Privacy Policy – Thrive Bioscience – Automated imaging, analytics, and documentation of live cells and tissues

==============

Last updated: October 1, 2020

This Privacy Policy describes Our policies and procedures on the collection,

use and disclosure of Your information when You use the Service and tells You

about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the

Service, You agree to the collection and use of information in accordance with

this Privacy Policy.

Interpretation and Definitions

==============================

Interpretation

————–

The words in which the initial letter is capitalized have meanings defined

under the following conditions.

The following definitions shall have the same meaning regardless of whether

they appear in singular or in plural.

Definitions

———–

For the purposes of this Privacy Policy:

* You means the individual accessing or using the Service, or the company,

or other legal entity on behalf of which such individual is accessing or

using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to

as the Data Subject or as the User as you are the individual using the

Service.

* Company (referred to as either “the Company”, “We”, “Us” or “Our” in this

Agreement) refers to Thrive Bioscience, Inc. 100 Cummings Center Beverly, Massachusetts 01915.

For the purpose of the GDPR, the Company is the Data Controller.

* Affiliate means an entity that controls, is controlled by or is under

common control with a party, where “control” means ownership of 50% or

more of the shares, equity interest or other securities entitled to vote

for election of directors or other managing authority.

* Account means a unique account created for You to access our Service or

parts of our Service.

* Website refers to Thrive Bioscience Inc, accessible from

https://www.thrivebio.com

* Service refers to the Website.

* Country refers to: Massachusetts, United States

* Service Provider means any natural or legal person who processes the data

on behalf of the Company. It refers to third-party companies or

individuals employed by the Company to facilitate the Service, to provide

the Service on behalf of the Company, to perform services related to the

Service or to assist the Company in analyzing how the Service is used.

For the purpose of the GDPR, Service Providers are considered Data

Processors.

* Third-party Social Media Service refers to any website or any social

network website through which a User can log in or create an account to

use the Service.

* Personal Data is any information that relates to an identified or

identifiable individual.

For the purposes for GDPR, Personal Data means any information relating

to You such as a name, an identification number, location data, online

identifier or to one or more factors specific to the physical,

physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA (California Consumer Privacy Act),

Personal Data means any information that

identifies, relates to, describes or is capable of being associated with,

or could reasonably be linked, directly or indirectly, with You.

* Cookies are small files that are placed on Your computer, mobile device or

any other device by a website, containing the details of Your browsing

history on that website among its many uses.

* Device means any device that can access the Service such as a computer, a

cellphone or a digital tablet.

* Usage Data refers to data collected automatically, either generated by the

use of the Service or from the Service infrastructure itself (for example,

the duration of a page visit).

* Data Controller, for the purposes of the GDPR (General Data Protection

Regulation), refers to the Company as the legal person which alone or

jointly with others determines the purposes and means of the processing of

Personal Data.

* Do Not Track (DNT) is a concept that has been promoted by US regulatory

authorities, in particular the U.S. Federal Trade Commission (FTC), for

the Internet industry to develop and implement a mechanism for allowing

internet users to control the tracking of their online activities across

websites.

* Business, for the purpose of the CCPA (California Consumer Privacy Act),

refers to the Company as the legal entity that collects Consumers’

personal information and determines the purposes and means of the

processing of Consumers’ personal information, or on behalf of which such

information is collected and that alone, or jointly with others,

determines the purposes and means of the processing of consumers’ personal

information, that does business in the State of California.

* Consumer, for the purpose of the CCPA (California Consumer Privacy Act),

means a natural person who is a California resident. A resident, as

defined in the law, includes (1) every individual who is in the USA for

other than a temporary or transitory purpose, and (2) every individual who

is domiciled in the USA who is outside the USA for a temporary or

transitory purpose.

