Privacy and Cookie Policy

At ViewBug, we believe privacy is a fundamental right. ViewBug is founded on the principle of helping photographers within our platform where users can share their photos with the community, join photo contests or challenges, create challenges, build websites and search for photos, like or comment on them.

The services can be accessed via the mobile ViewBug app (hereinafter "App")
or on www.viewbug.com (hereinafter "Website").

Information Collected by ViewBug
We only collect personal information that is relevant to the purpose of our website. This information allows us to provide you with a customized and efficient experience. We collect the following types of information from our ViewBug users:
Basically,
We collect certain information to make ViewBug better for you and to provide a great overall experience.
Information You Provide to Us
  1. We receive and store any information you enter on our website or provide to us in any other way. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our special features.

  2. Registration: In order for you to use ViewBug services you must complete a registration form. As part of this registration form, we require certain personal information.

  3. User Profile: To allow you to express yourself beyond just the information collected during registration, we enable you to provide additional information, such as your first and last names, email address, social media account names, your birthday, a bio, favorite URLs, and instant messaging IDs. In addition, you may choose to include photos of yourself in your profile. As indicated below, in the section titled "Sharing Your Information", you can control how your information is displayed and used.
Automatic Information
  1. We receive and store certain types of information whenever you interact with us. ViewBug and its authorized agents automatically receive and record certain "traffic data" on their server logs from your browser including your IP address, ViewBug cookie information, and the page you requested. ViewBug uses this traffic data to help diagnose problems with its servers, analyze trends and administer the website. This does not involve collecting any of your personal information.

  2. In addition to the "traffic data", ViewBug and its authorized agents may collect information about the device you're using to access ViewBug, its operating system, unique device identifier, device settings such as language and crash data. Which data is specifically collected depends on the type of device and/or system running on that device. This data is again used to help us diagnose problems with the site and/or mobile apps and analyze usage trends. This does not involve collecting any of your personal information.

  3. ViewBug may collect and use information regarding the geographic location of your devices. If the location data contains your personal information, then ViewBug will treat this location data in accordance with this Policy.

  4. ViewBug may collect and, on any page, display the total counts that page has been viewed. This includes User Profile pages.

  5. Many companies offer programs that help you to visit websites anonymously. While ViewBug will not be able to provide you with a personalized experience if we cannot recognize you, we want you to be aware that these programs are available.
Basically,
During your registration we collect your user profile data. Our servers might collect log information to make the website faster. We also collect geographical location data to present a better experience regardless of your location.
E-mail Communications
ViewBug is very concerned about your privacy and we will never provide your email address to a third party without your explicit permission, as detailed in the "Sharing Your Information" section below. ViewBug may send out e-mails with ViewBug-related news, products, offers, surveys or promotions. You may also receive notification e-mails from ViewBug, which inform you of actions (e.g. friend requests) that have been performed on the site. If you do not want to receive e-mail from us, please visit the Email Preferences section of your User Profile and/or follow the instructions contained in the unwanted e-mail message. However, please note that in all cases you will continue to receive all system e-mails (e.g. those regarding forgotten user passwords) and legal notices (e.g. updates to our policies) from us.
Basically,
We will send you emails based on your profile settings which you can change at any time. Occasionally, we might send emails to all our members.
Cookies
Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in our website are visited and by how many people. ViewBug cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or what your screen name or e-mail address is.

ViewBug utilizes third-party services like Google Analytics to help analyze how our site is used. These services, including Google Analytics, also use cookies to collect information about visitors to our site (including IP addresses) in an anonymous form that does not include personal information.

