we are involved.
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More + specifically, we may need to process your data or share + your personal information in the following situations:
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  • Business + Transfers. We may share or transfer your + 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.
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3. HOW + LONG DO WE KEEP YOUR INFORMATION?
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In + Short: We keep your + information for as long as necessary to + fulfill the purposes outlined in this + privacy notice unless otherwise required + by law.
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We will only + keep your personal information for as long + as it is necessary for the purposes set out + in this privacy notice, unless a longer + retention period is required or permitted by + law (such as tax, accounting or other legal + requirements). No purpose in this notice + will require us keeping your personal + information for longer than 2 + years.
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When we have + no ongoing legitimate business need to + process your personal information, we will + either delete or anonymize such information, + or, if this is not possible (for example, + because your personal information has been + stored in backup archives), then we will + securely store your personal information and + isolate it from any further processing until + deletion is possible.
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4. HOW + DO WE KEEP YOUR INFORMATION SAFE?
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In + Short: We aim to + protect your personal information through + a system of organizational and technical + security measures.
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We have + implemented appropriate technical and + organizational security measures designed to + protect the security of any personal + information we process. However, despite our + safeguards and efforts to secure your + information, no electronic transmission over + the Internet or information storage + technology can be guaranteed to be 100% + secure, so we cannot promise or guarantee + that hackers, cybercriminals, or other + unauthorized third parties will not be able + to defeat our security, and improperly + collect, access, steal, or modify your + information. Although we will do our best to + protect your personal information, + transmission of personal information to and + from our App + is at your own risk. You should only access + the App + within a secure environment.
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5. + WHAT ARE YOUR PRIVACY RIGHTS?
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In + Short: In + some regions, such as the European + Economic Area (EEA) and United Kingdom + (UK), you have rights that allow you + greater access to and control over your + personal information. You + may review, change, or terminate your + account at any time.
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In some + regions (like the EEA and UK), you have + certain rights under applicable data + protection laws. These may include the right + (i) to request access and obtain a copy of + your personal information, (ii) to request + rectification or erasure; (iii) to restrict + the processing of your personal information; + and (iv) if applicable, to data portability. + In certain circumstances, you may also have + the right to object to the processing of + your personal information. To make such a + request, please use the contact + details provided + below. We will consider and act upon any + request in accordance with applicable data + protection laws.
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If we are + relying on your consent to process your + personal information, you have the right to + withdraw your consent at any time. Please + note however that this will not affect the + lawfulness of the processing before its + withdrawal, nor will it affect the + processing of your personal information + conducted in reliance on lawful processing + grounds other than consent.
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If you are a + resident in the EEA or UK and you believe we + are unlawfully processing your personal + information, you also have the right to + complain to your local data protection + supervisory authority. You can find their + contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
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If you are a + resident in Switzerland, the contact details + for the data protection authorities are + available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
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6. + CONTROLS FOR DO-NOT-TRACK FEATURES
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Most web + browsers and some mobile operating systems + and mobile applications include a + Do-Not-Track ("DNT") feature or setting you + can activate to signal your privacy + preference not to have data about your + online browsing activities monitored and + collected. At this stage no uniform + technology standard for recognizing and + implementing DNT signals has been finalized. + As such, we do not currently respond to DNT + browser signals or any other mechanism that + automatically communicates your choice not + to be tracked online. If a standard for + online tracking is adopted that we must + follow in the future, we will inform you + about that practice in a revised version of + this privacy notice.
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7. DO + CALIFORNIA RESIDENTS HAVE SPECIFIC + PRIVACY RIGHTS?
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In + Short: Yes, if you + are a resident of California, you are + granted specific rights regarding access + to your personal information.
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California + Civil Code Section 1798.83, also known as + the "Shine The Light" law, permits our users + who are California residents to request and + obtain from us, once a year and free of + charge, information about categories of + personal information (if any) we disclosed + to third parties for direct marketing + purposes and the names and addresses of all + third parties with which we shared personal + information in the immediately preceding + calendar year. If you are a California + resident and would like to make such a + request, please submit your request in + writing to us using the contact information + provided below.
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If you are + under 18 years of age, reside in California, + you have the right to request removal of + unwanted data that you publicly post on the + App. + To request removal of such data, please + contact us using the contact information + provided below, and include the email + address associated with your account and a + statement that you reside in California. We + will make sure the data is not publicly + displayed on the App, + but please be aware that the data may not be + completely or comprehensively removed from + all our systems (e.g. backups, etc.).
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CCPA + Privacy Notice
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The + California Code of Regulations + defines a "resident" as:
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(1) every + individual who is in the State of California + for other than a temporary or transitory + purpose and
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(2) every + individual who is domiciled in the State of + California who is outside the State of + California for a temporary or transitory + purpose
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All other + individuals are defined as "non-residents."
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If this + definition of "resident" applies to you, we + must adhere to certain rights and + obligations regarding your personal + information.
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What + categories of personal information do we + collect?
