Privacy Policy

Introduction

This Privacy Policy (“Policy”) describes how the personal information you may provide in the Blinq software applications (“Software Applications”) and any of its related products and services (collectively, the “Services”) is collected, held, disclosed and used. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information or contact us with questions about our privacy practices. 

Blinq Technologies Pty Ltd (“Blinq Technologies Pty Ltd”, “we”, “us” or “our”, “Blinq”) is the operator of the Services. By accessing and using the Services, you acknowledge that you have read and understood this Policy. 

We handle personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles, and international privacy laws and regulations where applicable, including the EU and UK General Data Protection Regulation (“GDPR”), and various state privacy laws in the US. If you are a resident of the US or the UK/European Economic Area, please see below for more information about your rights under privacy laws in these jurisdictions. 

This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Our Privacy Principles

At the core of Blinq's Services is the ability for you to share your information with people you choose. As a result, data privacy is critical to the Services we offer. At Blinq, we believe in the importance of being able to control who gets that information.

To reflect this importance, we've designed our Services with several principles in mind that are intended to protect your data and privacy:

Your data is yours

We do not sell your personal information to third parties. It's just not what we do here at Blinq. Your data is yours to share with your network. We may share personal information as set out under ‘disclosure of information’ below.

Secure Storage

Blinq uses industry-standard security measures, including encryption and access controls, to protect your personal information.

Safe Sharing

Every Blinq card has a unique code and web address. Those you share your Blinq card with will be able to look at your card details. If they share your Blinq card with others or their company, others or their company may be able to view your details.

Control and Transparency

Blinq aims to be transparent about how your personal information is used and give you tools to manage your data and privacy preferences.

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Collection of personal information

Automatic collection of information

Our top priority is customer data security. When you use the Services, certain personal information may be collected automatically by our systems, such as device and app information (e.g., device type, operating system and app version), network information (e.g., IP address), and usage, diagnostic and performance data (e.g., feature usage events and error logs). Personal information collected automatically is used for example to: 

• help maintain the security and operation of the Services; 
• identify potential cases of abuse; 
• monitor system performance; and 
• establish statistical information regarding the usage of the Services.
  

Direct collection of personal information

You may access certain parts of the Services without directly identifying yourself. If, however, you wish to use some of the features in the Services, you may be asked to provide certain personal information (for example, your name and email address). 

We receive and store any information you provide to us when you use (including create an account, make a purchase, or fill any online forms in) the Services. This information may include the following:

• personal details such as name and country of residence;
• contact information such as email address, phone number and address;
• account details such as user name, unique user ID and password;
• payment information such as credit card details and bank details (which may be handled by third-party providers);
• geolocation data such as latitude and longitude; 
• information collected through features on your mobile device (such as contacts, camera, microphone or similar features) where you choose to enable those permissions in connection with specific functionality of the Services; and
• audio, including voice recordings where this functionality of the Services is used.

In relation to staff and job applicants, information we collect may include:

• experience, qualifications, skills and character;
• screening checks (e.g., reference, background, health, directorship, identity, eligibility to work, vocational suitability and criminal record checks);
• drug and alcohol checks;
• conduct and performance at work;
• use of workplace resources and IT;
• payroll and superannuation details;
• emergency contacts.

In some cases, we need to collect personal information pursuant to applicable laws including the Income Tax Assessment Act and other tax laws, Corporations Act, Fair Work Act, Superannuation Guarantee (Administration) Act, occupational health and safety acts and workers compensation acts.

You can choose not to provide us with certain personal information, but doing so may limit your ability to access or use some of the features in the Services. Users who are uncertain about what information is required are welcome to contact us using the contact details below.

Third party collection of data

Some of the personal information we collect directly from you via the Services (see section “Direct collection of personal information” above). 

However, we may also collect personal information about you from other sources where permitted by law, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Personal information we collect from other sources may include: 

• demographic information, such as age and gender; 
• device information, such as IP addresses; 
• location, such as city and state; 
• employment information such as job title, role and company; 
• contact information such as email address and phone number; and 
• information relating to online activity, such as information about your use of social media websites, page view information and search results and links.

