Privacy policy
Privacy Policy
Last Updated: [20260901]
This Privacy Policy (“Privacy Policy”) explains how DINO INNOVATION LIMITED (“we”, “our” or “us”), collects, uses, stores, discloses and otherwise processes Personal Data (as defined below) in connection with your access to and use of our Product, our Website [www.gigglepal.com] , our Platform，and Applications (collectively refer to as the “Services”).
Our Product is designed for use by children under the supervision of a parent or legal guardian. We understand that children may use the Product to access learning content, interact with certain features, including AI-enabled features, and generate learning and usage information through their use of the Product. The Platform is designed to enable parents and legal guardians to link and manage the Product, create and manage Child Profiles, manage device usage and settings, and exercise available parental controls.
Accordingly, we may process Personal Data relating to both parents or legal guardians and children in connection with the Services. We take additional measures to protect children’s Personal Data and seek to limit its collection and use to what is reasonably necessary to provide and support the relevant Services. For more information about how we protect children’s Personal Data and the rights and controls available to parents and legal guardians, please see Section 10.
This Privacy Policy applies to users with specific sections dedicated to residents of the United States and the European Economic Area (EEA)/United Kingdom. Supplemental terms applicable to residents of certain jurisdictions are set out in Section 16 below. By using our Services, you acknowledge that you have read and understood this Privacy Policy.
Context
1. Collection of Personal Data
3. AI Processing and Automated Systems
5. Disclosure of Personal Data
6. International Transfer of Personal Data
8. Protection of Personal Data
9. Cookies and Similar Online Technologies
12. Third Party Websites and Applications
16. Supplemental Terms – Jurisdiction-Specific
1. Collection of Personal Data
For the purpose of this Privacy Policy, "Personal Data" generally means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
Depending on how you interact with our Services, the following data may be collected by or on behalf of DINO INNOVATION LIMITED and may constitute Personal Data under applicable laws.
1.1. Personal Data you create or provide to us
We may collect certain information you choose to create or provide to us when you visit or use the Services, including:
1.2. Personal Data Collected or Created During Use of Our Services
| Category | Examples and Explanation | Purpose |
| Learning and usage data | Learning content accessed, learning duration, learning progress, achievements or scores (if applicable), interaction records, feature usage and other information generated through your child’s use of the Product. | Provide learning features, display learning and usage information to parents where applicable, maintain the functionality of the Services. |
| Current location data | The Product’s current location when you activate the device-location feature through the Platform. We do not retain historical location information through this feature, and the relevant location information is deleted after the location function is closed. | Display the current location of the Product to you when you request this feature. |
| Technical and Device Data | IP address, device identifier, device model, hardware and firmware version, network information, device status and other technical information automatically collected when the Device or Services are used. | Operate and maintain the Product and Services, maintain connectivity, deliver updates and provide technical support. |
| Log and Diagnostic Data | Device operation logs, error or crash logs, system diagnostics, security events, event timestamps and other technical records automatically generated during operation of the Services. | Maintain the security and reliability of the Services, diagnose and troubleshoot technical issues, and prevent misuse. |
1.3. Personal Data from third-party sources
1.3.1. We may receive Personal Data about you from third parties, including vendors and service providers who assist us in providing our Services such as e-commerce platform providers and payment processors. This may include the Website, or the Platform activity data collected through cookies and similar tracking technologies, transaction information from retail or distribution partners, advertising interaction data, and account details where you choose to use social login services.
1.3.2. Any Personal Data we receive from third parties will be handled in accordance with this Privacy Policy and we will only use it for the purposes described below or as otherwise permitted or required by applicable law.
1.3.3. The data we receive from these third-party services may depend on the relevant provider, your privacy settings, and the permissions you grant them. You should always review and, if necessary, adjust your privacy settings with the relevant third-party websites and services before linking or connecting them to our Services.
1.3.4. You may interact with a link to or from a third party or a social media feature. If you follow a link to any of these websites, note that your interactions with these companies are governed by their privacy policy, not ours. We recommend that you review the policies and terms of use of any third party before you submit any information to those websites.
1.4. Sensitive information
1.4.1. For the purpose of this Privacy Policy, "Sensitive Information" is a subset of Personal Data and includes categories such as health information.
