From b4e6035815bbab78b705416be54cd7faf9064862 Mon Sep 17 00:00:00 2001 From: Viet Nguyen <3805254+vnugent@users.noreply.github.com> Date: Tue, 5 Nov 2024 17:00:16 -0800 Subject: [PATCH] feat: privacy notice (#1197) * feat: privacy notice --- public/privacy.html | 7964 +++++++++++++++++++++++++++++++++++++++++++ 1 file changed, 7964 insertions(+) create mode 100644 public/privacy.html diff --git a/public/privacy.html b/public/privacy.html new file mode 100644 index 000000000..b1c145f49 --- /dev/null +++ b/public/privacy.html @@ -0,0 +1,7964 @@ + + + + + OpenBeta Privacy Notice + + + + +
+ + + +
+
+ + PRIVACY POLICY + +
+

+
Last updated November 05, + 2024
+

+

+

+
This + Privacy Notice for OpenBeta + ("we," + "us," or "our" + + ), describes how and why we might access, collect, + store, use, and/or share ( + "process") your + personal information when you use our services ( + "Services"), + including when you: + + +
+ + + +
+
    +
  • Download and use + our + mobile application (OpenBeta) + + , + + + + or any + other application of ours that + links to this Privacy Notice + + + +
    • +
+
+ +
+ +
+
    +
  • Engage with us in other related + ways, including any sales, marketing, or events + + + +
    • +
+
Questions + or + concerns? Reading this Privacy Notice will help you + understand your privacy rights and choices. We are responsible for + making decisions about how your personal information is processed. If + you do not agree with our policies and practices, please do not use our + Services. If you still have any + questions or concerns, please contact us at + support@openbeta.io.
+

+

+
SUMMARY OF KEY + POINTS
+

+
This summary provides key points + from our Privacy Notice, but you can find out more details about + any of these topics by clicking the link following each key point + or by using our table of + contents below + to find the section you are looking + for.
+

+
What personal information do we + process? When you visit, use, or navigate our Services, we may + process personal information depending on how you interact with us and the + Services, the choices you make, and the products and features you use. Learn + more about personal information you disclose to + us.
+

+
Do we process any sensitive personal + information? Some of the information may be considered + "special" or "sensitive" in certain jurisdictions, for + example your racial or ethnic origins, sexual orientation, and religious + beliefs. We do not process sensitive + personal information. +
+

+
Do we collect any information from third + parties? + We do not collect any information from + third parties. +
+

+
How do we process your + information? We process your information to provide, improve, + and administer our Services, communicate with you, for security and fraud + prevention, and to comply with law. We may also process your information for + other purposes with your consent. We process your information only when we + have a valid legal reason to do so. Learn more about how + we + process your + information.
+

+
In what situations and with which parties do we share personal + information? We may share information in specific situations + and with specific third parties. Learn more + about when + and with whom we share your personal + information. +
+

+
How do we keep your information + safe? We have adequate + organizational and technical + processes and procedures in place to protect your personal information. + However, no electronic transmission over the internet or information storage + technology can be guaranteed to be 100% secure, so we cannot promise or + guarantee that hackers, cybercriminals, or other + unauthorized third parties + will not be able to defeat our security and improperly collect, access, steal, + or modify your information. Learn more about how + we keep your information + safe. + +
+

+
What are your rights? Depending + on where you are located geographically, the applicable privacy law may mean + you have certain rights regarding your personal information. Learn more + about your + privacy rights.
+

+
How do you exercise your + rights? The easiest way to exercise your rights is by submitting a data + subject access + request + , or by contacting us. We will consider and + act upon any request in accordance with applicable data protection laws. +
+

+
Want + to learn more about what we do with any + information we collect? Review + the Privacy Notice in + full.
+

+

+
TABLE OF + CONTENTS
+

+
1. WHAT INFORMATION + DO WE COLLECT?
+
2. HOW DO WE PROCESS + YOUR INFORMATION? +
+
3. WHAT LEGAL BASES + DO + WE RELY + ON TO PROCESS YOUR PERSONAL INFORMATION? + +
+
4. WHEN AND + WITH WHOM DO WE SHARE YOUR + PERSONAL + INFORMATION? + + + + +
+
+ + + +
+
5. HOW LONG DO WE + KEEP YOUR INFORMATION? + +
+
6. HOW DO WE KEEP YOUR + INFORMATION SAFE? + + +
+
7. DO WE COLLECT + INFORMATION FROM MINORS? + +
+
8. + WHAT ARE YOUR PRIVACY + RIGHTS? +
+
9. CONTROLS FOR DO-NOT-TRACK + FEATURES
+
10. DO UNITED STATES + RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? + +
+
+ + + + + + + + + + +
+
11. DO WE MAKE + UPDATES TO THIS NOTICE?
+
12. HOW CAN YOU CONTACT US + ABOUT THIS NOTICE?
+
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE + DATA WE COLLECT FROM YOU?
+

