Owner and Data Controller

healthcareppcsolutions.com
1530 E Williams Field Rd.
Gilbert, AZ 85295

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address; Tracker; Usage Data; Data communicated while using the service; first name; last name; gender; date of birth; phone number; physical address; company name; profession; username; password; various types of Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; purchase history; geographic position; VAT Number; country; city; workplace; screenshots; profile picture; ZIP/Postal code; payment info; billing address; shipping address; fax number; state; county; Tax ID; field of activity; User ID; number of employees; website; marital status; Full access; Read only access; Read metadata; Modify; Insert and import; Compose; Basic settings management; Sensitive settings management; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Data communicated in order to use the Service; language; picture.

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 Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 Website or by the owners of third-party services used by this Website 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 Website 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 Website (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 of 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: User database management, Interaction with live chat platforms, Managing contacts and sending messages, Interaction with data collection platforms and other third parties, Advertising, Remarketing and behavioral targeting, Handling activities related to productivity, Commercial affiliation, Traffic optimization and distribution, Handling payments, Contacting the User, Access to third-party accounts, Analytics, Registration and authentication, Content commenting, Managing data collection and online surveys, Interaction with external social networks and platforms, Displaying content from external platforms, Managing support and contact requests, Location-based interactions, Tag Management, SPAM protection, Managing landing and invitation pages, Hosting and backend infrastructure, Infrastructure monitoring, Connecting Data and Interaction with support and feedback platforms.

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 Website

This Website 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 Website 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.

Access Friend Lists

Provides access to any friend lists the User created.

Access Page CTA

Provides the access to manage call to actions on User-managed Pages.

Access private data

Access the User’s and friends’ private data.

Access Requests

Provides read access to the User’s friend requests.

Activities

Provides access to the User’s list of activities.

Age range

Provides access to the User’s age range.

App Notifications

Send notifications.

Birthday

Provides access to the birthday.

Books Actions

Shows when the User has rated, read, quoted from or has said they want to read a book with the app.

Business Management API

Read and write with Business Management API.

Chat

Provides applications that integrate with Facebook Chat the ability to log in Users.

Checkins

Provides read access to the authorized User’s check-ins.

Contact email

Access the User’s contact email address.

Create Events

Enables the application to create and modify events on the User’s behalf.

Create notes

Add or modify notes.

Current City

Provides access to the User’s current location.

Custom Friend Lists Access

Provides access to the names of custom lists the User has created to organize their friends.

Custom User Actions

Allows the app retrieve the actions published by another application as specified by the app namespace.

Deals

Read the deal activity.

device information

Education History

Provides access to education history.

Email

Provides access to the User’s primary email address.

Events

Provides access to the list of events the User is attending.

Export Posts

Export the posts and make them public. All posts will be exported, including status updates.

Family Members and Relationship Status

Provides access to the User’s family and personal relationships and relationship status.

Fitness Actions

Shows the User’s workout with the app.

Friend subscriptions

Provides access to the User’s friends subscriptions associated with the app.

Friends’ About Me

Provides access to the ‘About Me’ section of the friends’ profile.

Friends’ Activities

Provides access to the friends’ list of activities.

Friends’ birthdays

Provides access to the friends’ birthdays.

Friends’ Checkins

Provides read access to the friends’ check-ins that the User can see.

Friends’ Current Cities

Provides access to the friends’ current locations.

Friends’ Custom User Actions

Allows the app to retrieve the actions published by another application as specified by the app namespace.

Friends’ Education History

Provides access to friends’ education history.

Friends’ Events

Provides access to the list of events the friends are attending.

Friends’ Family Members and Relationship Status

Provides access to a friend’s family and personal relationships and relationship status.

Friends’ Games and App Activity

Allows the app post and retrieve game achievement activity.

Friends’ Groups

Provides access to the list of groups the User’s friends are a members of.

Friends’ Hometown

Provides access to the friends’ hometown.

Friends’ Interests

Provides access to the friends’ lists of interests.

Friends’ Likes

Provides access to the list of all of the pages the friends have liked.

Friends’ music.listens Actions

Allows the app to retrieve the actions published by all applications using the built-in music.listens action.