1.4.2. We only process Sensitive Information where reasonably necessary to provide the relevant Services or for other purposes permitted by applicable law. Where applicable law requires consent or parental authorization for the processing of Sensitive Information, we will obtain such consent or authorization as required.
2. Personal Data Processing
2.1. We may use your Personal Data for the following purposes:
2.1.1. Provide the Services: To sell and deliver our products, process payments, manage orders, arrange shipping, facilitate returns or exchanges, and otherwise perform our contract with you. This includes creating and managing Parent Accounts and Child Profiles, activating and binding Products, providing learning and device features, applying parental settings and controls, processing AI interactions, providing the device-location feature when requested, and otherwise operating the Services.
2.1.2. Device Operation and Service Management: To operate and maintain the Product and Platform, manage device connectivity and settings, deliver software, firmware and security updates, and maintain the availability and functionality of the Services.
2.1.3. Improvement: To analyze the performance and use of the Services, diagnose and fix technical issues, and develop and improve our products, features and Services, where permitted by applicable law.
2.1.4. Customer Support: To respond to enquiries, provide troubleshooting and product support, manage warranty claims, arrange repairs or replacements, and communicate with you about your requests.
2.1.5. Security, fraud prevention and legal compliance: To protect our Services, systems, and users, detect and prevent fraud or misuse, enforce our terms and policies, and comply with applicable laws and regulatory requirements. We may also use Personal Data where necessary to establish, exercise or defend legal claims and protect the rights, safety and security of our users, our business and others..
3. AI Processing and Automated Systems
3.1. AI Interaction Data. Certain features of the Product allow a child to submit text, voice, images or other content and receive AI-generated responses. When an AI-enabled feature is used, the relevant input and associated context may be transmitted to and processed by Open AI in the United States solely for the purpose of generating the requested response, applying service-safety controls and providing necessary technical support.
3.2. Access, Retention and Model Training. Dino does not use a child’s AI Interaction Data for targeted advertising or to train Dino’s own general-purpose AI models. The AI service provider’s access, retention and use of such data are governed by our written agreement and the technical settings applicable to the relevant service.
3.3. Automated Decisions. We do not use AI Interaction Data to make solely automated decisions that produce legal or similarly significant effects on a child.
3.4. Limitations. AI-generated outputs may be inaccurate, incomplete or inappropriate. AI outputs are provided for general learning and interactive purposes only and are not a substitute for professional medical, legal, financial, emergency or safety advice. Parents and legal guardians should supervise age-appropriate use of the AI-enabled features.
4. Legal Bases for Processing
Where applicable under relevant data protection laws, we rely on one or more of the following legal bases for processing Personal Data:
4.1. Performance of a contract or steps before entering into a contract: If you order products or Services from us or contact us about them, we use Personal Data to provide, manage and support those products or Services, including account management, customer support and payment processing.
4.2. Legitimate interests: Where applicable, we may process Personal Data where necessary for our legitimate interests, including maintaining and improving the Services, diagnosing and fixing technical problems, protecting the security and integrity of our systems, enforcing our terms, resolving disputes, preventing fraud or unlawful activity, and protecting our rights and the rights of others, provided that those interests are not overridden by you or your child’s rights and freedoms.Where the relevant Personal Data relates to a child, we take particular account of the child’s interests, rights and freedoms.
4.3. Consent: Where required by applicable law, we may ask for separate consent or parental authorization, as applicable, for specific optional processing activities. You may withdraw consent at any time with effect for the future.
4.4. Compliance with legal obligations: We may process or retain Personal Data where necessary to comply with legal, tax, accounting or regulatory requirements, or to respond to lawful requests from authorities.
5. Disclosure of Personal Data
5.1. We may disclose your Personal Data to the following categories of recipients, as applicable and where necessary to operate our business, provide our products and services, and comply with applicable laws.
5.1.1. Our affiliates: We may share Personal Data with our related bodies corporate (if any) and other entities within our corporate group (“Affiliates”) for business operations, customer support, internal reporting, research and development, and to provide and improve our products and services.