* Sale, for the purpose of the CCPA (California Consumer Privacy Act),

means selling, renting, releasing, disclosing, disseminating, making

available, transferring, or otherwise communicating orally, in writing, or

by electronic or other means, a Consumer’s Personal information to another

business or a third party for monetary or other valuable consideration.

Collecting and Using Your Personal Data

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Types of Data Collected

———————–

Personal Data

~~~~~~~~~~~~~

While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:

* Email address

* First name and last name

* Phone number

* Address, State, Province, ZIP/Postal code, City

* Usage Data

Usage Data

~~~~~~~~~~

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol

address (e.g. IP address), browser type, browser version, the pages of our

Service that You visit, the time and date of Your visit, the time spent on

those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect

certain information automatically, including, but not limited to, the type of

mobile device You use, Your mobile device unique ID, the IP address of Your

mobile device, Your mobile operating system, the type of mobile Internet

browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

The Company allows You to create an account and log in to use the Service

through the following Third-party Social Media Services:

* Google

* Facebook

* Twitter

If You decide to register through or otherwise grant us access to a Third-

Party Social Media Service, We may collect Personal data that is already

associated with Your Third-Party Social Media Service’s account, such as Your

name, Your email address, Your activities or Your contact list associated with

that account.

You may also have the option of sharing additional information with the

Company through Your Third-Party Social Media Service’s account. If You choose

to provide such information and Personal Data, during registration or

otherwise, You are giving the Company permission to use, share, and store it

in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We use Cookies and similar tracking technologies to track the activity on Our

Service and store certain information. Tracking technologies used are beacons,

tags, and scripts to collect and track information and to improve and analyze

Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a

Cookie is being sent. However, if You do not accept Cookies, You may not be

able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on

your personal computer or mobile device when You go offline, while Session

Cookies are deleted as soon as You close your web browser. Learn more about

cookies here: [Cookies: What Do They

Do?](https://en.wikipedia.org/wiki/HTTP_cookie)

We use both session and persistent Cookies for the purposes set out below:

* Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services

available through the Website and to enable You to use some of its

features. They help to authenticate users and prevent fraudulent use of

user accounts. Without these Cookies, the services that You have asked for

cannot be provided, and We only use these Cookies to provide You with

those services.

* Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies

on the Website.

* Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use

the Website, such as remembering your login details or language

preference. The purpose of these Cookies is to provide You with a more

personal experience and to avoid You having to re-enter your preferences

every time You use the Website.

* Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the

Website and how users use the Website. The information gathered via these

Cookies may directly or indirectly identify you as an individual visitor.

This is because the information collected is typically linked to a

pseudonymous identifier associated with the device you use to access the

Website. We may also use these Cookies to test new pages, features or new

functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding

cookies, please visit our Cookies Policy.

Use of Your Personal Data

————————-

The Company may use Personal Data for the following purposes:

* To provide and maintain our Service, including to monitor the usage of

our Service.

* To manage Your Account: to manage Your registration as a user of the

Service. The Personal Data You provide can give You access to different

functionalities of the Service that are available to You as a registered

user.

* For the performance of a contract: the development, compliance and

undertaking of the purchase contract for the products, items or services

You have purchased or of any other contract with Us through the Service.

* To contact You: To contact You by email, telephone calls, SMS, or other

equivalent forms of electronic communication, such as a mobile

application’s push notifications regarding updates or informative

communications related to the functionalities, products or contracted

services, including the security updates, when necessary or reasonable for

their implementation.

* To provide You with news, special offers and general information about

other goods, services and events which we offer that are similar to those

that you have already purchased or enquired about unless You have opted

not to receive such information.

* To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

* With Service Providers: We may share Your personal information with

Service Providers to monitor and analyze the use of our Service, to

advertise on third party websites to You after You visited our Service,

for payment processing, to contact You.

* For Business transfers: We may share or transfer Your personal information

in connection with, or during negotiations of, any merger, sale of Company

assets, financing, or acquisition of all or a portion of our business to

another company.