We collect this personal information to help operate and improve the Services, support marketing and business development activities, and maintain the accuracy of personal information we hold about our users.

Recordings

We may also collect any personal information that you or your contacts choose to provide while you are recording conversations using the Services, and may share that personal information with third party service providers (such as providers of AI transcription tools and cloud hosting and storage providers used to securely upload, process, and store recordings and related output data.) 

Many laws require the consent of all parties to a conversation before that conversation (including any personal information or personal data) may be recorded and before a recording of that conversation may be shared with third-parties, which includes with us or with our third-party service providers (such as providers of AI transcription tools and cloud hosting and storage providers). Before using our Services to record a conversation, you must obtain consent or permission from each party to the conversation to it being recorded and to the sharing of such recording with us and our third party service providers (such as providers of AI transcription tools and cloud hosting and storage providers who may be located in the United States or elsewhere) in accordance with this Policy and our Terms and Conditions. 

We may store recordings of conversations made using our Services for the term of Membership plus 30 days, unless required by law.

Information we collect about non-users

We may collect and process personal information about individuals who are not Blinq users, such as when our users create or enrich profiles of their business contacts or when they record conversations with third-parties who are not Blinq users. This information may include names, professional contact details, profile photos, and publicly available professional information, or any other personal information included in a recorded conversation.

Users should only provide personal information about other individuals where they are authorised to do so or where it is reasonable to expect that the information would be shared in a professional context. 

Cookies

Our websites may also use cookies. A cookie is a small file of letters and numbers that may be placed on your device when you visit our website(s). These cookies recognise when your device has visited our website(s) before, so we can distinguish you from other users of the website. 

We use cookies to improve your experience on our website(s), including by enabling website functionality, remembering preferences and helping us understand how visitors use our website(s). If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.

Website analytics

Our website uses Google Analytics, Segment, Amplitude, Hightough and Datadog to help us better understand visitor traffic, so we can improve our services.  These tools may collect technical information such as IP address, device information, pages visited and interactions with our website. This information is typically analysed in aggregated or de-identified form, although in some circumstances it may be possible to associate certain technical information with an individual user. 

Use and processing of collected information

In order to make the Services available to you, or to meet a legal obligation, we need to collect and use certain personal information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. We collect, use and hold personal information for many purposes in connection with our functions and activities including the following purposes:

• deliver and improve products or services, including to record conversations and create AI transcriptions and summaries of those conversations, and create and manage user accounts;
• send administrative information;
• respond to inquiries, complaints and requests and offer support;
• request user feedback;
• investigate fraud;
• protect your safety or the safety of others, including from abuse and malicious users;
• operate our business, including for internal administrative purposes; 
• comply with our legal obligations, or exercise or protect our legal rights; and
• participate in legal and regulatory processes (including investigations and disputes) or prevent misuse of the Services.

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Where required under applicable data protection laws, the processing of your personal information depends on how you interact with the Services, where you are located in the world, and whether processing is necessary to:

• process information with your consent where required by law;
• perform a contract with you or take steps prior to entering into a contract; 
• comply with a legal obligation; and
• pursue legitimate business interests (provided these are not overridden by your rights and interests).

We may obtain additional information about individuals from third-party data providers, public databases, and other lawful sources to enrich and improve the accuracy of contact profiles on Blinq. This may involve providing limited information we already hold (such as a name or email address) to these providers and receiving updated or supplementary information in return.

We process this information to support our legitimate business interests, including enabling users to manage professional contacts, improve data accuracy, prevent fraud, and enhance the functionality of our services.

We do not use data enrichment to obtain sensitive personal information, nor do we use enriched data for advertising, credit eligibility, or profiling unrelated to professional contact management.

Billing and payments

We use third party payment processors to assist us in processing payments securely. When you make a payment through the Services, certain payment and transaction information may be provided directly to these processors in order to complete the transaction. Such third party processors' use of your personal information is governed by their respective privacy policies. We suggest that you review their respective privacy policies to understand how your information is handled by those providers.

