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Privacy Policy

This Privacy Policy makes it possible for the Company to comply with a complex web of rules and regulations that provide you access to the Service which provides content intended to help the community expose, explore and push back against threats to your health as means to extend Healthspan, Age-Well, and Stay-Younger Longer.

In addition to this Privacy Policy we recommend you also review the User Terms and Conditions which govern Your use of the Service and Disclaimers and Disclosures that further inform your use of the Service. 

By using the Service, you completely agree to the Privacy Policy, Terms and Conditions, Disclaimers and Disclosures. By accessing or using the Service You agree to be bound by these Terms and Conditions. If You disagree with any parts of these Terms and Conditions You may not access the Service. These make it possible to provide and allow you to interact with the Content as an individual and with other users at crowd scale to achieve results that make possible fulfillment of our highest potential as we age.

We are committed to protecting the privacy, confidentiality and security of any personal information about our users. Your privacy is important to Us and we have taken practical and prudent steps to protect it from unauthorized access. 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 operate, 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 of 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:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with another party.
  • Business, for the purpose of CCPA/CPRA, 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.
  • CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Centrificus, Inc.
  • Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident and is using the Service from within California.
  • 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.
  • Country refers to the United States
  • 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.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • 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.
  • GDPR refers to the General Data Protection Regulation in the EU and The EEA.
  • Personal Data selected information that relates to an identified or identifiable individual.
  • Service refers to the Websites: 
  • Service refers to the Websites: centrificus.com, crowdscalecatalyst.substack.com, healthspanextension.substack.com, healthconspiracies.com, healthspanextension.com, vitalityprograms.com
  • 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.
  • 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).
  • Website refers to the Service or other 3rd party websites.
  • 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.

Personally Identifiable Health Information

Disclaimer:  This is not a HIPAA compliant service, information is not encrypted and could get hacked.  Anything you comment to, post, share, submit, or upload to the Service is obviously visible to everyone on the plant with an internet connection. They are not all your friends. Do not share personally identifiable contact information, social handles that can be linked back to you, photos or images, etc. The internet backups everything everyday; there is no way to take it back after you publish it.  You are personally liable for anything you submit to and publish on the Service and any damage it may do to the Company, other businesses, or individuals.  Proceed with caution.

If you chose to share, reveal, your personally identifiable sensitive health information You agree that under no circumstances will the Company be liable in any way for any content or any loss or damage of any kind incurred as a result of Your use of the Service or any content on the Service.  In these Terms and Conditions you also agree to Indemnify and Hold Harmless the company for any actions or claims made against the Company attributable to Your interactions on the Service or your Content. This means YOU could pay both Your and the Company’s legal fees and any damages awarded in Small Claims Court, other Courts, or Arbitration.

As a community we need to be able to discuss health, wellness, and aging in general and specific terms in blogs and comments and posts so that we may work to expose, explore and push back against threats to our health; medical care as it is now and what it can be in the future; emerging geroscience research and information related to the biology of aging as means to potentially extend Healthspan, Age-Well, and Stay-Younger Longer.

While in general you have the right to share your personal stories and health-related information as constitutionally protected free speech and you likely do it all the time, on the Service this MUST be done anonymously without personally identifiable information that could lead to the revealing of your identity or that of anyone else especially family, friends, coworkers and anyone else – even strangers have rights.  Best practice is to use an alias, fictious username, or pseudonym for your username that is NOT traceable to you.

See the Terms and Conditions for the full text and how to properly use the Service in a compliant manner.  By continuing to use the Service you have agreed to the Privacy Policy, Terms and Conditions, and Disclaimers and Disclosures.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

We aspire to collect the minimum amount of information needed to provide services to you. While using Our Service, We may ask You to provide Us with certain personally identifiable information (“PII”) 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
  • Shipping / billing data for purchases
  • Phone number
  • Credit and Debit Card Bank account information as necessary to pay for products, donations, and services through a secure 3rd The Company and Service never retains your credit card or bank card information.
  • Usage Data
  • Media (Pictures & Videos), comments, posts
  • Login information like username and password

If You ever pay for a product and/or a service via bank wire transfer, We may have to ask You to provide information to facilitate this transaction and to verify Your identity.