The "help" portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We recommend that you leave the cookies activated because cookies allow you to use some of ViewBug's coolest features. Some of our business partners, like our advertisers, may use cookies on our website. We have no access to, or control over, these cookies.
Basically,
Our system will give you a safe cookie to remember you. Third-party services that help us analyze how our site is used also use cookies to collect information about visitors to our site.
Analytics
ViewBug uses services like Google Analytics and/or Amplitude to help analyze and understand how our site and mobile applications are used, so that we can make ViewBug products more interesting to you. These tools capture data about how individual users are using our site and mobile applications. This includes event logs, device type and device configuration settings such as language, crash data and other data but never personal information. These third-party services treat the analytics data in accordance with this privacy policy and ViewBug does not disclose your personal information to any third parties through our use of these services.
Basically,
The analytics services that we use do not collect personal information, and all information collected is used in accordance with this policy. Analytics services help us better understand usage trends and help us improve your experience based on those trends.
Sharing Your Information
Because ViewBug enables people to discover and share information with one another, information about the people who use ViewBug is an integral part of the ViewBug experience. Rest assured that we will not rent or sell your personal information to anyone and that we will share your personal information only as described below:
  • ViewBug Personnel: ViewBug personnel and authorized consultants and/or contractors may have access to user information if necessary in the normal course of ViewBug business.
  • Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if ViewBug, or substantially all of its assets, were acquired, user information would be one of the assets that is transferred.
  • Protection of ViewBug and Others: We may release personal information when we believe in good faith that release is necessary to comply with a law; to enforce or apply our Terms of Use and other policies; or to protect the rights, property, or safety of ViewBug, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
  • User Profile information: Information collected during registration and subsequent visits, such as your full name and location, may be displayed to other ViewBug users in your User Profile. The User Profile is the area on ViewBug where we allow you to tell other ViewBug users about yourself. You may control what personal information is displayed in your User Profile by visiting the Settings section of your User Profile.
  • Followers' Activity: Much like other online social networks, ViewBug allows non-followers to browse your followers’ activity.
  • Syndication: ViewBug allows for the RSS syndication of all of its public content within the ViewBug website.
  • Service Providers: ViewBug may share user information as well as information from tools such as cookies, log files, device identifiers and location data, with third-parties that help ViewBug provide services to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary for ViewBug to provide our services. ViewBug requires Services Providers to protect your data in a manner consistent with this Policy and to limit the use of such information to the performance of services for ViewBug. ViewBug may also remove parts of data that can identify you and share anonymized data with Service Providers, including combining your information with other information in a way that it is no longer associated with you.
  • With Your Consent: Except as noted above, we will contact you when your personal information is shared with third parties or used for a purpose incompatible with the purpose(s) for which it was originally collected, and you will be able to opt out to prevent the sharing of this information.
Basically,
We do not sell your information to anyone. We show publicly available information to other users such as in your profile, and you can change what you wish to display in your account settings. We may share information so that we can provide our service, and we may share information where required by law. We may also share information with third-parties that help ViewBug provide services to you.
Keeping Information Secure
  • Your ViewBug account information is protected by a password for your privacy and security. Protect against unauthorized access to your password and to your computer by logging off once you have finished using a shared computer.
  • Only employees who need personal information to perform a specific job (for example, a customer service representative) are granted access to it. All of our employees are kept up to date on our privacy and security practices.
Basically,
Your account is protected by an encrypted password. We keep it secure; you must also keep it safe. Our employees may not access your account unless required to do a specific job.
Ways to Control Display and Use of Your Information
  • As stated previously, you can always opt not to disclose information, but then you may be unable to use certain features on our website.
  • By visiting your User Profile, you can correct, amend, add or delete personal information on our website.
  • If you do not wish to receive e-mail from us or other ViewBug users, please visit the Settings of your User Profile and/or follow the instructions contained in the unwanted e-mail message.
  • However, please note that you will continue to receive all system e-mails (e.g. those regarding forgotten user passwords) and legal notices (e.g. updates to our policies) from us.
  • As explained earlier, the "help" portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. Please note, however, that if your browser does not accept cookies, you will not be able to take advantage of some of our attractive features.
Basically,
You choose what you share with us and can edit it within your account settings.
Children Under 18 Years of Age
You must be 14 years and older to register to use the ViewBug website. As a result, ViewBug does not specifically collect information about children. If we learn that ViewBug has collected information from a child under the age of 13, we will delete that information as quickly as possible. We recommend that minors between the ages of 14 and 18 ask and receive their parents' permission before using ViewBug or sending information about themselves or anyone else over the Internet.
Basically,
You cannot register if you are under 18 years old. Ask for your parents' permission if you are between 14 and 18 years old. You are not allowed to register if you are under 14 years old.
Information modification or Deletion
You have the right at any time to request information about what personal data we process about you and to demand correction, deletion and/or restriction of your personal data stored by us. For your security, we will ask you to verify your details in the event of such a request or change. Please send contact us: https://help.viewbug.com
Basically,
You can contact us with any questions or requests at any time.
Changes to this Privacy Policy
ViewBug may amend this Privacy Policy from time to time, at its sole discretion. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes to the Privacy Policy, we will notify you by posting an announcement on the ViewBug website so you are always aware of what information we collect, how we use it, and under what circumstances if any, it is disclosed.
Basically,
The Privacy Policy may change.
Conditions of Use
If you decide to visit the ViewBug website or use any of our official mobile applications, your visit and any possible dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, arbitration of disputes, and application of California law.
Basically,
Visiting ViewBug or using any of our official mobile applications is subject to our Terms of Use and Privacy Policy.
California users’ Privacy Rights
Californian users of ViewBug have additional rights afforded to them under the California Consumer Privacy Act (CCPA).

Categories of personal information collected by ViewBug

For more details about the personal information ViewBug has collected in the past year, please see section “Information you provide to us”. For details on how we use that information, and who we share it with, please see section “Sharing your information”.

ViewBug does not “sell” (as defined in the CCPA) the personal information of ViewBug users.

Making a request in relation to your personal information

The CCPA gives California consumers various rights with respect to the personal information we collect, including the right to (subject to certain limitations):
  • Request to access the personal information ViewBug has about you; and
  • Request that ViewBug delete all of your personal information.

California users may make a request by contacting us at members@viewbug.com. We will authenticate your request using the email address associated with your ViewBug account and if necessary, proof of residency.

Privacy Policy of ViewBug
This Application collects some Personal Data from its Users.

Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.

This document contains a section dedicated to Californian consumers and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller
ViewBug
1104 camino del mar
Suite 107
Del Mar CA 92014 US

Owner contact email: copyrightinfo@viewbug.com

Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Tracker; Usage Data; device information.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law.
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject.
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
  • In any case, the Owner 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.

Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.


Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.


Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Infrastructure monitoring, Advertising, Remarketing and behavioral targeting and Access to third-party accounts.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me
Provides access to the 'About Me' section of the profile.

Contact email
Access the User's contact email address.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

  • Access to third-party accounts
  • Advertising
  • Analytics
  • Infrastructure monitoring
  • Remarketing and behavioral targeting
  • The rights of Users
  • Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Applicability of broader protection standards
While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by an Owner based within the EU.
  • Concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users.
  • Concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

Cookie Policy
This Application uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold
In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers and internet information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them
The right to know and to portability
You have the right to request that we disclose to you:

  • The categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared.
  • In case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • For sales, the personal information categories purchased by each category of recipient; and
  • For disclosures for a business purpose, the personal information categories obtained by each category of recipient.
  • The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Basically,
The CCPA creates new consumer rights for Californian users as of 1 January 2020.
Effective Date of this Privacy Policy
This Privacy Policy is effective as of May 24, 2018.