MONEYTIME PRIVACY POLICY

MONEYTIME PRIVACY POLICY

This MoneytimePrivacy Policy was last updated on March 18, 2019.

We, [Moneytime Inc.], located at 4225 Executive Square Suite 1000 San Diego, CA 92037 (“Moneytime”, “we” or “us”), and our corporate affiliates, are committed to protecting and respecting your privacy. We are the company responsible for the collection, use, and disclosure of your personal information under this Privacy Policy. We believe in transparency and want you to feel comfortable using our platform, and we are committed to being upfront about our privacy practices.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

  1.       Introduction
  1. Scope of this Privacy Policy 

This Privacy Policy explains the information we collect from you when you access and use our website (including https://moneytime.com/) (the “Site”), as well as our platforms, widgets, analytics tools, and other technical applications that we may provide through our Site or other products and services provided by us (which, together, are referred to as the “Services”), how we use and disclose such information. We also wish to make sure that you are aware of the options available to you when you access and use our Services.

  • b.          Contact Us 

If you have any questions about this Privacy Policy, please contact us at:

Moneytime Inc.

Email address: [email protected]

Postal address: 4225 Executive Square, Suite 1000, La Jolla, San Diego 92370

  • Third-Party Links 

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect information about you. We do not control these third-party services and are not responsible for their privacy, information, or other practices. We encourage you to read the privacy policy of every website or other online service that you visit or use.

2.         Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. If you choose to create an account on our Services, you may choose to provide Personal Information to us, such as your full name, email address, password, gender, postal address (including zip code, city and state), location, phone number, a profile picture, username.

You may choose to sign into your account using your social media sign in credentials (e.g., your [Facebook, Google or Twitter] sign-in credentials). If you choose to do this, you may share certain Personal Information from your social media account with us, such as your name, email address, profile photo, posts, comments and other information associated with your social media account.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. 

3.         Use of Personal Information

We and our service providers use Personal Information for legitimate business purposes, including to:

  • Provide the functionality of the Services and fulfill your requests.
    • To provide the Services’ functionality to you, such as arranging access to your account and providing you with related customer service.
    • To respond to your inquiries and fulfill your requests, such as when you send us questions.
    • To complete your transactions and provide you with related customer service.
    • To send administrative information to you, such as changes to our terms, conditions, and policies.
    • To allow you to send messages to another person if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • Provide you with our newsletter and/or other marketing materials and facilitate social sharing.
    • To send you marketing related emails, with information about our services, new products, and other news about our company.
    • To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

  • Analyze such information for business reporting and providing personalized services.
    • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
    • To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
    • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

  • Allow you to participate in sweepstakes, contests, or other promotions.
    • We may offer you the opportunity to participate in a sweepstakes, contest, or other promotion. Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.

We use this information to manage our contractual relationship with you.

  • Aggregate and/or anonymize Personal Information.
    • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other information for our use, which we may use and disclose for any purpose.
  • Accomplish our business purposes.
    • For data analysis, for example, to improve the efficiency of our Services;
    • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
    • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
    • For developing new products and services;
    • For enhancing, improving, or modifying our current products and services;
    • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
    • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
    • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

4.         Disclosure of Personal Information

Your Personal Information will be disclosed:

  • To our affiliates for the purposes described in this Privacy Policy. You can consult the list and location of our affiliates here [link to list of affiliates or name the affiliates and their countries here]. [MoFo: May affiliates use the information for their own direct marketing purposes?]
  • To our third-party service providers, to facilitate services they provide to us. These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
  • By you, if you choose, through your social sharing activity. If you choose to connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
  • By you, if you choose, through features that permit you to post information and content, such as message boards, chat, profile pages, and blogs. Any information or content that you post or disclose through these features will become public and may be available to other users and the general public.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations, which can include laws outside your country of residence.
  • To cooperate with public and government authorities, to respond to a request or to provide information we believe is important.These can include authorities outside your country of residence.
  • To cooperate with law enforcement, such as when we respond to law enforcement requests and orders or provide information we believe is important, including to law enforcement outside your country of residence.
  • For other legal reasons, such as to enforce our terms and conditions and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
  • In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

5.         Other Information

“Other Information” is any information that does reveal your specific identity or does not directly relate to an identifiable individual. We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

a.         Collection and Use of Other Information

you use or interact with our Services, we automatically collect (by [cookies, web beacons and similar technologies]) certain information, such as: [(a) anonymous encrypted code representing your Internet protocol (IP) address or your device identifier (if using a mobile device) and being used as a persistent identifier, anonymous login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and version, device information; as well as (b) information about a user’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), the products a visitor viewed or searched for, the frequency and scope of the respective use of the Services, page interaction information (such as scrolling, clicks, and mouse-overs), the content viewed (including advertisements clicked on) and pages visited, and cookie data.]