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.

Cookies Policy

Our website and Services use cookies and other similar technologies (collectively in this Policy, “cookies”), in order to provide a better and personalized service to you, to help keep your account safe, and to generally improve our Websites and Services. Cookies perform essential functions, such as ensuring a webpage loads correctly and securely. They also help us provide you with a consistent and efficient experience. For example, we may use cookies to remember which language you prefer, to remember that you are a repeat visitor so we can direct you to the appropriate part of our website, or to present you with services that are matched to your preferences.

Cookies are small pieces of text used to store information on web browsers. They are used by many websites to store and receive identifiers and other information on devices, such as a handheld phone or computer. We also may include tracking pixels, which are small graphic images, in our marketing communications to determine engagement. These cookies may be set by us or by third parties with whom we have partnered to assist in our marketing efforts.

Categories of cookies:

Strictly Necessary Cookies.

Strictly Necessary cookies are essential to providing the Website and Services to you and cannot be turned off. They provide necessary security settings or help you use our websites’ features and Services as expected (including remembering your cookie consent preferences). We place Strictly Necessary cookies.

Functional Cookies.

Functional cookies allow us to remember choices you make about the kind of experience you want on our Platform and to provide you with a more personalized experience. For example, a functional cookie is required to remember which language you prefer. You may choose to opt out of these cookies, but if you do, various functions of the websites or Services may be unavailable to you or may not work as intended.

Performance.

Performance cookies help us learn how you use our Platform to help improve their performance and design. These cookies provide us with aggregated statistical information such as number of page visits, page load speeds, how long a user spends on a particular page, and the types of browsers or devices used to access our system.

Targeting.

These third party cookies are placed by third party advertising platforms or networks to collect information about your visits to and actions on certain pages of our Platform so they can deliver ads for relevant products and services to you later, such as when you are on certain third party sites. These cookies also track ads performance.

Analytics cookies.

We use it to collect information about how users access our platform – for example, the number of users on a website, how long they stay on the site for, and what parts of the site they visit.

We do not sell, rent, or share personal information with third parties as defined under the California Consumer Privacy Act of 2018 (California Civil Code Sec. 1798.100 et seq.), nor do we do not sell, rent, or share personal information with third parties for their direct marketing purposes as defined under California Civil Code Sec. 1798.83. We do permit third parties to collect personal information as described in our Privacy Policy for the business purposes described here.

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.
  • To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

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 show advertisements to You to help support and maintain 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. 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 and post Content to the Service or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent – including Citizen-Science projects you choose to participate in.

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.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete, update, amend or delete certain information about You from within the Service. If it is impractical for the Company to manage individual data requests we reserve the right and may choose to permanently delete your account and all of its information.  If your prior account was in good standing you may create a new account.  When the Company has a legal obligation or lawful basis it may be required to retain certain information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, or the form of ownership transfer Your Personal Data may be transferred and 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. We strive to protect our Users against any cyber incident. We have implemented our system with WordPress best practices security measures to protect our users. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

You expressly agree and acknowledge that the use of the Services is at your sole risk. In no event will the Company professionals or their officers, employees, directors, parents, subsidiaries, affiliates, partners, agents or licensors be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of revenues, profits, goodwill, use data or other intangible losses arising out of or related to your use of the Website and Services.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use a variety of third-party Service providers to monitor and analyze the use of our Service including but not limited to:

  • 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

Advertising

We may use a variety of Service Providers and Ad-Networks to show advertisements to You to help support and maintain the Service including but not limited to:

  • Google AdSense & DoubleClick Cookie. Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: (http://www.google.com/ads/preferences/)

SMS Marketing

The Company and its Affiliates may from time to time send You text message communications containing notifications and links to blog content, comment and post updates and replies, notice of related crowd-scale campaigns and citizen-science projects, Service updates, marketing and promotional materials about Our and other 3r party products and services. We will provide You the option of opting in and opting out of receiving future marketing text communications.