Managing information

You are able to delete certain personal information we hold about you in the Services. The personal information you can delete may change as the Services evolve. When you delete personal information, however, we may maintain a copy of the unrevised personal information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your personal information or permanently delete your account, you can do so by contacting us.

Choices and rights for non-users

Individuals whose information appears on Blinq but who are not Blinq users may request access to, correction of, or deletion of their personal information by contacting us at [email protected]. 

If you are located in the European Economic Area or the United Kingdom, you may have additional rights under applicable data protection laws, including the GDPR. If you are a US resident of the states of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Montana, Minnesota, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have additional rights under the privacy laws of those states.  Please see the section titled “Privacy Rights for Residents of Certain States” below for more information. We will handle your privacy rights requests in accordance with those laws.

Disclosure of information

We may share your personal information with third parties for the purposes set out under ‘use and processing of collected information’ above, including: 

• our third party service providers that work with us (such as providers of technology services, data processing, legal, accounting and other professional services); and 
• our affiliates and subsidiaries; and
• government agencies, courts and tribunals, where we are required or permitted by law. 

These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We require these providers to handle personal information in accordance with applicable privacy obligations.

Information you provide in connection with text messaging opt-in will not be shared with any third parties, excluding aggregators and providers of the text messaging services.

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, personal information associated with user accounts may be transferred as part of that transaction. 

Retention of information

We may hold your personal information in electronic or other forms. In some cases, we may use a third party service provider, such as hosting or cloud infrastructure providers, to store your information. In any event, we take reasonable steps to ensure that personal information we hold about you is kept confidential and secure. 

We will retain and use your personal information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and operate our services, unless a longer retention period is required or permitted by law. We may use any aggregated and anonymized data derived from your personal information after you update or delete it. Once the retention period expires, personal information shall be deleted. 

Information security

We secure information you provide on systems and infrastructure in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in its control and custody. While we take reasonable steps to protect personal information, however, no method of data transmission over the Internet or wireless network is completely secure. Therefore, while we strive to protect your personal information, you acknowledge that:

• there are security and privacy limitations of the Internet which are beyond our control;
• the security, integrity, and privacy of any and all information and data exchanged between you and the Services cannot be guaranteed; and 
• any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

Overseas transfer of information

Depending on your location, the personal information we collect about you may be transferred to, stored in or processed in countries other than your own. Some of the third parties we disclose personal information to may be located outside Australia or may store or process information using servers located overseas, including but not limited to the United States, Canada, Germany, Ireland, Belgium and Finland.

Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that appropriate safeguards are in place to protect personal information and that recipients handle personal information in accordance with applicable privacy obligations.

Overseas recipients may be located in a number of jurisdictions where our service providers operate data infrastructure. These jurisdictions may not have privacy laws that are equivalent to those in Australia.

Where required under applicable data protection laws, you may request information about the safeguards we use when transferring personal information outside your jurisdiction by contacting us using the details provided in this Policy.

Limited Use requirements

Blinq's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Advertisements

We may display online advertisements on our website and within our services. In connection with these advertisements, we may share aggregated and anonymized, non-identifying information about our customers that we or our advertisers collect through your use of the Services. We do not share personal information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.

Email marketing

We may offer electronic newsletters or other marketing communications to which you may voluntarily subscribe at any time. If you subscribe to receive marketing communications from us, we will use your email address to send you information about our services, updates, or other relevant content. Your email address may be shared with service providers who assist us in delivering these communications, but it will not be shared with advertisers or unrelated third parties for their own marketing purposes.

In compliance with the applicable data protection laws, all emails sent from us will clearly state who the email is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

Notice to end users 

If you use one of our Services with an account provided by an organisation you are affiliated with, such as your employer, we may collect, use and disclose personal information about you to provide services to you or your organisation, in accordance with your organisation’s instructions. Please note your organisation will generally be able to access and handle your data. You should refer to your organisation’s privacy policy for more information about how they collect and handle your personal information, and how you may exercise your privacy rights in relation to that information.

Data breach

In the event we become aware that the security of the Services has been compromised or users’ personal information has been accessed, disclosed or otherwise affected to unauthorised third parties that may constitute a data breach, we will investigate the incident and take reasonably appropriate measures to mitigate its impact.