5.1.2. Service providers and vendors: We may disclose Personal Data to third-party service providers who perform services on our behalf, such as:
(1) Website hosting, cloud infrastructureand IT service providers;
(2) Payment service providers;
(3) Order fulfillment, logistics and delivery providers;
(4) Customer support and technical support providers;
(5) Analytics, crash-reporting, application stability monitoring and diagnostic service providers;
(6) AI service providers that process AI Interaction Input to provide AI-enabled features; and
These service providers are authorized to use your Personal Data only as necessary to provide services to us and are required to protect your information in accordance with applicable confidentiality and security obligations.
5.1.3. E-commerce, crowdfunding and transaction partners: Where you purchase our products through our Website, Kickstarter or another authorized online sales channel, relevant Personal Data may be disclosed to or processed by e-commerce, crowdfunding, payment, fulfillment, logistics or delivery partners as necessary to process and fulfil your order, payment, delivery, return or refund.
5.1.4. Business transfers: We may disclose or transfer Personal Data in connection with a corporate transaction, such as a merger, sale of assets, restructuring, financing, or acquisition of all or part of our business.
5.1.5. Legal and regulatory authorities: We may disclose Personal Data where we reasonably believe such disclosure is necessary to comply with applicable laws, regulations, court orders or legal processes, to respond to lawful requests from government or regulatory authorities, to enforce our terms and policies, to detect, prevent or investigate fraud, security incidents or other unlawful activity, or to protect the rights, property or safety of us, our customers, or others.
5.2. Where applicable under U.S. privacy laws, we do not currently sell or share Personal Data for cross-context behavioral advertising or targeted advertising. If this changes, we will update this Privacy Policy and provide the opt-out mechanisms required by applicable law, including a “Do Not Sell or Share My Personal Information” link and, where required, recognition of applicable opt-out preference signals..
6. International Transfer and U.S. Storage
6.1. U.S. Storage. We store and process Personal Data on servers located in the United States. This means that Personal Data collected from users in the EEA is transferred to the United States, where data-protection laws may differ from those in the user’s country.
6.2. Transfer Safeguards. Where the GDPR applies, we rely on the EU-U.S. Data Privacy Framework only for a U.S. recipient whose active certification covers the relevant Personal Data. Where the recipient is not covered by an applicable certification, we use the European Commission’s Standard Contractual Clauses and, where required, supplementary technical and organisational measures following a transfer risk assessment.
6.3. U.S. Recipients. Our U.S. recipients, their processing purposes and the applicable transfer safeguards are identified in our cloud service provider.
6.4. Further Information. You may contact us to request further information about the safeguard applicable to a transfer or a copy of the relevant safeguard, subject to appropriate redactions.
6.5. United Kingdom. If Personal Data subject to the UK GDPR is transferred to the United States, we will use an applicable UK adequacy regulation, the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses, as appropriate.
7. Data Retention
7.1. We take reasonable steps to ensure Personal Data is stored securely.
7.2. We retain your Personal Data only for as long as necessary to fulfill the purposes in this Privacy Policy, including providing the Services, complying with legal and tax obligations, resolving disputes, and enforcing our agreements.
7.3. In determining how long to retain Personal Data, we consider factors such as:
7.3.1. Whether we have an ongoing relationship with you (for example, if you have an account or have recently purchased products or contacted us);
7.3.2. Whether the information is needed to provide services or manage our business operations;
7.3.3. Whether we are required to retain the information to comply with legal, tax, accounting or regulatory obligations; and
7.3.4. Any applicable limitation periods under law.
7.4. When Personal Data is no longer required, we will take reasonable steps to permanently delete or destroy the relevant Personal Data; or anonymize or de-identify the relevant Personal Data.
8. Protection of Personal Data
8.1. We implement reasonable technical and organisational measures designed to protect Personal Data from misuse, interference and loss, and from unauthorised access, modification or disclosure. Measures may include encryption in transit, access controls, logging and monitoring, staff training and vendor security requirements.
8.2. These measures may include, where appropriate:
8.2.1. Using encryption and other security technologies to protect data during transmission and storage;
8.2.2. Implementing access control mechanisms to restrict access to Personal Data to authorized personnel only;
8.2.3. Applying internal policies and procedures governing the handling of Personal Data; and
8.2.4. Regularly reviewing and improving our security practices.
8.3. While we take reasonable steps to protect your Personal Data, no method of transmission over the internet or electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of your Personal Data.
8.4. You are responsible for keeping your account credentials confidential and secure. We recommend that you use a strong and unique password, do not share your account details with others, limit access to your devices and browsers, and log out after use, especially on shared or public devices.