+

+
1. + WHAT + INFORMATION DO WE + COLLECT? +
+

+
Personal + information you disclose to us
+
+

+
In + Short: We + collect personal information that you + provide to + us. +
+
+

+
We + collect personal information that you + voluntarily provide to us when you + + register on the Services,  + + express an + interest in obtaining information about us or our products and + Services, when you participate in activities on the Services, or + otherwise when you contact us.
+

+
+ +
+
Personal Information Provided by + You. The personal information that we collect depends on + the context of your interactions with us and the Services, the choices + you make, and the products and features you use. The personal + information we collect may include the following: + +
+
    +
  • + email addresses +
    • +
+
+ + + +
+
Sensitive Information. + We do not process sensitive information. +
+

+
+ + + + + + + + + +
+
Application Data. If you use our + application(s), we also may collect the following information if you choose to + provide us with access or permission: +
+
    +
  • Geolocation + Information. We may request access or permission to track + location-based information from your mobile device, either continuously + or while you are using our mobile application(s), to provide certain + location-based services. If you wish to change our access or + permissions, you may do so in your device's settings.
    • +
+
+ +
+ +
+
    +
  • Mobile + Device Data. We automatically collect device + information (such as your mobile device ID, model, and + manufacturer), operating system, version information and system + configuration information, device and application identification + numbers, browser type and version, hardware model Internet service + provider and/or mobile carrier, and Internet Protocol (IP) address + (or proxy server). If you are using our application(s), we may + also collect information about the phone network associated with + your mobile device, your mobile device’s operating system or + platform, the type of mobile device you use, your mobile device’s + unique device ID, and information about the features of our + application(s) you accessed. +
    • +
+
+ +
+
    +
  • Push + Notifications. We may request to send you push + notifications regarding your account or certain features of the + application(s). If you wish to opt out from receiving these types + of communications, you may turn them off in your device's + settings. +
    • +
+
This information is primarily needed to + maintain the security and operation of our application(s), for + troubleshooting, and for our internal analytics and reporting + purposes.
+

+
+ +
+
All + personal information that you + provide to us must be true, complete, and accurate, and you must + notify us of any changes to such personal + information.
+

+
+ + + + + + + + + +
+

+
2. + HOW DO WE + PROCESS YOUR + INFORMATION? +
+
+

+
In + Short: We + process your information to provide, + improve, and administer our + Services, communicate with you, for + security and fraud prevention, and + to comply with law. We may also + process your information for other + purposes with your + consent. +
+
+

+
We process your personal + information for a variety of reasons, depending on how you + interact with our Services, including: + +
+
    +
  • To facilitate account + creation and authentication and otherwise manage user + accounts. We may process your + information so you can create and log in to your account, as + well as keep your account in working order. + + + +
    • +
+
+ + +
+ + +
+ + +
+ + +
+ +
+ + +
+ + +
+ + +