Where required by applicable data protection or breach notification laws, we will notify relevant regulatory authorities and affected individuals. Where required by applicable data protection or breach notification laws, we will notify relevant regulatory authorities and affected individuals. In the event of a data breach, we will make reasonable efforts to notify affected individuals where it is required or considered appropriate. When we do, we will post a notice in the Services, send you an email or notify you by other reasonable means available to us.

Privacy of children

The Services are intended for professional use and are not directed to individuals under the age of 18. We do not knowingly collect any personal information from children under the age of 18. If you are under the age of 18, please do not submit any personal information through the Services.

We encourage parents and legal guardians to monitor their children's online activity and to help enforce this Policy by instructing their children never to provide personal information through the Services. 

If you have reason to believe that a child under the age of 18 has provided personal information to us through the Services, please contact us. In jurisdictions where applicable law permits individuals under the age of 18 to use online services with the consent of a parent or legal guardian, such consent may be required before personal information can be processed.

Links to other resources

The Services contain links to third-party websites or services that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Services and to read the privacy statements of each and every resource that may collect personal information.

The rights of users

You may exercise certain rights regarding your personal information processed by us by contacting us (see ‘contacting us’ below). Depending on your location and applicable data protection laws, you may have the right to do the following:

• withdraw consent where you have previously given your consent to the processing of your information;
• object to the processing of your information in certain circumstances;
• learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; 
• verify the accuracy of your information and ask for it to be updated or corrected; 
• request that the processing of your personal information be restricted in certain circumstances; 
• to obtain the erasure of your personal information from us; 
• you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.

The right to object to processing

Where personal information is processed for legitimate business purposes, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your personal information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. If you would like to exercise this right or learn more about how your personal information may be used for marketing purposes, you may refer to the relevant sections of this Policy or contact us using the details provided below.

Enquiries and complaints

If you have a question or concern about how we handle, process or manage your personal information, please contact us (see ‘contacting us’ below). Note we may require proof of your identity and further details of your request, and may need to engage or consult with other parties in order to investigate and deal with your complaint.

We will keep records of your request and any resolution.

Please allow up to 14 days for us to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. 

If you are in Australia and are not satisfied with our response to a complaint, you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au/) to lodge a complaint. 

Changes and amendments

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational needs. If we make material changes to the way we handle personal information, we will take reasonable steps to notify you, which may include sending an email or providing notice through the Services or other contact information you have provided.

Any updated version of this Privacy Policy will be effective when it is posted, unless otherwise specified. Your continued use of the Services after the updated Privacy Policy becomes effective indicates your acknowledgement of the revised Policy.

However, we will not, without your consent, use your personal information in a manner materially different from what was stated at the time your personal information was collected.

Acceptance of this policy

By accessing or using the Services, you acknowledge that you have read this Policy and agree to all its terms and conditions. If you do not agree to abide by the terms of this Policy, you should not access or use the Services.

Contacting us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your personal information, you may do so via the contact form or send an email to [email protected].

If you are located in the European Economic Area/UK and have questions about how we process your personal data or wish to exercise your rights under GDPR, you may contact our Data Protection Officer: [email protected].

Data protection rights under GDPR and UK GDPR

Blinq Technologies Pty Ltd is committed to compliance with the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act 2018 (UK) (collectively in this Policy referred to as the “GDPR”)  when handling personal data of individuals located in the European Union and the UK. 

Legal basis for processing 

Under the GDPR, we process personal data based on one or more of the following lawful bases:

• the consent of the data subject, where consent is required for particular processing activities; 
• processing necessary for the performance of a contract with the data subject or to take steps at the request of the data subject prior to entering into a contract (for example, when creating and managing your account or providing our services); 
• compliance with a legal obligation to which we are subject; 
• legitimate interests pursued by the controller or a third party, such as improving our services, preventing fraud, maintaining security and managing professional contact information. 