We may use Text Messages services for the dissemination, invitations, incentives for purchase or commercial transaction of any product or service, such as, but not limited to: (i) the act of encouraging the purchase / use of a product / service of the company or advertisers that subcontract it; (ii) Text Messages that have advertising, promotional or marketing connotations, or that show preference for any company or brand.

Telephone Consumer Protection Act 47 U.S.C. § 227

The Company is compliant with the Telephone Consumer Protection Act. We do not engage in “telephone solicitation”, which means the initiation of a telephone call or message for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or services, that is transmitted to any person, but such term does not include a call or message (i) to any person with that person’s prior express invitation or permission, (ii) to any person with whom the caller has an established business relationship, or (iii) by a tax exempt nonprofit organization.

We do not send “unsolicited advertisement”, which means any material advertising the commercial availability or quality of any property, goods, or services which is transmitted to any person without that person’s prior express invitation or permission, in writing or otherwise. We do not use “telephone facsimile machine”, which means equipment which has the capacity (i) to transcribe text or images, or both, from paper into an electronic signal and to transmit that signal over a regular telephone line, or (ii) to transcribe text or images (or both) from an electronic signal received over a regular telephone line onto paper.

Email Marketing

We may use Your Personal Data to contact You with notification of updated and new blog content, comments and post updates and replies, notice of related crowd-scale campaigns and citizen-science projects and campaign updates, newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving these communications from Us by following the unsubscribe link or instructions provided in any email We send.

We may use a variety of Email Marketing Service Providers to manage and send emails to You including but not limited to.

  • 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/)

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.  If You use a third party service to pay a product and/or service via bank transfer, they may ask You to provide information to facilitate this transaction and to verify Your identity.

  • Apple Store In-App Payments Their Privacy Policy can be viewed at (https://www.apple.com/legal/privacy/en-ww/)
  • Stripe Their Privacy Policy can be viewed at (https://stripe.com/us/privacy)
  • PayPal Their Privacy Policy can be viewed at (https://www.paypal.com/webapps/mpp/ua/privacy-full)

Behavioral Remarketing

The Company may use remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

  • Measure and analyze traffic and browsing activity on Our Service
  • Show advertisements for our products and/or services to You on third-party websites or apps
  • Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

  • NAI’s opt-out platform: (http://www.networkadvertising.org/choices/)
  • EDAA’s opt-out platform (http://www.youronlinechoices.com/)
  • DAA’s opt-out platform: (http://optout.aboutads.info/?c=2&lang=EN)

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with third-party vendors. This allows Our third-party vendors to recognize and deliver You personalized ads across devices and browsers.  A hashing algorithm transforms email addresses into hexadecimal strings, so each email becomes an unrecognizable jumble of numbers and letters. This code cannot be traced back to the email address, but the behaviors attached to the email address may be recorded. In other words, a hashed email can be used to obtain data about an individual’s online behavior without marketers obtaining the email address.

To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We may use but are not limited to are:

  • 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)
  • 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/516147308587266) For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: (https://www.facebook.com/privacy/explanation). 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 Behavioral 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/)
    • Digital Advertising Alliance of Canada in Canada (http://youradchoices.ca/)
    • European Interactive Digital Advertising Alliance in Europe (http://www.youronlinechoices.eu/), or opt-out using your mobile device settings.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service including but not limited to:

  • Several types of CAPTCHA, including image-based, audio-based, and text-based challenges. Some of the most popular CAPTCHA methods include reCAPTCHA by Google, hCaptcha, and FunCaptcha.

GDPR Privacy – Foreign / International Users

The Company is based in the United States of America (USA) and intends to primarily serve Services to residents of the USA, if You are a Foreign / International User or consumer, there may be limited situations where mandatory provisions of the law of the country in which you are resident in provide additional rights.

