Privacy Policy

You have important rights concerning your personal information. The Company is committed to respecting these rights and has processes in place to enable you to exercise them. Your rights may vary depending on your jurisdiction (for example, GDPR grants certain rights to individuals in the European Economic Area, while CCPA grants specific rights to California residents), but we will endeavor to honor any legitimate request to the fullest extent required by applicable law. These rights include:

8.1. Rights for Individuals in the EEA, UK, and Similar Jurisdictions: If you are located in the European Union, United Kingdom, or other jurisdictions with comparable data protection laws, you have the following rights with respect to your personal data:

• Right to Be Informed: You have the right to be informed about the collection and use of your personal data. This Privacy Policy is intended to provide you with that information, including who we are, what data we collect, how we use it, and other relevant details.
• Right of Access: You have the right to request confirmation of whether we are processing personal data about you, and if so, to request a copy of the personal data we hold about you (commonly known as a “data subject access request”). We will provide you with a copy of your data, along with information on what data we have, why we have it, who we disclose it to, how long we store it, and whether it came from a source other than you, as required by law .
• Right to Rectification: You have the right to request that we correct or update any inaccurate or incomplete personal data we hold about you. If you believe any of your information is incorrect, please let us know and we will rectify it.
• Right to Erasure: You have the right to request the deletion of your personal data in certain circumstances (also known as the “right to be forgotten”). For example, you can request erasure if the data is no longer necessary for the purposes for which it was collected if you have withdrawn your consent and no other legal basis for processing exists, or if you object to processing and we have no overriding legitimate grounds to continue. We will honor valid erasure requests and also instruct any applicable service providers or processors to delete your data, provided that no lawful exception to deletion applies (such as a requirement to retain data for legal compliance).
• Right to Restrict Processing: You have the right to request that we restrict (pause) the processing of your personal data under certain conditions – for example, while we verify your data correction request, or if you object to our processing and we are considering that objection. When processing is restricted, we will continue to store your personal data but will not use it until the restriction is lifted (unless for legal reasons).
• Right to Data Portability: You have the right to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible. This right applies when processing is based on your consent or on a contract with you, and is carried out by automated means. We will assist in the direct transfer to a third party where possible if you request.
• Right to Object: You have the right to object to our processing of your personal data when such processing is based on our legitimate interests (or those of a third party) or is for direct marketing purposes. If you object on compelling legitimate grounds relating to your particular situation, we will consider your objection and will no longer process the data unless we have demonstrably overridden legitimate grounds or it is needed for legal claims. If you object to processing for direct marketing, we will cease such processing for that purpose.
• Right Not to be Subject to Automated Decisions: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects or similarly significant effects for you, unless it is necessary for entering into or performing a contract, based on your explicit consent, or otherwise authorized by law. We generally do not make such automated decisions without human involvement, but if we ever do, you have the right to request human review and to contest the decision.
• Right to Withdraw Consent: If we rely on your consent to process personal data, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it will not affect processing of your personal data under other legal bases (for example, processing based on a contract or legitimate interests). If you withdraw consent for a specific purpose (such as receiving marketing communications), we will stop processing your data for that purpose.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your national data protection supervisory authority (such as the Data Protection Commission in Ireland, the Information Commissioner’s Office in the UK, or your local EU regulator) if you believe that we have infringed your data protection rights. We would, however, appreciate the chance to address your concerns before you approach a regulator, so please consider contacting us first so we can try to resolve the issue. We take all privacy complaints seriously and will respond in accordance with applicable law.
  
  

These rights are not absolute – there are exceptions and limitations. For instance, we may refuse an access request if granting it would adversely affect the rights and freedoms of others, or we might retain certain data despite a deletion request if required for legal compliance. If we deny a request for legitimate reasons, we will inform you of the reason (unless we are legally prevented from doing so).