* With Affiliates: We may share Your information with Our affiliates, in

which case we will require those affiliates to honor this Privacy Policy.

Affiliates include Our parent company and any other subsidiaries, joint

venture partners or other companies that We control or that are under

common control with Us.

* With Business partners: We may share Your information with Our business

partners to offer You certain products, services or promotions.

* With other users: when You share personal information or otherwise

interact in the public areas with other users, such information may be

viewed by all users and may be publicly distributed outside. If You

interact with other users or register through a Third-Party Social Media

Service, Your contacts on the Third-Party Social Media Service may see

Your name, profile, pictures and description of Your activity. Similarly,

other users will be able to view descriptions of Your activity,

communicate with You and view Your profile.

Retention of Your Personal Data

——————————-

The Company will retain Your Personal Data only for as long as is necessary

for the purposes set out in this Privacy Policy. We will retain and use Your

Personal Data to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your data to comply with applicable

laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage

Data is generally retained for a shorter period of time, except when this data

is used to strengthen the security or to improve the functionality of Our

Service, or We are legally obligated to retain this data for longer time

periods.

Transfer of Your Personal Data

——————————

Your information, including Personal Data, is processed at the Company’s

operating offices and in any other places where the parties involved in the

processing are located. It means that this information may be transferred to —

and maintained on — computers located outside of Your state, province, country

or other governmental jurisdiction where the data protection laws may differ

than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such

information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data

is treated securely and in accordance with this Privacy Policy and no transfer

of Your Personal Data will take place to an organization or a country unless

there are adequate controls in place including the security of Your data and

other personal information.

Disclosure of Your Personal Data

——————————–

Business Transactions

~~~~~~~~~~~~~~~~~~~~~

If the Company is involved in a merger, acquisition or asset sale, Your

Personal Data may be transferred. We will provide notice before Your Personal

Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

~~~~~~~~~~~~~~~

Under certain circumstances, the Company may be required to disclose Your

Personal Data if required to do so by law or in response to valid requests by

public authorities (e.g. a court or a government agency).