8.5. If you have any questions or concerns about the security of your Personal Data, please contact us using the details set out in the "Contact Us" section below.
9. Cookies and Similar Online Technologies
9.1. Cookies are small text files placed on your device when you visit our Services. They help us recognize your browser or device and remember certain information about your visit. Cookies do not usually identify you by name, but they may identify your device or browser.
9.2. Like many websites, we use cookies and similar technologies to help our Services work properly, to remember your preferences, to understand how our Services is used, and to measure and improve our marketing. We may also permit third parties and service providers to use cookies and similar technologies on our Services to provide analytics and other functions described in this Privacy Policy .You can also stop all collection of information via our web services by not using our Services.
9.3. We, along with third-party service providers and business partners, use cookies, tags, and scripts. These technologies help us analyze trends, manage the Services, track your activities on the site, and collect statistical information about our user base. We receive individual or aggregated analytics reports from these technologies. This helps us better understand how our Services is used, learn which sections of our Services you visit, and improve the effectiveness of our advertising and search functions.
9.4. We use cookies to ensure the best performance of our Services and to make it easier for you to access our Services by remembering your device and preferences. Where we provide a cookie banner or cookie settings tool, you can choose whether to accept optional cookies (such as analytics and advertising cookies).
9.5. You may also be able to utilize third-party tools and features to further restrict our use of cookies and similar technologies. For example, cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. In addition, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser.
10. Children's Privacy
10.1. Parent-Managed Service. The Product is intended to be set up and managed by a Parent. A Parent creates or accesses the Parent Account, links the Product, creates the Child Profile and controls available features.
10.2. United States. Before collecting Personal Data directly from a child under 13 where COPPA applies, we provide the Parent with a direct notice and obtain verifiable parental consent, unless a limited legal exception applies. We will verify your identity using a Google account verification code.
10.3. EEA. In the EEA, the age at which a child may consent to an information-society service varies between 13 and 16. Where consent is our legal basis and the child is below the applicable age, we make reasonable efforts, taking into account available technology and the risks of processing, to verify that the Parent has authorized the processing.
10.4. Separate Actions. We maintain separate actions for:
10.4.1. acceptance of the Terms and general Privacy Policy;
10.4.2. authorization for the collection and use of the child’s Personal Data; and
10.4.3. activation of the current-location feature.
Acceptance of the Terms does not by itself constitute verifiable parental consent.
10.5. Location. The current-location feature is off by default. Before first activation, we provide a just-in-time notice explaining the location precision, purpose, recipient, retention period and how the feature may be disabled.
10.6. Parent Rights. A Parent may review the child’s Personal Data, request correction or deletion, withdraw consent, refuse further collection and disable optional features through https://guardian-pre-va.gigglepal.com/ or by contacting: service@gigglepal.com.
10.7. Unauthorized Collection. If we learn that we collected a child’s Personal Data without required Parent authorization, we will promptly suspend the relevant processing and delete the information, unless retention is required by law.
11. Your Privacy Rights
You may have certain rights in relation to the Personal Data we hold about you or your child, where applicable. The availability and scope of these rights may vary depending on your place of residence and the applicable privacy laws. These rights are subject to applicable legal requirements and limited exceptions.
11.1. Right to access: You may request access to the Personal Data that we hold about you or your child, where applicable. This includes information about the types of Personal Data we collect, how we use it, and to whom it may be disclosed.
11.2. Right to correction: You may request that we correct Personal Data we hold about you or your child, where applicable, if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.
11.3. Right to request deletion or de-identification: You may request that we delete or de-identify Personal Data relating to you or your child, where applicable, where it is no longer required for a lawful purpose, subject to our legal and regulatory obligations..
11.4. Right to withdraw consent: Where we rely on your consent or, where applicable, your consent or authorization as a parent or legal guardian to process Personal Data, you may withdraw that consent or authorization at any time. Withdrawal of consent or authorization will not affect the lawfulness of any processing carried out before the withdrawal.
11.5. Right to make a complaint: If you believe that we have not handled Personal Data relating to you or your child in accordance with applicable privacy laws, you have the right to lodge a complaint with us.