8.2. Rights for California (CCPA) and Other U.S. State Residents: If you are a resident of California, you are entitled to specific rights under the CCPA (as amended by the CPRA), and similar rights may apply if you are a resident of other states with privacy laws (such as Virginia, Colorado, Connecticut, Utah, etc., which we will address in line with their respective statutes). For California residents, the following rights apply:

• Right to Know: You have the right to request that we disclose what personal information we have collected about you in the past 12 months, including the categories of personal information, the categories of sources, the business or commercial purposes for collecting (or selling/sharing, if applicable) that information, and the categories of third parties with whom we share personal information. You also have the right to request access to the specific pieces of personal information we collected about you.
• Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (for example, we may retain information to complete a transaction you requested, to detect security incidents, for legal compliance, etc.). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
• Right to Opt-Out of Sale or Sharing: You have the right to opt out of the “sale” or “sharing” of your personal information. The CCPA defines “sale” broadly to include certain types of data sharing for advertising purposes. We do not sell personal information for money; however, we may share usage data with third-party advertising partners to serve you personalized ads, which under CCPA could be considered a “sale” or “sharing” of data. If we engage in such activity, we will provide a “Do Not Sell or Share My Personal Information” link or honor global opt-out preference signals such as the Global Privacy Control (GPC) as a valid opt-out request for cookies and tracking technologies. When you opt-out, we will stop selling/sharing your personal data for these purposes.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. We will not deny services, charge different prices, or provide a different level of quality of service to you just because you exercise your privacy rights. However, in some cases, if you ask us to delete your data or opt out of certain processing, we may not be able to provide services that rely on that data (for example, if you opt out of certain data sharing, some personalized features may not function). We will always inform you if any service limitations would result from honoring your request.
• Right to Correct: As of January 1, 2023, California residents also have the right to request the correction of inaccurate personal information maintained about them. Upon receipt of a verifiable request, we will use commercially reasonable efforts to correct the information as directed.
• Right to Limit Use of Sensitive Personal Information: If we collect “sensitive personal information” (as defined by CCPA, e.g. precise geolocation, social security number, etc.), California residents have the right to limit our use or disclosure of such sensitive information to only what is necessary to perform the services or provide the goods (or other exempt purposes). We generally do not collect or use sensitive personal information for purposes beyond what is necessary to provide our services, but if we ever do, we will honor requests to limit its use/disclosure.
  
  

To exercise any of the above rights, California (or other applicable state) residents can contact us using the information in the Contact Information section. We will ask you to verify your identity and residency to ensure that your personal information is protected from unauthorized access. You may also designate an authorized agent to make requests on your behalf; we will require proof of the authorization and still take steps to verify the identity of the requester or the validity of the request.

Additionally, California’s “Shine the Light” law (Civil Code § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with unaffiliated third parties for their own direct marketing use without your permission. If you have questions about this, you can contact us as well.

8.3. How to Exercise Your Rights:

• Submission of Requests: To exercise any applicable privacy rights (access, correction, deletion, etc.), please contact us by email, phone, or mail as specified in the Contact Information section below. Please clearly describe your request – for example, “I am requesting a copy of my personal data” or “I would like to delete my account data.” For certain requests, we may provide self-service options (for instance, you can update your profile information or download your data by logging into your account settings, if available).
• Verification: For security, we will need to verify your identity (and jurisdiction, if relevant) before processing your request. Verification may involve confirming information we already have on file (such as sending a response to your email on record or asking for details about your last interaction with us). For deletion or highly sensitive requests, we may require a higher level of verification. If you have an account with us, generally making the request through your logged-in account serves as verification. Authorized agents making requests on behalf of someone will need to provide proof of authorization and we may still verify the subject of the data.
• Response Time: We will respond to valid requests as soon as we reasonably can, and in any event within the timeframes required by law. Under GDPR, this is typically within one month, extendable by an additional two months if necessary (we’ll inform you if we need the extra time). Under CCPA, we aim to respond to verified consumer requests within 45 days, and can extend by another 45 days if needed with notice. If we need additional information from you to verify or fulfill your request, we will let you know promptly.
• No Fee Usually Required: We will not charge you a fee for exercising your rights unless the request is manifestly unfounded, repetitive, or excessive. If a fee may apply, we will inform you and explain the decision before completing the request, giving you the option to proceed or not.
• Limitations: As mentioned, your rights may be subject to certain limitations. If we cannot fulfill a part of your request, we will provide an explanation, unless we are legally prevented from doing so. For example, if you request deletion, we might retain data that we are required to keep for legal tax record purposes, but we would remove as much data as possible and isolate it from active use.
  
  

We want to reiterate that privacy and data protection are core values of our Company. Different laws outline various data privacy rights that individuals can exercise , and we have established this comprehensive process to make it straightforward for you to exercise those rights. If you have any questions or concerns about your rights or how to exercise them, you can always reach out to us via the contact details below. We are here to help and will do our best to address any issues regarding your privacy.