Last updated: September 14th, 2022.
Arspectra SARL is a limited liability company under Luxembourg law, who's registered office is located at 20 Rue Du Commerce, 3895 Foetz, Luxembourg and which is registered with the Luxembourg Business Registers under number B225853 (“Arspectra”or “we”). References to “you” and “your” are to persons external to Arspectra (users of our Website such as clients, partners, prospects, suppliers and job applicants).
The protection of your personal data is really important to us. We will ensure that your personal data is processed safely and lawfully, and always in accordance with applicable data protection legislation, and in particular with the General Data Protection Regulation (“GDPR”).
1. Who is responsible for processing your personal data?
Arspectra is the controller, in the meaning of the GDPR, for the processingof your personal data.
2. What personal data do we process?
We will process directly identifying information about you when you provide us with such personal data (for example, through a contact form on one of the pages on our Website our via e-mail) or when you contact us directly by e-mail, phone or fax.
Such personal data can include the following information:
· your name, email address, address, phone number, your job title, your company;
· bank account and payment information in order to pay for products and/or services on the Website;
· if you are a job applicant, your current role and name of your employer, the industry sector where you work, your CV and cover letter.
· If you visit our website, usage data such as your IP address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data may be collected, depending on the consent that you give us;
When you pay for a product or service via bank transfer, we may ask you to provide information to facilitate this transaction and to verify your identity. Such information may include, without limitation:
· Date of birth;
· Passport or National ID card;
· Bank card statement;
· Other information linking you to an address.
We will also process certain non-directly identifying data when you visit our Website, such as the type of browser you are using, the operating system you are using, your IP address, etc.
2. Why do we process your data and under which legal basis?
For the technical and functional management of the Website
We process personal data for the technical and functional management of our Website and to make the Website easy to use. By using your data, we can check how our Website is used and we can improve its content and layout. This data also allows us to adequately secure our Website.
For this, we can process data such as your IP address, the pages you visit, the browser you are using, and the time and duration of your visit.
We process this data based on the legitimate interest of Arspectra in providing a well-functioning and secure Website.
To provide you with our services and manage your account
If you are one of our clients, we process your personal data to provide you with the services you requested us to perform as well as to send you our invoice. Such services can include drafting agreements, negotiating the terms of a transaction, representing you in court etc.
To this end, we can process data such as your name, your job, your company name, your address, your e-mail address, your invoicing information.
We process this information for the performance of the contract with you. Without your personal data, we cannot perform the contract and provide you with our services.
To contact you
We process your personal data to contact you by email, telephone, 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. We process this information for the performance of the contract with you. Without your personal data, we cannot perform the contract and provide you with our services.
To represent and defend the interests of our clients
We may have received your personal data in the context of one of the missions entrusted to us by one of our clients. Your personal data will only be processed to the extent that and for as long as this is necessary for the representation of our client’s interests.
We process this information based on our legitimate interests consisting inbeing able to carry out our missions for our clients.
To keep you informed of our services and activities and for direct marketing
We process your personal data to keep you informed of our activities, for example, with our newsletter and legal updates, invitations to seminars, workshops or other events.
To this end, we can process data such as your name, your job, your company name, your address, your e-mail address and your preferred language.
We process this information based on our legitimate interests to keep our prospects or clients informed of our activities and services. You can object to this processing of your personal data at any time (see point 6).
To answer your questions
If you ask us a question by telephone, via a contact form on the Website or by e-mail, we will process your personal data in order to answer that question.
For this, we can process data such as your name, your contact information, your correspondence with Arspectra, and any other personal data you provide that may be relevant to answering your question.
We process this information based on our legitimate interests. You are free to choose to provide us with your personal data, and you object at any time(see point 6).
To make contact in the context of a selection and recruitment process
When you apply for a job through the Website or by e-mail, we process your personal data in order to contact you and to follow up your application.
For this, we can process data such as your name, your contact information, your correspondence with Arspectra, your resume, and other documents you provide us with.
The processing of your personal data for this purpose is based on your request to take steps prior to entering into a contract.
To comply with our legal and regulatory obligations
If you are a client of Arspectra, we have to comply with certain legal and regulatory obligations such as with respect to anti-money laundering, KYC declarations and sanction checks. We must also comply with our tax and accounting obligations.
For this, we can process data such as your name, your contact information, your correspondence with Arspectra and your financial data.
The processing of your personal data for this purpose is based on the need for Arspectra to respect a legal obligation we need to comply with.
Handling our own disputes
We may process your personal data to handle our own disputes and protect and enforce our rights.
For this, we can process data such as your name, your contact information, your correspondence with Arspectra and your financial data.
The processing of your personal data for this purpose is based on our legitimate interests consisting in being able to safeguard our rights in the event of disputes.