+ + +

+

+ + +

+

+ +

+

+ +

+
    +
  • + To + request + feedback. We + may + process + your + information + when + necessary + to + request + feedback + and to + contact + you + about + your + use of + our + Services. + + + +
    • +
+
+ + +
+ + + +
+
    +
  • + To + send + you + marketing + and + promotional + communications. We + may + process + the + personal + information + you + send + to us + for + our + marketing + purposes, + if + this + is in + accordance + with + your + marketing + preferences. + You + can + opt + out of + our + marketing + emails + at any + time. + For + more + information, + see + + + " + + WHAT + ARE + YOUR + PRIVACY + RIGHTS? + + + " + + below. + + + + +
    • +
+
+ + + +
+ + + + + +
+ + + +
+ + + +
+ + + +
+
    +
  • + To + protect + our + Services. + We + may + process + your + information + as + part + of + our + efforts + to + keep + our + Services + safe + and + secure, + including + fraud + monitoring + and + prevention. + + + +
    • +
+
+ + + +
+ + + +
+ + + +
+ + + +
+
    +
  • + To + identify + usage + trends. + We + may + process + information + about + how + you + use + our + Services + to + better + understand + how + they + are + being + used + so + we + can + improve + them. + + + +
    • +
+
+ + + +
+ + + +
+ + + +
+ + + +
+
    +
  • + To + save + or + protect + an + individual's + vital + interest. + We + may + process + your + information + when + necessary + to + save + or + protect + an + individual’s + vital + interest, + such + as + to + prevent + harm. + + + +
    • +
+
+ + + + + + + + + + + + +
+
+
+
+
+ 3. + WHAT + LEGAL + BASES + DO + WE + RELY + ON + TO + PROCESS + YOUR + INFORMATION? +
+
+
+
+
+ In + Short: We + only + process + your + personal + information + when + we + believe + it + is + necessary + and + we + have + a + valid + legal + reason + (i.e. + + + , + + + legal + basis) + to + do + so + under + applicable + law, + like + with + your + consent, + to + comply + with + laws, + to + provide + you + with + services + to + enter + into + or + + + fulfill + + + our + contractual + obligations, + to + protect + your + rights, + or + to + + + fulfill + + + our + legitimate + business + interests. + +
+
+
+
+
+ + + + + + + +
+
+ If + you + are + located + in + the + EU + or + UK, + this + section + applies + to + you. +
+
+
+
+
+ + + + +
+
+ The + General + Data + Protection + Regulation + (GDPR) + and + UK + GDPR + require + us + to + explain + the + valid + legal + bases + we + rely + on + in + order + to + process + your + personal + information. + As + such, + we + may + rely + on + the + following + legal + bases + to + process + your + personal + information: +
+
    +
  • + Consent. We + may + process + your + information + if + you + have + given + us + permission + (i.e. + + + , + + + consent) + to + use + your + personal + information + for + a + specific + purpose. + You + can + withdraw + your + consent + at + any + time. + Learn + more + about  + withdrawing + your + consent. +
    • +
+
+ + + +
+ + + +
+
    +
  • + Legitimate + Interests. + We + may + process + your + information + when + we + believe + it + is + reasonably + necessary + to + achieve + our + legitimate + business + interests + and + those + interests + do + not + outweigh + your + interests + and + fundamental + rights + and + freedoms. + For + example, + we + may + process + your + personal + information + for + some + of + the + purposes + described + in + order + to: +
    • +
+
+ + + + +
+
    +
  • + Send + users + information + about + special + offers + and + discounts + on + our + products + and + services + + + +
    • +
+
+ + + + +
+ + + + +
+
    +
  • + + + + Analyze + + + how + our + Services + are + used + so + we + can + improve + them + to + engage + and + retain + users + + + +
    • +
+
+ + + + +
+ + + + +
+
    +
  • + Diagnose + problems + and/or + prevent + fraudulent + activities + + + +
    • +
+
+ + + + +
+
    +
  • + Understand + how + our + users + use + our + products + and + services + so + we + can + improve + user + experience + + + +
    • +
+
+ + + + + + + + + + +
+
    +
  • + Legal + Obligations. + We + may + process + your + information + where + we + believe + it + is + necessary + for + compliance + with + our + legal + obligations, + such + as + to + cooperate + with + a + law + enforcement + body + or + regulatory + agency, + exercise + or + defend + our + legal + rights, + or + disclose + your + information + as + evidence + in + litigation + in + which + we + are + involved. + + +
    +     +
    • +
+
+ + + +
+
    +
  • + Vital + Interests. + We + may + process + your + information + where + we + believe + it + is + necessary + to + protect + your + vital + interests + or + the + vital + interests + of + a + third + party, + such + as + situations + involving + potential + threats + to + the + safety + of + any + person. + + + +
    • +
+
+ + + + + + + + + +
+
+ If + you + are + located + in + Canada, + this + section + applies + to + you. +
+
+
+
+
+ + + + +
+
+ We + may + process + your + information + if + you + have + given + us + specific + permission + (i.e. + + + , + + + express + consent) + to + use + your + personal + information + for + a + specific + purpose, + or + in + situations + where + your + permission + can + be + inferred + (i.e. + + + , + + + implied + consent). + You + can  + withdraw + your + consent at + any + time. +
+
+
+
+
+ In + some + exceptional + cases, + we + may + be + legally + permitted + under + applicable + law + to + process + your + information + without + your + consent, + including, + for + example: +
+
    +
  • + If + collection + is + clearly + in + the + interests + of + an + individual + and + consent + cannot + be + obtained + in + a + timely + way +
    • +
+
+ + + + +
+