We use this information to ensure that the Services function properly, for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience, to understand and measure how the Services are used, to improve and resolve questions regarding the Services, to resolve questions about them, and to measure the effectiveness of our marketing campaigns. We may derive your approximate location from your IP address.

To learn about cookies, please visit http://www.allaboutcookies.org/. You may be able to delete or decline cookies by changing your browser settings. The “Help” function in the toolbar of most browsers should indicate how you can set your browser to notify you before accepting cookies or to disable cookies entirely. If, however, you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services properly.

We do not currently respond to browser do-not-track signals.

b.         Our Advertising

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services. Specifically, you may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

Information collected by third parties. The third parties that display advertisements on our site may use tracking technologies, such as cookies, web beacons and similar technologies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, our website does not provide personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers end-users a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

6.         Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Please be aware that we may transfer your information to Israel, the European Union, and other jurisdictions through certain third parties that we use to operate and manage the Site and Services, including Amazon Web Services (AWS) or Google Cloud Services

7.         Retention Period

We retain aggregated or anonymous information, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as necessary for the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8.         Information Security   

We have put in place security measures designed to prevent Personal Information from being accidentally lost or acquired, used, accessed, altered, or disclosed in an unauthorized way. Please keep in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your Personal Information may have been compromised during, or as a result of, your use of the Services), please immediately notify us in accordance with the “Contact Us” section above.

9.         Protection of Children’s Privacy

We are concerned about the privacy and safety of children when they use the internet. Our Services are not directed to children under eighteen (18).

We will never knowingly request Personal Information online from anyone under the age of 18 without prior verifiable parental consent. Our Services are general audience sites and are not targeted to or intended for use by children. However, if we learn that we have received information from a child under the age of 18 without parental consent, we will delete that information from our database.

10.       Choices and Access

If you would like to request to review, correct, update, suppress, restrict, or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us at [email protected] or 4225 Executive Square Suite 1000 San Diego, CA 92037. We will respond to your request consistent with applicable law.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

11.       Changes to Our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. Your use of the Services following these changes means that you accept the revised Privacy Policy.

12.       Additional Information Regarding the European Economic Area

You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Residents of the State of California may request a list of all third parties to which we have disclosed personal information during the preceding year for the third-parties’ direct marketing purposes. If you are a California resident and want a list, you should send a request to: info@moneytime.com or, contact us at: 4225 Executive Square, Suite 1000, La Jolla, San Diego 92037.

ATTN: CEO

You need to provide the statement “Your California Privacy Rights” in the subject field of your e-mail or on the envelope or post card and in the actual request. For all requests, please include your name, street address, city, state, and zip code. We will not accept requests via telephone or by facsimile. We are not responsible for notices that are not labelled or sent properly, or that do not have complete information.

The Moneytime Privacy Policy was last updated on March 1, 2019.

We, Moneytime Inc., a company incorporated under the laws of the State of Delaware, USA, with registered place of business at 4225 Executive Square Suite 1000 San Diego, CA 92037 (“Moneytime“, “we” or “us“), and our corporate affiliates, are committed to protecting and respecting your privacy. We believe in transparency and want you to feel comfortable using our platform, and we are committed to being upfront about our privacy practices.

  1. Important information and who we are
    1. Purpose of This Privacy Policy 

This Privacy Policy (“Policy“) explains which information we collect from you, when you (“you” or “your“, the user of our Services) access and use our website (including https://moneytime.com/) (the “Site“), as well as our platforms, widgets, analytics tools, and other technical applications that we may provide either through our Site or through third-party websites or other products and services provided by us (which, together, are referred to as the “Services“), and how we process or otherwise use such information and protect it. The Policy also wishes to make sure that you are aware of the options available to you when you access and use our Services.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

  • b.          Contact Us 

If you have any questions or concerns about Moneytime’s Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at:

Moneytime Inc.

Email address: [email protected]

Postal address: 4225 Executive Square, Suite 1000, La Jolla, San Diego 92370

Telephone number: 858-275-6570

If you are an EU resident, you have the right to make a complaint at any time to the relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach such authority, so please contact us in the first instance.

  • Third-Party Links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies and practices. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  • 2.          The Personal Data We Collect and Process.
    • a.              Personal Data Collected or Processed When You Use the Services.