We may use your personal data 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.
4. Who has access to your personal data?
Arspectra makes use of Webflow Inc. to manage and host the Website. Arspectra has entered into a agreement with such entities.
Arspectra’s servers are located in Luxembourg and we will not transfer your personal data to countries outside the European Economic Area except (i) at your request, or (ii) to the extent necessary for the institution, exercise or substantiation of a legal claim. In the context of the use of some software applications, personal data may however be temporarily transferred to countries outside the Economic European Area. In such a case, an adequate level of protection is provided through the use of the European Commission's Standard Clauses.
We may use third-party service providers to monitor and analyze the use of our Website.
Google Analytics is a web analytics service offered by Google that track sand reports website traffic. Google uses the data collected to track and monitor the use of our Website. 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.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Our Websites allows you to follow us on social media channels, e.g. LinkedIn and Twitter. We do not use these buttons to share your personal data with social media providers. When you click on a follow button, the relevant social media provider will gather your personal data directly from you. Please read the privacy notice of any social media provider with which you intend to share your personal data.
We may provide paid products and/or services within the Website. In that case, we may use third-party services for payment processing (e.g. payment processors).
When you use our Website to pay for a product and/or service via bank transfer, we may ask you to provide information to facilitate this transaction and to verify your identity.
Other third parties
We may share your personal data with:
· (sub)contractors for assisting us in fulfilling the purposes listed above;
· service providers: to monitor and analyze the use of our Website, for payment processing, or to contact you;
· our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
· the bar authorities, judicial, police or administrative authorities if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, a binding decision of an administrative authority or a court order;
· investors and other relevant third parties in in the event of a potential sale or other corporate transaction related to Arspectra;
· other Website users: when you share personal data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
Arspectra will only share your personal data with these third parties provided that they comply with GDPR if they act as independent controllers, or based on a data processing agreement if they act as processors. For a detailed list of these third parties, please contact us by e-mail at firstname.lastname@example.org, by post to Rue Du Commerce 20, 3895 Foetz,(Luxembourg) or by phone at: +352 691 722 733.
5. How do we protect your personal data and how long do we keep your personal data?
Arspectra takes reasonable security measures to protect your personal data from destruction, loss, modification or any other unauthorized processing.
Arspectra does not store your personal data for longer than necessary for the purposes for which it is stored. 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.
We will also retain Usage Data (i.e. data collected automatically, either generated by the use of the Website or from the Website infrastructure itself 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 Website, or if we are legally obligated to retain this data for longer time periods.
If you would like to find out how long we keep your personal data for a particular purpose you can contact us by e-mail at email@example.com, by post to Rue Du Commerce 20, 3895 Foetz, (Luxembourg) or by phone at: +352 691 722 733.
6. What rights do you have and how can you exercise your rights?
· You have the right to access your personal data. This allows you to find out which personal data we process about you.
· You have the right to correct your personal data. This allows you to correct or complete incorrect or incomplete personal data that we process about you.
· You have the right of deletion of your personal data. This allows you to permanently delete the personal data we process about you. We are not always obliged to delete your personal data at your request -this right only applies in the cases and to the extent provided for by law.
· You have the right to limit the processing of personal data relating to you. This allows you to freeze our use of your personal data without deleting it. We are not always obliged to limit the processing of your personal data at your request - this right only applies in the cases and to the extent provided for by law.
· You have the right to object to the processing of your personal data. This allows you to object to the further processing of your personal data. We are not always obliged to accept your objection - this right only applies if we process your personal data on the basis of our legitimate interest.
· You have the right to withdraw your consent when the processing of your personal data takes place on the basis of your consent. Withdrawal of your consent does not affect the lawfulness of the processing based on consent before withdrawal.
· You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by a third party. We will be allowed to continue to process your personal data if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise or defense of legal claims. You can always object to the processing of your personal data for direct marketing purposes.
· You may have the right to data portability. This allows you to easily transfer, copy or move personal data from one controller to another. This right can only be exercised if the processing is based on your consent or on an agreement concluded with you.
You can direct your request based on the above rights and your complaints at firstname.lastname@example.org, by post to Rue Du Commerce 20, 3895 Foetz,(Luxembourg) or by phone at: +352 691 722 733.
You also have the right to file a complaint with the supervisory authority of the place where you live. For Luxembourg this is the Luxembourg National Commission for Data Protection (Commission nationale pour la protection des données (“CNPD”)). It can be reached by mail at 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg, via website at the following address: https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html and by phone at: (+352) 26 10 60 -1.
Last updated: September 14th, 2022.