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We have + collected the following categories of + personal information in the past twelve (12) + months:
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CategoryExamplesCollected
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A. + Identifiers
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Contact + details, such as real name, alias, + postal address, telephone or mobile + contact number, unique personal + identifier, online identifier, + Internet Protocol address, email + address and account name
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NO
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B. + Personal information categories + listed in the California Customer + Records statute
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Name, + contact information, education, + employment, employment history and + financial information
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NO
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C. + Protected classification + characteristics under California or + federal law
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Gender + and date of birth
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NO
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D. + Commercial information
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Transaction + information, purchase history, + financial details and payment + information
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NO
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E. + Biometric information
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Fingerprints + and voiceprints
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NO
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F. + Internet or other similar network + activity
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Browsing + history, search history, online + behavior, interest data, and + interactions with our and other + websites, applications, systems and + advertisements
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NO
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G. + Geolocation data
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Device + location
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NO
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H. + Audio, electronic, visual, thermal, + olfactory, or similar information
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Images + and audio, video or call recordings + created in connection with our + business activities
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NO
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I. + Professional or employment-related + information
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Business + contact details in order to provide + you our services at a business + level, job title as well as work + history and professional + qualifications if you apply for a + job with us
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NO
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J. + Education Information
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Student + records and directory information
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NO
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K. + Inferences drawn from other personal + information
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Inferences + drawn from any of the collected + personal information listed above to + create a profile or summary about, + for example, an individuals + preferences and characteristics
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NO
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We may also + collect other personal information outside + of these categories instances where you + interact with us in-person, online, or by + phone or mail in the context of:
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  • Receiving + help through our customer support + channels;
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  • Participation + in customer surveys or contests; and
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  • Facilitation + in the delivery of our Services and to + respond to your inquiries.
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How do + we use and share your personal + information?
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More + information about our data collection and + sharing practices can be found in this + privacy notice.
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You may + contact us by + email at james.surine@gmail.com.
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If you are + using an authorized agent to exercise your + right to opt-out we may deny a request if + the authorized agent does not submit proof + that they have been validly authorized to + act on your behalf.
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Will + your information be shared with anyone + else?
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We may + disclose your personal information with our + service providers pursuant to a written + contract between us and each service + provider. Each service provider is a + for-profit entity that processes the + information on our behalf.
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We may use + your personal information for our own + business purposes, such as for undertaking + internal research for technological + development and demonstration. This is not + considered to be "selling" of your personal + data.
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James + Surine + has not disclosed or sold any personal + information to third parties for a business + or commercial purpose in the preceding 12 + months. James Surine + will not sell personal information in the + future belonging to website visitors, users + and other consumers.
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Your + rights with respect to your personal data
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Right to + request deletion of the data - Request to + delete
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You can ask + for the deletion of your personal + information. If you ask us to delete your + personal information, we will respect your + request and delete your personal + information, subject to certain exceptions + provided by law, such as (but not limited + to) the exercise by another consumer of his + or her right to free speech, our compliance + requirements resulting from a legal + obligation or any processing that may be + required to protect against illegal + activities.
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Right to be + informed - Request to know
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Depending on + the circumstances, you have a right to know:
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  • whether we + collect and use your personal information;
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  • the + categories of personal information that we + collect;
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  • the purposes + for which the collected personal + information is used;
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  • whether we + sell your personal information to third + parties;
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  • the + categories of personal information that we + sold or disclosed for a business purpose;
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  • the + categories of third parties to whom the + personal information was sold or disclosed + for a business purpose; and
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  • the business + or commercial purpose for collecting or + selling personal information.
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In accordance + with applicable law, we are not obligated to + provide or delete consumer information that + is de-identified in response to a consumer + request or to re-identify individual data to + verify a consumer request.
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Right to + Non-Discrimination for the Exercise of a + Consumers Privacy Rights
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We will not + discriminate against you if you exercise + your privacy rights.
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Verification + process
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Upon receiving + your request, we will need to verify your + identity to determine you are the same + person about whom we have the information in + our system. These verification efforts + require us to ask you to provide information + so that we can match it with information you + have previously provided us. For instance, + depending on the type of request you submit, + we may ask you to provide certain + information so that we can match the + information you provide with the information + we already have on file, or we may contact + you through a communication method (e.g. + phone or email) that you have previously + provided to us. We may also use other + verification methods as the circumstances + dictate.
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We will only + use personal information provided in your + request to verify your identity or authority + to make the request. To the extent possible, + we will avoid requesting additional + information from you for the purposes of + verification. If, however, we cannot verify + your identity from the information already + maintained by us, we may request that you + provide additional information for the + purposes of verifying your identity, and for + security or fraud-prevention purposes. We + will delete such additionally provided + information as soon as we finish verifying + you.
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Other + privacy rights
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  • you may + object to the processing of your personal + data.
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  • you may + request correction of your personal data + if it is incorrect or no longer relevant, + or ask to restrict the processing of the + data.
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  • you can + designate an authorized agent to make a + request under the CCPA on your behalf. We + may deny a request from an authorized + agent that does not submit proof that they + have been validly authorized to act on + your behalf in accordance with the CCPA.
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  • you may + request to opt-out from future selling of + your personal information to third + parties. Upon receiving a request to + opt-out, we will act upon the request as + soon as feasibly possible, but no later + than 15 days from the date of the request + submission.
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To exercise + these rights, you can contact us by + email at james.surine@gmail.com. If you have a + complaint about how we handle your data, we + would like to hear from you. +
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8. DO + WE MAKE UPDATES TO THIS NOTICE? +
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In + Short: Yes, we will update + this notice as necessary to stay compliant + with relevant laws.
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We may update + this privacy notice from time to time. The + updated version will be indicated by an + updated "Revised" date and the updated + version will be effective as soon as it is + accessible. If we make material changes to + this privacy notice, we may notify you + either by prominently posting a notice of + such changes or by directly sending you a + notification. We encourage you to review + this privacy notice frequently to be + informed of how we are protecting your + information.
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9. HOW + CAN YOU CONTACT US ABOUT THIS + NOTICE? +
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If you have + questions or comments about this notice, you + may email + us at james.surine@gmail.com
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10. + HOW CAN YOU REVIEW, UPDATE, OR + DELETE THE DATA WE COLLECT FROM YOU? +
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You + have the right to request access to the + personal information we collect from you, + change that information, or delete it. To request to review, + update, or delete your personal information, + please email + james.surine@gmail.com.
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+ This privacy policy was created using Termly's Privacy + Policy Generator.
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