Other legal requirements

~~~~~~~~~~~~~~~~~~~~~~~~

The Company may disclose Your Personal Data in the good faith belief that such

action is necessary to:

* Comply with a legal obligation

* Protect and defend the rights or property of the Company

* Prevent or investigate possible wrongdoing in connection with the Service

* Protect the personal safety of Users of the Service or the public

* Protect against legal liability

Security of Your Personal Data

——————————

The security of Your Personal Data is important to Us, but remember that no

method of transmission over the Internet, or method of electronic storage is

100% secure. While We strive to use commercially acceptable means to protect

Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

============================================================

Service Providers have access to Your Personal Data only to perform their

tasks on Our behalf and are obligated not to disclose or use it for any other

purpose.

Analytics

———

We may use third-party Service providers to monitor and analyze the use of our

Service.

* Google Analytics

Google Analytics is a web analytics service offered by Google that tracks

and reports website traffic. Google uses the data collected to track and

monitor the use of our Service. This data is shared with other Google

services. Google may use the collected data to contextualize and

personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to

Google Analytics by installing the Google Analytics opt-out browser add-

on. The add-on prevents the Google Analytics JavaScript (ga.js,

analytics.js and dc.js) from sharing information with Google Analytics

about visits activity.

For more information on the privacy practices of Google, please visit the

Google Privacy & Terms web page:

<https://policies.google.com/privacy?hl=en>

Email Marketing

—————

We may use Your Personal Data to contact You with newsletters, marketing or

promotional materials and other information that may be of interest to You.

You may opt-out of receiving any, or all, of these communications from Us by

following the unsubscribe link or instructions provided in any email We send

or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

* Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket

Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit

their Privacy policy: <https://mailchimp.com/legal/privacy/>

* Constant Contact

Constant Contact is an email marketing sending service provided by

Constant Contact, Inc.

For more information on the privacy practices of Constant Contact, please

visit their Privacy policy: <https://www.constantcontact.com/forward

/privacy-center>

Behavioral Remarketing

———————-

The Company uses remarketing services to advertise on third party websites to

You after You visited our Service. We and Our third-party vendors use cookies

to inform, optimize and serve ads based on Your past visits to our Service.

* Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize

the Google Display Network ads by visiting the Google Ads Settings page:

<http://www.google.com/settings/ads>

Google also recommends installing the Google Analytics Opt-out Browser

Add-on – <https://tools.google.com/dlpage/gaoptout> \- for your web

browser. Google Analytics Opt-out Browser Add-on provides visitors with

the ability to prevent their data from being collected and used by Google

Analytics.

For more information on the privacy practices of Google, please visit the

Google Privacy & Terms web page:

<https://policies.google.com/privacy?hl=en>

* Bing Ads Remarketing

Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads interest-based ads by following their

instructions: <https://advertise.bingads.microsoft.com/en-

us/resources/policies/personalized-ads>

You can learn more about the privacy practices and policies of Microsoft

by visiting their Privacy Policy page: <https://privacy.microsoft.com/en-

us/PrivacyStatement>

* Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter’s interest-based ads by following their

instructions: <https://support.twitter.com/articles/20170405>

You can learn more about the privacy practices and policies of Twitter by

visiting their Privacy Policy page: <https://twitter.com/privacy>

* Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by

visiting this page: <https://www.facebook.com/help/164968693837950>

To opt-out from Facebook’s interest-based ads, follow these instructions

from Facebook: <https://www.facebook.com/help/568137493302217>

Facebook adheres to the Self-Regulatory Principles for Online Behavioural

Advertising established by the Digital Advertising Alliance. You can also

opt-out from Facebook and other participating companies through the

Digital Advertising Alliance in the USA

<http://www.aboutads.info/choices/>, the Digital Advertising Alliance of

Canada in Canada <http://youradchoices.ca/> or the European Interactive

Digital Advertising Alliance in Europe <http://www.youronlinechoices.eu/>,

or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit

Facebook’s Data Policy: <https://www.facebook.com/privacy/explanation>

* Pinterest

Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest’s interest-based ads by enabling the “Do

Not Track” functionality of your web browser or by following Pinterest

instructions: <http://help.pinterest.com/en/articles/personalization-and-

data>

You can learn more about the privacy practices and policies of Pinterest

by visiting their Privacy Policy page: <https://about.pinterest.com/en

/privacy-policy>

* AdRoll

AdRoll remarketing service is provided by Semantic Sugar, Inc.

You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising

Preferences web page:

[http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false](http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false)

For more information on the privacy practices of AdRoll, please visit the

AdRoll Privacy Policy web page: <http://www.adroll.com/about/privacy>

* Perfect Audience

Perfect Audience remarketing service is provided by NowSpots Inc.

You can opt-out of Perfect Audience remarketing by visiting these pages:

Platform Opt-out (<http://pixel.prfct.co/coo>) and Partner Opt-out

(<http://ib.adnxs.com/optout>).

For more information on the privacy practices of Perfect Audience, please

visit the Perfect Audience Privacy Policy & Opt-out web page:

<https://www.perfectaudience.com/privacy/index.html>

* AppNexus

AppNexus remarketing service is provided by AppNexus Inc.

You can opt-out of AppNexus remarketing by visiting the Privacy & the

AppNexus Platform web page: <https://www.appnexus.com/platform-privacy-

policy#choices>

For more information on the privacy practices of AppNexus, please visit

the AppNexus Platform Privacy Policy web page: <https://www.appnexus.com

/platform-privacy-policy>

Payments

——–

We may provide paid products and/or services within the Service. In that case,

we may use third-party services for payment processing (e.g. payment

processors).

We will not store or collect Your payment card details. That information is