As an industry best practice, the Company and Service maintain a leading WordPress compliance plugin that provides Users of the Service high quality Privacy compliance services.  Federal, State, and international requirements are constantly changing and as such the Service will reasonably maintain and update the plugin as the application updates their plugin from time to time.  As such the company strives to keep current with privacy policies and plugin solution but offers no guarantee beyond best-efforts and the current capabilities of the selected compliance and software plugins that make it possible to provide the Service as a WordPress site.

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.

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 if You are within the EU, to self-service:

  • 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.
  • correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • limit 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 limit or restrict processing Your Personal Data for direct marketing purposes.
  • 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.
  • download and transfer of Your Personal Data. We will provide to You, 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

We are a very small organization primarily targeting Users in the USA.  We provide self-service options for international users so they may have reasonable control of their data rights.  If self-service options fail in your case you may also exercise Your rights by contacting Us through the Contact Us page using the Legal drop down option. If You make a request, We will try our best to respond to You as soon as possible, but note we are a very small operation with a worldwide audience and as such can’t guarantee a response time.

We are required by law to verify Your identity before responding to User data requests involving PII which opens up a gray area of compliance whereby you may have to submit highly confidential information like an identification card and other documentation which despite best efforts the Company can’t and expressly does not guarantee or warrant will be maintained securely.  There could be a security breach – We could get hacked.  We reserve the right to terminate your account and delete your data for any reason and in some cases it may make sense for you to simply delete your account and all data and create a new account where you select preferences anew for how your data and privacy preference are handled automatically.

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/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in the Privacy Policy.  It applies solely to all visitors, users, and others who reside in the State of California.  

As an industry best practice, the Company and Service maintain a leading WordPress compliance plugin that provides Users of the Service high quality Privacy compliance services.  Federal, State, and international requirements are constantly changing and as such the Service will reasonably maintain and update the plugin as the application updates their plugin from time to time.  As such the company strives to keep current with privacy policies and plugin solution but offers no guarantee beyond best-efforts and the current capabilities of the selected compliance and software plugins that make it possible to provide the Service as a WordPress site.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us as in the case of posting Your Content to the Service (like age), verifying your identity to make changes requested changes to your data.  Credit cards and other payment information are not maintained on the Our Service as they are collected through 3rd party providers like Stripe.

  • Category A: Identifiers. Examples: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers. Collected: Yes name, address, email, alias, cell phone number, online and IP identifiers
  • Category B: Other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: name, address, signature, Social Security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. For the information mentioned specifically: Collected: Yes for name and address,
  • Category C: Protected classification characteristics under California or federal law. Examples: age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: Yes for age
  • Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: Yes.
  • Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No
  • Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: Yes.
  • Category G: Geolocation data. Examples: Approximate physical location. Collected: Yes.
  • Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No.
  • Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No.
  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99) Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No.
  • Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No.
  • Category L: Sensitive personal information. Examples: Account login and password information, geolocation data. Collected: Yes.

Under CCPA/CPRA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA/CPRA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
  • Indirectly from You. For example, from observing Your activity on our Service.
  • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to provide advertising on our Service, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

  • To operate our Service and provide You with Our Service.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
  • Other uses.

The examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section. If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

Share of Personal Information

We may share, and may have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

  • Service Providers
  • Payment processors
  • Our affiliates
  • Our business partners
  • Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Pseudonymous and Anonymous Data

The Service may use Your Personal Information and other information about You to create and analyze anonymized and aggregated information. Anonymized and aggregated information is used to measure visitors’ interest in and use the Sites, interest in certain contents and features, and other applications. Anonymized or aggregated information is generally not considered to be Personal Information, and We may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information with our affiliates and with Third Parties for Our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying You.

Research and Development

The Service may use Your Personal Information to create non-identifiable anonymous information that We may use, alone or in the aggregate, along with information obtained from other sources, in order to help Us to optimally deliver Our existing products and services or develop new products, processes and services.

Fraud protection

The Service may use the Personal Information about You in order to prevent fraud and to protect the accuracy and integrity of financial transactions made throughout the Sites. The Service may share the Personal Information with a third party service provider for such a purpose.