11.6. How to submit a privacy request: you may submit a request to exercise your privacy rights by contacting us using the contact details set out in the "Contact us" section below. To help us process your request, please provide sufficient information to identify yourself and clearly describe your request. We may need to verify your identity and, where applicable, your authority as the child’s parent or legal guardian before processing your request.
11.7. Our response to requests: We will respond to your request within the timeframe required by applicable law. We may need to verify your identity and, where applicable, your authority as the child’s parent or legal guardian before processing a request.
12. Third Party Websites and Applications
12.1. Our Services may contain links to third-party websites or services that are not owned or controlled by us (“Third Party Website(s)”). We are not responsible for the privacy practices or the content of Third Party Websites, and this Privacy Policy does not apply to your use of them. We encourage you to review the privacy policy of any Third Party Website you visit.
12.2. To provide you with a better product and service experience, our Services may use certain third-party technologies, such as scripts, tags, pixels, plug-ins, or similar tools, provided by authorized third-party partners.
12.3. We conduct appropriate security assessments and monitoring of these third-party technologies to help protect the security of Personal Data. These technologies are primarily used to support core Services functionalities, enhance performance, enable analytics, and ensure stable and secure operation of our website.
12.4. We may adjust the types or scope of third-party technologies used on our Services from time to time in response to new service requirements or changes in business functions.
13. Changes to this Privacy Policy
13.1. We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.
13.2. When we update this Privacy Policy, we will revise the "Last Updated" date at the top of this Privacy Policy. Where the changes are material, we will take reasonable steps to notify you in accordance with applicable law. Such notification may include, where appropriate, providing notice by email (where you have provided us with a valid email address), posting a prominent notice on our website or other platforms, or using any other notification method required or permitted by applicable privacy laws.
13.3. We encourage you to review this Privacy Policy periodically to stay informed about how we handle your Personal Data.
14. Contact us
Should you have any questions or comments regarding this Privacy Policy, please feel free to contact us at:
14.1. Company name: DINO INNOVATION LIMITED
14.2. Email: service@gigglepal.com
14.3. Adress: 37 CROYDON ROAD BECKENHAM UNITED KINGDOM BR3 4AB
15. Details of Controllers
Your Personal Data is controlled by the our Group company located in your region. The following entities are responsible for processing your data:
| Controller entities | Contact Details |
| DINO INNOVATION LIMITED | Adress: 37 CROYDON ROAD BECKENHAM UNITED KINGDOM BR3 4AB |
16. Supplemental Terms – Jurisdiction-Specific
16.1. UNITED STATES
16.1.1. These following disclosures supplement the information contained in the main body of our Privacy Policy by providing additional information about our Personal Data processing practices relating to individual residents of certain states in the United States, where applicable under U.S. state privacy laws. For a detailed description of how we collect, use, disclose, and otherwise process Personal Data, please read the main body of our Privacy Policy.
16.1.2. Collection and use of Personal Data
(1) Personal Data.
(A) Personal Data Collected: Although we describe the categories of information we may collect in Section (1) above, we have not collected any personal information from California residents in the 12-month period preceding the "Last Updated" date of this Privacy Policy.
(B) Personal Data Sold or Shared: We have not sold or shared (for cross-context behavioral advertising) any personal information of California residents to third parties in the preceding 12 months.
(C) Personal Data Disclosed for Business Purposes: We have not disclosed any personal information of California residents for a business purpose to third parties in the preceding 12 months.
(2) Sensitive Personal Data
(A) We do not intentionally collect Sensitive Personal Data unless it is necessary to provide or secure our Sites, Applications, products or services, comply with applicable laws, or fulfill another purpose disclosed at the time of collection and permitted by applicable law.
The following categories of Personal Data may be collected or otherwise processed in connection with our Sites, Applications, products or services and may be classified as “Sensitive Personal Data” under certain privacy laws:
(b) Payment card information (collected and processed solely by our third-party payment providers; we do not have access to this data).
(B) We only use or disclose Sensitive Personal Data where reasonably necessary and proportionate,and where permitted by law, for the purposes of performing services you have requested, verifying and improving the services we provide, detecting security incidents, fraud and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process Sensitive Personal Data without the purpose of inferring characteristics about the relevant individual, and we do not sell Sensitive Personal Data or process or otherwise share Sensitive Personal Data for the purpose of targeted advertising (as further described below).