When you use or interact with our Services, we automatically collect (by cookies, web beacons and similar technologies) certain information, such as: (a) anonymous encrypted code representing your Internet protocol (IP) address or your device identifier (if using a mobile device) and being used as a persistent identifier, anonymous login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and version, device information; as well as (b) information about a user’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), the products a visitor viewed or searched for, the frequency and scope of the respective use of the Services, page interaction information (such as scrolling, clicks, and mouse-overs), the content viewed (including advertisements clicked on) and pages visited, and cookie data.  

As such, the information we collect cannot be used by us to specifically identify you. Our Services do not collect any personal information, i.e. information about a natural person such as name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual. To the extent required, the legal grounds for collecting, processing and using your information is your consent, which you may withdraw.

In addition, when you engage with advertisements, links to third party websites or funded links that are displayed on the Services, Moneytime, third-party advertisers and data service providers may use industry-wide tracking methods (e.g., cookies, web beacons, etc.) which store certain information and which allow us or such third-parties to collect certain data for the purpose of serving advertisements through the use of the Moneytime Services (including without limitation, serving advertisements that may be of interest to you). Such tracking methods may store non-personal information as well as a persistent identifier. In such case, you will be subject to such third-party advertisers’ privacy policy. Please note, however, that we do not control such third-party advertisers or service providers, i.e. the third-party advertisers or service providers solely determine the purposes and means of the processing of personal data and are thus data controllers. We generally do not have any access to the information so collected.

Please note that, in addition to the methods of collection set forth above, we may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific website feature.

If you choose to create an account on our Services, you may choose to provide information, such as your full name, email address, password, gender, postal address (including zip code, city and state), location, phone number, a profile picture, username We collect and process this data for the purpose of registering you as a user. In addition to your consent, the legal grounds for collecting, processing and using your personal data is the performance of the agreement between you and us to provide you with the Services and our legitimate interests of protecting the security of our users’ accounts. 

You may choose to sign in to your account using your social media sign in credentials (e.g., your Facebook, Google or Twitter sign in credentials). If you choose to do this, the first time you do so you will be asked whether you agree that the social media provider may provide certain information to us, such as your name, email address, profile photo, posts, comments and other information associated with your social media account.

All this information is made available to us by the social media provider due to the way the social sign-in configuration works. However, the only information we retain and process is your name, email address and password. If you do not want your information to be shared with us by the social media provider, then you can simply sign in to your account using your account credentials instead of your social media account credentials.

We associate the email address provided by the social media provider with your account so that you can use your email address to sign in to your account in the future if you no longer wish to sign in using your social media account credentials. The legal ground for processing this information for this purpose is our legitimate interest in providing you an alternative sign in method and in securing your account.

  • Collaboration with Google and other Third-Party Ad Networks.

We may collaborate with Google or other third-party vendors or advertising networks as business partners. Google uses cookies to help serve the ads it displays on the websites of its partners, such as websites displaying Google ads or participating in Google certified ad networks. When users visit a Google partner’s website, a cookie may be dropped on that end user’s browser.

  • Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to our website or other websites.
  • Google’s use of advertising cookies enables it and its partners to serve ads to you based on your visit to our sites and/or other sites on the Internet.
  • You may opt out of personalized advertising by visiting Ads Settings. Alternatively, you can opt out of some third-party vendor’s use of cookies for interest-based advertising by visiting aboutads.info.

Please be advised that the cookies of other third-party vendors or ad networks may also be used to serve ads on our website, and therefore, please be informed as follows:

  • Third-party vendors and ad networks may serve ads on our site.
  • You may opt out of personalized advertising from such third-party vendors and ad networks under the following link: http://optout.aboutads.info/?c=2#!/
  • Alternatively, you can opt out of some third-party vendor’s use of cookies for interest-based advertising by visiting aboutads.info.

Information collected by third parties. The third parties that display advertisements on our site may use tracking technologies, such as cookies, web beacons and similar technologies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, our website does not provide personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers end-users a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

To learn more about cookies, please visit http://www.allaboutcookies.org/. You may delete or decline cookies by changing your browser settings. The “Help” function in the toolbar of most browsers should indicate how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services properly.

  • 3.          How we use the information we collect and store

We respect your privacy. As explained above, Moneytime does not collect any personal data or information that can identify you. We generally use the information that we collect and process to provide and improve our services and products, for targeted online and offline marketing, and for general research and aggregate reporting.