Data transfers

Personal data may be transferred to and processed in countries outside the European Economic Area (“EEA”) and the UK where our service providers operate. When we transfer personal data outside the EEA or the UK, we ensure adequate safeguards are in place to protect the privacy and security of personal data, which may include the use of Standard Contractual Clauses or other legally recognised transfer mechanisms required in accordance with applicable data protection laws, including the GDPR. 

Data subject rights

If you are a resident of the EEA or the UK, you may have the following data protection rights under the GDPR::

• You have the right to access personal data we hold about you; 
• You have the right to request correction of inaccurate or incomplete personal data;
• You have the right to request deletion of personal data in certain circumstances;
• You have the right to object or restrict the processing of your personal data;
• You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• You also have the right to withdraw your consent at any time where Blinq Technologies Pty Ltd relied on your consent to process your personal data; 

You have the right to lodge a complaint with your local supervisory authority if you believe your data protection rights have been violated.

US Privacy Rights for Residents of Certain States 

If you are a resident of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Montana, Minnesota, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have certain rights regarding the use of your personal information. This section describes those rights and how you can exercise them. Not all state privacy laws provide equal privacy rights.  While we endeavor to respond to all privacy rights requests, we reserve the right to limit our response if we determine that your request is fraudulent or made in bad faith, or if the law otherwise does not require it.

The Right To Notice that personal information will be Collected and Used

You have the right to know certain information about our collection and use of personal information over the past 12 months. The categories of such personal information are listed below along with the sources of that information, the purposes for which we collect it, the types of third parties to whom we have disclosed it, and the purposes for that disclosure.

For all of the categories listed below: (i) we do not use this personal information to create profiles on individuals that produce legal or similarly significant effects; (ii) we do not sell this personal information for monetary consideration; and (ii) we retain this personal information only for the time period necessary to achieve the purposes outlined in this Privacy Policy, taking into account our business needs (such as resolving disputes, conducting audits, and enforcing legal rights), the sensitivity of the personal information and risks involved in keeping it, and the retention requirements under applicable law.  The length of retention may vary depending upon factors such as recordkeeping or legal compliance requirements, the need to resolve inquiries or complaints, and the existence of an ongoing relationship with you. Please see the “Retention of information” section of this Policy for additional information.

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Although it is not our normal practice to collect or use the following information, when users decide to record conversations and/or use AI tools to transcribe and summarise those recordings, it is possible that these conversations may include (and our services may collect) other categories of personal information, including sensitive personal information, that may be included in those recordings, such as: inferences drawn from other personal information (such as a profile reflecting a person’s preferences or trends); protected classification characteristics under California or federal law (such as approximate age, inferred ethnicity, inferred marital status, or inferred medical condition); a person’s status as transgender or nonbinary; health or medical information; religious or philosophical beliefs; genetic data; neural data; union membership; status as a victim of a crime; biometric information for identification purposes; your account login combined with a password (aside from allowing our Clients access to our Platform); the contents of your mail, email and text messages where we are not the intended recipient; your financial account, debit card or credit card number combined with any required security or access code, password, or credentials allowing access to an account; or the personal information of children.  If this information happens to be included in a recorded conversation, we may share it with third-party service providers (such as providers of AI transcription tools and cloud hosting and storage providers) to generate and store audio, transcriptions and summaries of the recording.

We encourage users not to include sensitive personal information in any recordings. We require users to obtain consent from all parties to record conversations or share those recordings with AI transcription tools.  And we prohibit any recordings containing the personal information of children.  Please see our Terms and Conditions for contractual terms binding our users to these requirements.

Your State Privacy Rights

Depending on your state of residence, you may have the right to:

• Request to know more about the personal information that we collect, use, and disclose.  Once we receive your request, we may disclose:
  
  • The categories of personal information we’ve collected about you
  • The categories of sources for personal information we’ve collected about you
  • Our business or commercial purpose for collecting and/or sharing or selling that personal information
  • The categories of personal information that we’ve shared with or sold to third parties
  • The categories of third parties with whom we’ve shared, or to whom we’ve sold, that personal information (residents of Delaware, Maryland, Minnesota, and Oregon have the right to request a list of such third parties)
  • The specific pieces of personal information we’ve collected about you
• Request to access your personal information, including in a portable format
• Request deletion of your personal information
• Request correction of inaccurate personal information
• Opt-out of the sale or sharing of personal information for targeted or cross-context behavioral advertising, or limit the use of Sensitive personal information
• Not be discriminated against for exercising these rights