(C) However, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of Sensitive Personal Data (as described in the Your Additional U.S. Privacy Choices section below).
(3) Deidentified Information: We may at times receive, or process Personal Data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
16.1.3. Keep Your Information Safe and Secure
(1) All our products are built with strong security features that continuously protect your information. The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you. And if we do detect something risky that we think you should know about, we’ ll notify you and help guide you through steps to stay better protected.
(2) We work hard to protect you and us from unauthorized access, alteration, disclosure, or destruction of information we hold, including:
(A) We use encryption to keep your data private while in transit.
(B) We offer a range of security features,such as password protection and encrypted transmission.
(C) We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.
(D) We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations.
16.1.4. Personal Data Disclosures, Sales, and Targeted Advertising
(1) We may disclose the categories of Personal Data above to the following categories of third parties: the entities that make up the our group, Processors, ad networks and advertising partners, business and marketing partners, third-party providers with services integrating with our services, individuals you choose to share Personal Data with, and certain third parties where you have provided consent or where otherwise required or permitted by law. Please see Section (5) for more detail. Please be aware that we will not transfer your Sensitive Personal Data to any third parties, including advertising platforms, data brokers, or information resellers, for purposes other than providing or improving the use case or features of our Sites, Applications, products, or services, without your consent.
(2) Our disclosure or making available of identifiers, customer records, commercial information, internet/ network information, and inferences to ad networks and advertising partners may qualify as the sale of Personal Data or the sharing or processing of Personal Data for the purpose of displaying advertisements that are selected based on Personal Data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws.
(3) Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of Personal Data or the processing of Personal Data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).
(4) Please note we do not sell the Personal Data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes. In addition, we do not sell Sensitive Personal Data, and we do not process or otherwise share Sensitive Personal Data for the purpose of targeted advertising.
16.1.5. Automated Decision-Making and Profiling
We do not conduct automated processing of Personal Data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.
16.1.6. Your Additional U.S. Privacy Choices
(1) Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
(A) Right to Know: the right to confirm whether we are processing Personal Data about you and, under California and Oregon law only, to obtain certain personalized details about the Personal Data we have collected about you, including:
(a) The categories of Personal Data collected;
(b) The categories of sources of the Personal Data
(c) The purposes for which the Personal Data were collected;
(d) The categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom this Personal Data were disclosed (or a list of the specific third parties to whom Personal Data have been disclosed);
(e) The categories of Personal Data shared for targeted advertising purposes (if any), and the categories of recipients to whom the Personal Data were disclosed for these purposes; and
(f) The categories of Personal Data sold (if any) and the categories of third parties to whom the Personal Data were sold.
(B) Right to Access & Portability: the right to obtain access to the Personal Data we have collected about you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
(C) Right to Correction: the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
(D) Right to Control Over Sensitive Personal Data: the right to exercise control over our collection and processing of certain Sensitive Personal Data.
(E) Right to Opt-Out of Targeted Advertising: the right to direct us not to use or share Personal Data for certain targeted advertising purposes.
(F) Right to Opt-Out of Sales: the right to direct us not to sell Personal Data to third parties.
(G) Right to Deletion: the right to have us delete Personal Data we maintain about you (subject to certain exceptions).
(2) Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
(3) Submitting Privacy Rights Requests
To exercise your privacy rights, please follow the procedures below:
(A) Submission Methods: You may submit a request by emailing us at [●] or by using our online privacy web form available on the Website.
Opt-Out of Tracking: To opt-out of the "sale" or "sharing" of personal data via cookies for targeted advertising, please click the “Cookie Settings” or “Do Not Sell or Share My Personal Information” link in our website footer and adjust your preferences.
(B) Identity Verification: Before processing requests for access, correction, or deletion, we must verify your identity to protect your security. This process typically involves:
(C) Authenticated Users: Requiring you to log in to your account to verify your credentials.
(D) Non-Account Holders: Matching at least two or three data points provided in your request (such as name, email, and associated device serial number) against our existing records.
(E) Required Information: All requests must include the requester’s full name, email address, their relationship with us, and the specific right they wish to exercise.
(F) Response Timeline: We will acknowledge receipt of your request within 10 business days and aim to provide a substantive response within 45 days (which may be extended by an additional 45 days where reasonably necessary).
(5) Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
(5) Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.