  1. We use the information that we collect in order to:
  2. deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  3. communicate back to you;
  4. provide and monetize our website; to deliver content or advertising; to perform market research or measure Website usage; and to analyse traffic counts, your interests and website performance;
  5. to perform network communications, to administer our site and to support internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure;
  6. for maintaining and analysing the function of the Services’ features and offerings, advertisements, and e-mail communications, and to improve them when necessary.
  7. Respond and handle your questions and requests. In such cases, we do not store any contact information.
    1. We specifically use the information that you choose to provide to us, to help us to:
  8. In this respect, please note that we limit access to your personal information by our personnel to those whom we believe reasonably need that information, in order to provide products or services to you or in order to do their jobs.
  9. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We value your privacy and will not share information except with the parties set out below for the purposes indicated in the following instances:

  1. With our affiliates. This relates to companies that are legally part of the same group of companies that we are part of, or that become part of that group. Currently our affiliates are based in the USA and in Israel.
    1. Third-Party Service. Professional and legal advisers acting as processors including lawyers, bankers, auditors and insurers based in the USA and Israel who provide consultancy, banking, legal, insurance and accounting services or who conduct general business analyses, and who require reporting of processing activities in certain circumstances.
    1. Providers. We may make use of third-party service providers in the course of collecting, storing or processing information we collect from and receive about you in order to (i) deliver content or advertising; (ii) perform market research or measure website usage; or (iii) analyze traffic counts, your interests and website performance. For example, we may tell our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find interesting and to customize content and advertising.
    1. Non-Personally Identifiable Information. We may also share aggregated or non-personally identifiable data, which is not considered as personal data under law. See additional information under Section 2(a) above.
    1. We may disclose information that we collect (i) as a response to a legal request (such as a court order, search warrant, or subpoena) if we believe that we are required to do so by applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud, intellectual property infringement, piracy, or other illegal activities; enforce this Policy or our Terms of Use, including in order to investigate potential breaches; protect our rights, property or safety, or those of our users or from members of the public from harm, as required or permitted by law; and prevent death or imminent bodily harm.
    1. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use the information we collect in the same way as set out in this Policy.
    1. We use commercially reasonable efforts to engage with third-party service providers that post a privacy policy governing their collection, processing and use of non-personal and personal information. Please note, however, that we do not control such third-party service providers, i.e. the third-party service providers solely determine the purposes and means of the processing of personal data and are thus data controllers.
  2. Transfers of Data

Please be aware that we may transfer your information to Israel, the European Union and other countries through certain third-parties that we use to operate and manage the Site and Services, including Amazon Web Services (AWS) or Google Cloud Services

  •  Data Retention

We retain aggregated or anonymous data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as is necessary for the purposes set out in this Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • How do We Secure Your Information?  

We consider data security a top priority and we do our best to keep your information secure. We have put in place appropriate security measures to prevent information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Such measures include:

  • Encrypting many of our services using SSL.
  • Employing firewalls and intrusion detection systems.
  • Practicing administrative, technical, and physical security procedures to help protect the information you provide us.

Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your information, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your personal data may have been compromised during, or as a result of, your use of the Services), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section above (Section 1(b)).          

  • 8.          Protection of Children’s Privacy

We are concerned about the privacy and safety of children when they use the internet. Our Services are not directed to children under eighteen (18).

We will never knowingly request personally identifiable information online from anyone under the age of 18 without prior verifiable parental consent. Our Services are general audience sites and are not targeted to or intended for use by children. However, if we learn that we have received information from a child under the age of 18 without parental consent, we will delete that information from our database.

  • Your Legal Rights

If you reside in the European Union, you have certain rights under European Data Protection Law with regard to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which, if applicable, will be notified to you at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at – [email protected].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you do not reside in the European Union but you believe that you have a right to restriction of processing or a right to object to processing under your local laws, please contact us at [email protected].

  1. Changes to Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. To the extent permitted by law, your continued use of our Services following the posting of changes to this Policy or providing notice to you, whichever occurs first, means that you accept those changes.

  1. General

If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.      

  1. Governing Law and Jurisdiction

This Policy shall be governed by the laws of the State of Delaware, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the federal and state courts located in Delaware, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.

  1. Note to International Users

We are a private company incorporated under the laws of the State Delaware, USA. If you are located elsewhere, the information you provide to us or that we collect will be transferred to the USA and governed by applicable laws and regulations and this Privacy Policy. Some of this information may be transferred to, processed and stored by our service providers in other countries.

Residents of the State of California may request a list of all third-parties to which we have disclosed personal information during the preceding year for the third-parties’ direct marketing purposes. If you are a California resident and want a list, you should send a request to: [email protected] or, contact us at: 4225 Executive Square, Suite 1000, La Jolla, San Diego 92370.

ATTN:

You need to provide the statement “Your California Privacy Rights” in the subject field of your e-mail or on the envelope or post card and in the actual request. For all requests, please include your name, street address, city, state, and zip code. We will not accept requests via telephone or by facsimile. We are not responsible for notices that are not labelled or sent properly, or that do not have complete information.

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