Exercising Your State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Montana, Minnesota, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia and would like to make a request pursuant to any of the rights described in this section, you may do so by following the instructions on the form found here. Alternatively, you may make the same requests by emailing us at [email protected]. You may also use the same webform or contact information to authorize an agent to submit requests on your behalf. We may require written and signed authorization from you before an agent may act on your behalf.

Process for verifying a request to know or delete information

To protect your personal information, we are required to verify that any person making a request to know or delete is in fact you or your authorized agent. We will verify any consumer’s request to exercise the right to know or the right to request deletion by comparing the identifying information you provide with the personal information we have in our systems.  

If you are requesting to know the categories of personal information collected, we may require you to provide two data points that match two of the data points we maintain.  However, if you request to know specific pieces of information, a higher bar for verification is required, which may require us to match three data points of information provided by you with three data points that we maintain.

When you make a request to delete your personal information, the level of reasonable certainty required during our verification process will vary depending on the nature of the personal information you wish to have deleted. Specifically, for sensitive personal information, we may necessitate that three data points provided by you align with three data points already stored in our records. For all other types of personal information subject to a deletion request, we will gather the necessary data points in accordance with a reasonable degree of certainty standard. We will act in good faith when determining what standard to apply when verifying all consumer requests.

We do not require verification of requests to opt-out of the sale or sharing of personal information or limit the use of sensitive personal information.

You may designate an authorized agent to act on your behalf to make a privacy request. If you use an authorized agent for requests to know or delete, we may require that you provide your authorized agent with written permission to exercise your privacy rights.  

Once we receive your request, we will respond within 10 business days and inform you if we need any more information in order to verify your request. We will provide the information you requested within 45 days of your request. If we require more than 45 days to respond to your request, we will inform you of the reasons why. For requests from California consumers to opt out of the sale or sharing of their personal information for the purposes of cross-context behavioral advertising, or requests to limit the use of sensitive personal information, we will respond within 15 days. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded.

Your right to appeal

Residents of Colorado, Connecticut, Minnesota, Montana, Oregon, Texas, and Virginia have the right to appeal our decisions in response to the exercise of your privacy rights requests. To initiate an internal appeal, please contact us at the addresses or phone number listed above or by filling out the form found here. We will respond to your request for an internal appeal within 45 days, but we may take up to 60 additional days for good cause. If you are unhappy with the results of your appeal, you may contact your state attorney general.

If you have questions about the categories of information we may collect about you or the sources of such information, please see the section of this Policy called, “Collection of personal information”. For more details about our processing activities, please see the section called, “Use and processing of collected information”, and for more information about how we may disclose information to third parties, please see the section called, “Disclosure of information”.

Sensitive personal information

We may collect certain sensitive personal information as defined under the California Consumer Privacy Act (“CCPA”). We do not use or disclose sensitive personal information for purposes other than permitted under applicable law, such as providing our services, maintaining account security, and preventing fraud.

Because we use sensitive personal information only for these permitted purposes, we do not use or disclose sensitive personal information in a manner that would require offering a “limit the use of my sensitive personal information” option under California law.

Universal Opt-Out Mechanisms 

Universal Opt-Out Mechanisms (“UOOMs”) are browser signals that indicate a visitor’s intent to opt-out of some uses of their personal information on websites they visit. If our website recognizes that your browser is expressing a UOOM, we will treat it as a request to opt-out of the sharing of your personal information. Our website does not respond to “Do Not Track” signals. In some cases, we will not be able to link the UOOM of your browser to other personal information that we may have collected from you by other means. To express your intent to opt-out of our processing personal information collected from you outside of our website, please see the section titled “Exercising Your State Privacy Rights” below. For more information on UOOMs and how to use a browser or browser extension incorporating these signals, see https://globalprivacycontrol.org/.