Sale of Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean 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 by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood and will never in the normal course of business sell Your personal contact information like name, address and cell phone number with the possible exception of a future merger, acquisition, sale or other transfer of the Company. We may allow Service Providers to use your information, such as hashed email addresses or other online identifiers collected on Our Service with third-party vendors for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.  This information allows Our third-party vendors to recognize and deliver You personalized ads across devices and browsers.  A hashing algorithm transforms email addresses into hexadecimal strings, so each email becomes an unrecognizable jumble of numbers and letters. This code cannot be traced back to the email address.

We may sell and may have sold in context of CCPA/CPRA online identifiers in last twelve (12) months the following categories of personal information:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 18 Years of Age

We do not knowingly collect, sell, or share personal information or create accounts from minors under the age of 18 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission. If You have reason to believe that a child under the age of 18 has provided Us with personal information, please use the Contact Us form with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California and the Company or Service business volumes mandate compliance with CCPA/CPRA, You have the following rights via self-service options or if that fails to contact us using the Contact Us form:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used which are contained in this Privacy Policy.
  • The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information which are contained in this Privacy Policy.
  • The right to say no to the sale or sharing of Personal Data (opt-out). You have the self-service right to direct Us to not sell Your personal information
  • The right to correct Personal Data. You have the self-service right to correct or rectify any inaccurate personal information about You that We collected.
  • The right to limit use and disclosure of sensitive Personal Data. You have the self-service right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies.
  • The right to delete Personal Data. You and We have the right to deletion of Your Personal Data under certain circumstances, subject to certain exceptions. OWe may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
    • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights

Exercising Your CCPA/CPRA Data Protection Rights

Please see the “Do Not Sell My Personal Information” section and “Limit the Use or Disclosure of My Sensitive Personal Information” sections below for more information on how to opt out and limit the use of sensitive information collected. Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us through the Contact Us form. Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

Provided the Company and Service meets the formal business requirements mandating compliance with CCPA/CPRA the Company will disclose and deliver the required information free of charge within 45 days of receiving and acknowledging receipt of Your verifiable request. The time-period to provide the required information may be extended once by an additional 45 days when reasonably necessary. Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

Do Not Sell My Personal Information –

As defined in the CCPA/CPRA, “sell” and “sale” mean 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 by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood and will never in the normal course of business sell Your personal contact information like name, address and cell phone number with the possible exception of a future merger, acquisition, sale or other transfer of the Company. We may allow Service Providers to use your information, such as hashed email addresses or other online identifiers collected on Our Service with third-party vendors for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.  This information allows Our third-party vendors to recognize and deliver You personalized ads across devices and browsers.  A hashing algorithm transforms email addresses into hexadecimal strings, so each email becomes an unrecognizable jumble of numbers and letters. This code cannot be traced back to the email address,

You have the right to opt-out of the sale of Your personal information via self-service tools provided by the compliance plugin operated on the Service.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA 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/CPRA 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/will need to opt out on every browser that You use.

Website

If applicable, click “Privacy Preferences”, “Update Privacy Preferences” or “Do Not Sell My Personal Information” buttons listed on the Service to review your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.

Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

  • The NAI’s opt-out platform: (http://www.networkadvertising.org/choices/)
  • The EDAA’s opt-out platform (http://www.youronlinechoices.com/)
  • The DAA’s opt-out platform: (http://optout.aboutads.info/?c=2&lang=EN)

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.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods. We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the “Use of Your Personal Data” section.

“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.

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 Us form.

Children’s Privacy

Our Service does not intend to provide Services to anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, you may contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We may 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.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows 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.  You must be at least 18 years old to use the Service rendering this not applicable.

However, if registered as a user in error YOU or your Guardian may request removal of such data, and if You are a California resident, You can contact Us and provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative. 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.

Contact Us

If you have any questions about this Privacy Policy, You can send a message by visiting the Contact Us page on the Service.