Friends’ news.read Actions

Allows the app to retrieve the actions published by all applications using the built-in news.reads action.

Friends’ Notes

Provides access to the friends’ notes.

Friends’ Online Presence

Provides access to the User’s friend’s online/offline presence.

Friends’ Photos

Provides access to the photos the friends have uploaded, and photos the friends have been tagged in.

Friends’ Questions

Provides access to the questions the friends have asked.

Friends’ Religious and Political Views

Provides access to the friends’ religious and political affiliations.

Friends’ Significant Others and Relationship Details

Provides access to the friends’ relationship preferences.

Friends’ Statuses

Provides access to the friends’ status messages and checkins.

Friends’ video.watches Actions

Allows the app to retrieve the actions published by all applications using the built-in video.watches action.

Friends’ Videos

Provides access to the videos the friends have uploaded and have been tagged in.

Friends’ Websites

Provides access to the friends’ web site URLs.

Friends’ Work History

Provides access to a friend’s work history.

Games and App Activity

Allows the app post and retrieve game achievement activity.

Gender

Provides access to the User’s gender.

Groups

Provides access to the list of groups the User is a member of.

Groups member info

Provides access to publicly available group member information.

Hometown

Provides access to the User’s hometown.

Insights

Provides read access to the Insights data for pages, applications, and domains the user owns.

Instagram basic

Allows reading an Instagram account profile information and media.

Instagram manage comments

Allows the creation, deletion and hiding of comments on behalf of the Instagram account linked to a Page. Also allows reading and responding to public media and comments that a business has been photo tagged in or @mentioned in.

Instagram manage insights

Provides access to insights for the Instagram account linked to a Facebook Page. Also gives the possibility to discover and read the profile information and media of other business profiles.

Interests

Provides access to the User’s list of interests.

Leads Retrieval

Allows retrieving and reading all information captured by a lead advertisement form with an advertisement created in Ads Manager or the Marketing API.

Likes

Provides access to the list of all of the pages the User has liked.

Link

Provides access to the Facebook Profile URL of the User.

List of Friends

Provides access to the User’s list of friends that also use said app.

Manage Advertisements

Provides the ability to manage ads and call the Facebook Ads API on behalf of a User.

Manage Catalog

Allows creating, reading, updating and deleting business-owned product catalogs for which the User is an administrator.

Manage Friend Lists

Enables the app to create, delete and edit the User’s friend lists.

Manage Groups

Manage the User’s groups.

Manage Mailbox

Read and send messages from the User’s mailbox.

Manage Notifications

Enables the app to read notifications and mark them as read.

Manage Pages

Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.

Managing Page Advertisements

Allows managing advertisements associated with the Page.

Mobile Messaging on behalf of Page

Send and receive mobile messages on behalf of a Facebook Page.

music.listen Action

Allows the app to retrieve the actions published by all applications using the built-in music.listens action.

News Feed and Wall

Provides access to all the posts in the User’s News Feed and enables the application to perform searches against the User’s News Feed.

news.read Actions

Allows the app to retrieve the actions published by all applications using the built-in news.reads action.

Notes

Provides access to the User’s notes.

Offline Access

Access the data when the User is not using the application.

Online Presence

Provides access to the User’s online/offline presence.

Page Messaging

Send and receive messages through a Facebook Page.

Pages manage CTA

Allows carrying out POST and DELETE functions on endpoints used to manage call-to-action buttons on a Facebook Page.

Pages manage engagement

Allows creating, editing and deleting comments posted on the page.

Pages manage instant articles

Allows managing Instant Articles on behalf of Facebook Pages administered by the User.

Pages manage metadata

Allows subscribing and receiving webhooks about activity on the Page, and updating settings on the Page.

Pages manage posts

Allows the creation, editing and deletion of the User’s Page posts.

Pages read engagement

Provides access to content (posts, photos, videos, events) posted by the Page, access to followers data (including name, PSID), and profile picture, and access to metadata and other insights about the Page.

Pages read User content

Allows reading User generated content on the Page, such as posts, comments, and ratings by Users or other Pages, and deleting User comments on Page posts.