provided directly to Our third-party payment processors whose use of Your

personal information is governed by their Privacy Policy. These payment

processors adhere to the standards set by PCI-DSS as managed by the PCI

Security Standards Council, which is a joint effort of brands like Visa,

Mastercard, American Express and Discover. PCI-DSS requirements help ensure

the secure handling of payment information.

* PayPal

Their Privacy Policy can be viewed at

<https://www.paypal.com/webapps/mpp/ua/privacy-full>

GDPR Privacy

============

Legal Basis for Processing Personal Data under GDPR

—————————————————

We may process Personal Data under the following conditions:

* Consent: You have given Your consent for processing Personal Data for one

or more specific purposes.

* Performance of a contract: Provision of Personal Data is necessary for the

performance of an agreement with You and/or for any pre-contractual

obligations thereof.

* Legal obligations: Processing Personal Data is necessary for compliance

with a legal obligation to which the Company is subject.

* Vital interests: Processing Personal Data is necessary in order to protect

Your vital interests or of another natural person.

* Public interests: Processing Personal Data is related to a task that is

carried out in the public interest or in the exercise of official

authority vested in the Company.

* Legitimate interests: Processing Personal Data is necessary for the

purposes of the legitimate interests pursued by the Company.

In any case, the Company 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.

Your Rights under the GDPR

————————–

The Company undertakes to respect the confidentiality of Your Personal Data

and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the

EU, to:

* Request access to Your Personal Data. The right to access, update or

delete the information We have on You. Whenever made possible, you can

access, update or request deletion of Your Personal Data directly within

Your account settings section. If you are unable to perform these actions

yourself, please contact Us to assist You. This also enables You to

receive a copy of the Personal Data We hold about You.

* Request correction of the Personal Data that We hold about You. You have

the right to to have any incomplete or inaccurate information We hold

about You corrected.

* Object to processing of Your Personal Data. This right exists where We are

relying on a legitimate interest as the legal basis for Our processing and

there is something about Your particular situation, which makes You want

to object to our processing of Your Personal Data on this ground. You also

have the right to object where We are processing Your Personal Data for

direct marketing purposes.

* Request erasure of Your Personal Data. You have the right to ask Us to

delete or remove Personal Data when there is no good reason for Us to

continue processing it.

* Request the transfer of Your Personal Data. We will provide to You, or to

a third-party You have chosen, Your Personal Data in a structured,

commonly used, machine-readable format. Please note that this right only

applies to automated information which You initially provided consent for

Us to use or where We used the information to perform a contract with You.

* Withdraw Your consent. You have the right to withdraw Your consent on

using your Personal Data. If You withdraw Your consent, We may not be able

to provide You with access to certain specific functionalities of the

Service.

Exercising of Your GDPR Data Protection Rights

———————————————-

You may exercise Your rights of access, rectification, cancellation and

opposition by contacting Us. Please note that we may ask You to verify Your

identity before responding to such requests. If You make a request, We will

try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our

collection and use of Your Personal Data. For more information, if You are in

the European Economic Area (EEA), please contact Your local data protection

authority in the EEA.

CCPA Privacy

============

Your Rights under the CCPA (California Consumer Privacy Act)

————————–

Under this Privacy Policy, and by law if You are a resident of California, You

have the following rights:

* The right to notice. You must be properly notified which categories of

Personal Data are being collected and the purposes for which the Personal

Data is being used.

* The right to access / the right to request. The CCPA permits You to

request and obtain from the Company information regarding the disclosure

of Your Personal Data that has been collected in the past 12 months by the

Company or its subsidiaries to a third-party for the third party’s direct

marketing purposes.

* The right to say no to the sale of Personal Data. You also have the right

to ask the Company not to sell Your Personal Data to third parties. You

can submit such a request by visiting our “Do Not Sell My Personal

Information” section or web page.

* The right to know about Your Personal Data. You have the right to request

and obtain from the Company information regarding the disclosure of the

following:

* The categories of Personal Data collected

* The sources from which the Personal Data was collected

* The business or commercial purpose for collecting or selling the

Personal Data

* Categories of third parties with whom We share Personal Data

* The specific pieces of Personal Data we collected about You

* The right to delete Personal Data. You also have the right to request the

deletion of Your Personal Data that have been collected in the past 12

months.

* The right not to be discriminated against. You have the right not to be

discriminated against for exercising any of Your Consumer’s rights,

including by:

* Denying goods or services to You

* Charging different prices or rates for goods or services, including the

use of discounts or other benefits or imposing penalties

* Providing a different level or quality of goods or services to You

* Suggesting that You will receive a different price or rate for goods or

services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

——————————————-

In order to exercise any of Your rights under the CCPA, and if you are a

California resident, You can email or call us or visit our “Do Not Sell My

Personal Information” section or web page.

The Company will disclose and deliver the required information free of charge

within 45 days of receiving Your verifiable request. The time period to

provide the required information may be extended once by an additional 45 days

when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

———————————–

We do not sell personal information. However, the Service Providers we partner

with (for example, our advertising partners) may use technology on the Service

that “sells” personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-

based advertising purposes and these potential sales as defined under CCPA

law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need

to opt out on every browser that you use.

Website