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' Personal Data and determines the purposes and means of the processing of Consumers' Personal Data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' Personal Data, that does business in the State of California.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC),for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Personal Data, for the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Data to another business or a third party for monetary or other valuable consideration.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website, to host the Website on behalf of the Company, to perform services related to the Website or to assist the Company in analyzing how the Website is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
2. Categories of Personal Data collected
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 Data which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data 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 Data would only be collected if you provided such Personal Data directly to us.
Category A: Identifiers.
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.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or 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.
Category C: Protected classification characteristics under California or federal law.
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).
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Category E: Biometric information.
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.
Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Category G: Geolocation data.
Examples: Approximate physical location.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
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)).
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.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Under CCPA, Personal Data does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
· Information excluded from the CCPA's scope, such as:
· Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
· Personal Data 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.
3. Sources of Personal Data
We obtain the categories of Personal Data listed above from the following categories of sources:
· Directly from you. For example, from the forms you complete on our Website, preferences you express or provide through our Website, or from your purchases on our Website.
· Indirectly from you. For example, from observing your activity on our Website.
· Automatically from you. For example, through cookies we or our Service Providers seton your Device as you navigate through our Website.
· From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that we use to provide the Website to you.
4. Use of Personal Data for Business Purposes or Commercial Purposes
We may use or disclose Personal Data. We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:
· To operate our Website and provide you our Website;
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Website;
· To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Website, we will use that Personal Data to respond to your inquiry. If you provide your Personal Data to purchase a product or service, we will use that information to process your payment and facilitate delivery;
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
· As described to you when collecting your Personal Data or as otherwise set forth in the CCPA;
· For internal administrative and auditing purposes;
· To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
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.
5. Disclosure of Personal Data for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Data for business or commercial purposes:
· Category A: Identifiers.
· Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
· Category D: Commercial information
· Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Data 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.
When we disclose Personal Data for a business purpose or a commercial purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except performing the contract.
6. Sale of Personal Data
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Data 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 Data, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data 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.
We may sell and may have sold in the last twelve (12) months the following categories of Personal Data:
· Category A: Identifiers.
· Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
· Category D: Commercial information.
· Category F: Internet or other similar network activity.
7. Sharing of Personal Data
We may share your Personal Data identified in the above categories with the following categories of third parties:
· Service Providers;
· Payment processors;
· Our affiliates;
· Our business partners;
· Third party vendors to whom you or your agents authorize us to disclose your Personal Data in connection with products or services we provide to you.
8. Sale of Personal Data of Minors Under 16 Years of Age
We do not sell the Personal Data 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 Data 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.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with Personal Data, please contact us with sufficient detail to enable us to delete that information.
9. Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their Personal Data. If you are a resident of California, you have the following rights:
· The right to notice. 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.
· The right to request. Under CCPA, 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 Data. Once we receive and confirm your request, we will disclose to you:
· The categories of Personal Data we collected about you;
· The categories of sources for the Personal Data we collected about you;
· Our business or commercial purpose for collecting or selling that Personal Data;
· The categories of third parties with whom we share that Personal Data;
· The specific pieces of Personal Data we collected about you;
· If we sold your Personal Data or disclosed your Personal Data for a business purpose, we will disclose to you:
· The categories of Personal Data categories sold;
· The categories of Personal Data categories disclosed.
· The right to say no to the sale of Personal Data (opt-out). You have the right to direct us to not sell your Personal Data. To submit an opt-out request please contact us.
· The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your Personal Data 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:
· Complete the transaction for which we collected the Personal Data, 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;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to 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;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us;
· Comply with a legal obligation;
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
· The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:
· Denying goods or services to you;
· Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties;
· Providing a different level or quality of goods or services to you;
· Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
10. Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us:
By email: email@example.com.
By visiting this page on our website: http://www.arspectra.com/contact.
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 Data.
Your request to us must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative;
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with the required information if we cannot:
· Verify your identity or authority to make the request;
· And confirm that the Personal Data relates to you.
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.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
11. Do Not Sell My Personal Data
You have the right to opt-out of the sale of your Personal Data. Once we receive and confirm a verifiable consumer request from you, we will stop selling your Personal Data. To exercise your right to opt-out, please contact us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Website that sells Personal Data as defined by the CCPA law. If you wish to opt out of the use of your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
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.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
· The NAI's opt-out platform: http://www.networkadvertising.org/choices/
· The EDAA's opt-out platform http://www.youronlinechoices.com/
· The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
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:
· "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices;
· "Limit Ad Tracking" on iOS devices.
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
12. Links to other websites
"DO NOT TRACK"POLICY AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CALOPPA)
Our Website does not respond to Do Not Track signals.
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.
Our Website 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.
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.
YOUR CALIFORNIA PRIVACYRIGHTS (CALIFORNIA'S SHINE THE LIGHT LAW)
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.
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.
CALIFORNIA PRIVACY RIGHTSFOR MINOR USERS (CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
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.
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.