Pages User locale

Provides access to the User’s locale through the connected Page.

Pages User timezone

Grants access to a User’s time zone through the connected Page.

Photos

Provides access to the photos the User has uploaded, and photos the User has been tagged in.

Post Likes to my Wall

Publish stories about things the User Likes to the Wall.

Publish App Activity

Allows the app to publish to the Open Graph using Built-in Actions, Achievements, Scores, or Custom Actions. The app can also publish other activity which is detailed in the Facebook’s Publishing Permissions document.

Publish as Page

Enables the ability to post, comment and like as any of the Pages managed by the User.

Publish Checkins

Enables the app to perform checkins on behalf of the User.

Publish content into groups

Allows posting content into a group on behalf of the User.

Publish to the Wall

Enables the app to post content, comments, and likes to a User’s stream and to the streams of the User’s friends.

Publish videos

Allows publishing live videos on the User’s timeline.

Questions

Provides access to the questions the User has asked.

Read advertisements

Allows to pull advertisement report information for advertisements accounts owned or granted access to by the owner or owners of other advertisement accounts, through this permission. Also provides access to the Server-Side API to allow advertisers to send web events from their servers directly to Facebook.

Read attribution

Grants access to the Attribution API to pull attribution report data for lines of business owned or granted access to by the owner or owners of other lines of business.

Read Group Content

Lets the app read content in a group managed by the User.

Read insights

Allows reading the Insights data for Pages, apps and web domains the User owns.

Read Mailbox

Provides the ability to read from a user’s Facebook Inbox.

Read page mailbox

Lets the app read from the page inboxes of the pages managed by the User.

Religious and Political Views

Provides access to the User’s religious and political affiliations.

RSVP to Events

Enables the application to RSVP to events on the User’s behalf.

Share

Share items on the User’s behalf.

Show List of Managed Pages

Provides the access to show the list of the Pages that the User manages.

Significant Other and Relationship Details

Provides access to the User’s relationship preferences.

Status

Provides access to the User’s status messages and checkins.

Status Updates

Update the User’s status.

Tagged Places

Provides access to the places the User has been tagged at in photos, videos, statuses and links.

Text Messaging

Send SMS messages to the User’s phone.

Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Upload Photos

Add or modify user’s photos.

Usage Data

User location

Allows reading the city name as listed in the location field of a User’s Facebook profile.

User subscriptions

Provides access to the User’s subscriptions associated with the app.

User Timeline Posts Access

Provides access to the posts on a Users’s timeline.

User videos

Allows reading a list of videos uploaded by a User.

Video upload

Add or modify User’s videos.

video.watches Action

Allows the app to retrieve the actions published by all applications using the built-in video.watches action.

Videos

Provides access to the videos the User has uploaded and videos the User has been tagged in.

Website

Provides access to the User’s web site URL.

Whatsapp business management

Allows reading and/or managing WhatsApp business assets owned or granted access to by other businesses through this permission. These business assets include WhatsApp business accounts, phone numbers and message templates.

Work History

Provides access to work history.

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

• Commercial affiliation

• Connecting Data

• Contacting the User

• Content commenting

• Displaying content from external platforms

• Handling activities related to productivity

• Handling payments

• Hosting and backend infrastructure

• Infrastructure monitoring

• Interaction with data collection platforms and other third parties

• Interaction with external social networks and platforms

• Interaction with live chat platforms

• Interaction with support and feedback platforms

• Location-based interactions

• Managing contacts and sending messages

• Managing data collection and online surveys

• Managing landing and invitation pages

• Managing support and contact requests

• Registration and authentication

• Remarketing and behavioral targeting

• SPAM protection

• Tag Management

• Traffic optimization and distribution

• User database management

Further information about Personal Data

• Selling goods and services online

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.

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 Website 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 Website 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 Website and any third-party services may collect files that record interaction with this Website (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 Website 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 Website 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 Website 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, california Consumer Records Statute information, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information, FERPA information and inferred 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 Website.

For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, 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 Website 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 Website, 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 Website 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 Website, 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.