~~~~~~~

You can opt out of receiving ads that are personalized as served by our

Service Providers by following our instructions presented on the Service:

* From Our “Cookie Consent” notice banner

* Or from Our “CCPA Opt-out” notice banner

* Or from Our “Do Not Sell My Personal Information” notice banner

* Or from Our “Do Not Sell My Personal Information” link

The opt out will place a cookie on Your computer that is unique to the browser

You use to opt out. If you change browsers or delete the cookies saved by your

browser, you will need to opt out again.

Mobile Devices

~~~~~~~~~~~~~~

Your mobile device may give you the ability to opt out of the use of

information about the apps you use in order to serve you ads that are targeted

to your interests:

* “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on

Android devices

* “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile

device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act

(CalOPPA)

=======================================================================================

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities.

If You are visiting such websites, You can set Your preferences in Your web

browser to inform websites that You do not want to be tracked. You can enable

or disable DNT by visiting the preferences or settings page of Your web

browser.

Children’s Privacy

==================

Our Service does not address anyone under the age of 13. We do not knowingly

collect personally identifiable information from anyone under the age of 13.

If You are a parent or guardian and You are aware that Your child has provided

Us with Personal Data, please contact Us. If We become aware that We have

collected Personal Data from anyone under the age of 13 without verification

of parental consent, We take steps to remove that information from Our

servers.

If We need to rely on consent as a legal basis for processing Your information

and Your country requires consent from a parent, We may require Your parent’s

consent before We collect and use that information.

Your California Privacy Rights (California’s Shine the Light law)

=================================================================

Under California Civil Code Section 1798 (California’s Shine the Light law),

California residents with an established business relationship with us can

request information once a year about sharing their Personal Data with third

parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light

law, and if you are a California resident, You can contact Us using the

contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions

Code Section 22581)

==================================================================================================

California Business and Professions Code section 22581 allow California

residents under the age of 18 who are registered users of online sites,

services or applications to request and obtain removal of content or

information they have publicly posted.

To request removal of such data, and if you are a California resident, You can

address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive

removal of content or information posted online and that the law may not

permit or require removal in certain circumstances.

Links to Other Websites

=======================

Our Service may contain links to other websites that are not operated by Us.

If You click on a third party link, You will be directed to that third party’s

site. We strongly advise You to review the Privacy Policy of every site You

visit.

We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.

Changes to this Privacy Policy

==============================

We may update our Privacy Policy from time to time. We will notify You of any

changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior

to the change becoming effective and update the “Last updated” date at the top

of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this

page.

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If you have any questions about this Privacy Policy, You can contact us:

* By email: sales@computerally.com