    +
  • + For + investigations + and + fraud + detection + and + prevention + + + +
    • +
+
+ + + +
+
    +
  • + For + business + transactions + provided + certain + conditions + are + met + + + +
    • +
+
+ + + +
+
    +
  • + If + it + is + contained + in + a + witness + statement + and + the + collection + is + necessary + to + assess, + process, + or + settle + an + insurance + claim + + + +
    • +
+
+ + + +
+
    +
  • + For + identifying + injured, + ill, + or + deceased + persons + and + communicating + with + next + of + kin + + + +
    • +
+
+ + + + +
+
    +
  • + If + we + have + reasonable + grounds + to + believe + an + individual + has + been, + is, + or + may + be + victim + of + financial + abuse + + + +
    • +
+
+ + + + +
+
    +
  • + If + it + is + reasonable + to + expect + collection + and + use + with + consent + would + compromise + the + availability + or + the + accuracy + of + the + information + and + the + collection + is + reasonable + for + purposes + related + to + investigating + a + breach + of + an + agreement + or + a + contravention + of + the + laws + of + Canada + or + a + province + + + +
    • +
+
+ + + + +
+
    +
  • + If + disclosure + is + required + to + comply + with + a + subpoena, + warrant, + court + order, + or + rules + of + the + court + relating + to + the + production + of + records + + + +
    • +
+
+ + + +
+
    +
  • + If + it + was + produced + by + an + individual + in + the + course + of + their + employment, + business, + or + profession + and + the + collection + is + consistent + with + the + purposes + for + which + the + information + was + produced + + + +
    • +
+
+ + + + +
+
    +
  • + If + the + collection + is + solely + for + journalistic, + artistic, + or + literary + purposes + + + +
    • +
+
+ + + + +
+
    +
  • + If + the + information + is + publicly + available + and + is + specified + by + the + regulations + + + + +
    • +
+
+ + + + + + +
+
+
+
+
+ 4. + WHEN + AND + WITH + WHOM + DO + WE + SHARE + YOUR + PERSONAL + INFORMATION? +
+
+
+
+
+ In + Short: We + may + share + information + in + specific + situations + described + in + this + section + and/or + with + the + following + + + third + parties. + +
+
+ + + + +
+
+
+
+
+ We + + + may + need + to + share + your + personal + information + in + the + following + situations: + +
+
    +
  • + Business + Transfers. + We + may + share + or + transfer + your + 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. +
    • +
+
+ + + + +
+ + + + + +
+ + + +
+ + + +
+ + + + + + + + + + +
+ + + + + + + + + + + + + + + + + + + + + + + + +
+
+
+
+
+ 5. + HOW + LONG + DO + WE + KEEP + YOUR + INFORMATION? +
+
+
+
+
+ In + Short: We + keep + your + information + for + as + long + as + necessary + to + + + fulfill + + + the + purposes + outlined + in + this + Privacy + Notice + unless + otherwise + required + by + law. + +
+
+
+
+
+ We + will + only + keep + your + personal + information + for + as + long + as + it + is + necessary + for + the + purposes + set + out + in + this + Privacy + Notice, + unless + a + longer + retention + period + is + required + or + permitted + by + law + (such + as + tax, + accounting, + or + other + legal + requirements). + + + No + purpose + in + this + notice + will + require + us + keeping + your + personal + information + for + longer + than + + + + + + + the + period + of + time + in + which + users + have + an + account + with + us + + + + + + . + +
+
+
+
+
+ When + we + have + no + ongoing + legitimate + business + need + to + process + your + personal + information, + we + will + either + delete + or + + + anonymize + + + such + information, + or, + if + this + is + not + possible + (for + example, + because + your + personal + information + has + been + stored + in + backup + archives), + then + we + will + securely + store + your + personal + information + and + isolate + it + from + any + further + processing + until + deletion + is + possible. + + + + +
+
+
+
+
+ 6. + HOW + DO + WE + KEEP + YOUR + INFORMATION + SAFE? +
+
+
+
+
+ In + Short: We + aim + to + protect + your + personal + information + through + a + system + of + + + organizational + + + and + technical + security + measures. + +
+
+
+
+
+ We + have + implemented + appropriate + and + reasonable + technical + and + + + organizational + + + security + measures + designed + to + protect + the + security + of + any + personal + information + we + process. + However, + despite + our + safeguards + and + efforts + to + secure + your + information, + no + electronic + transmission + over + the + Internet + or + information + storage + technology + can + be + guaranteed + to + be + 100% + secure, + so + we + cannot + promise + or + guarantee + that + hackers, + cybercriminals, + or + other + + + unauthorized + + + third + parties + will + not + be + able + to + defeat + our + security + and + improperly + collect, + access, + steal, + or + modify + your + information. + Although + we + will + do + our + best + to + protect + your + personal + information, + transmission + of + personal + information + to + and + from + our + Services + is + at + your + own + risk. + You + should + only + access + the + Services + within + a + secure + environment. + + + + + + + +
+
+
+
+
+ 7. + DO + WE + COLLECT + INFORMATION + FROM + MINORS? +
+
+
+
+
+ In + Short: We + do + not + knowingly + collect + data + from + or + market + to + + + children + under + 18 + years + of + age + + + . + + + + +
+
+
+
+
+ We + do + not + knowingly + collect, + solicit + data + from, + or + market + to + children + under + 18 + years + of + age, + nor + do + we + knowingly + sell + such + personal + information. + By + using + the + Services, + you + represent + that + you + are + at + least + 18 + or + that + you + are + the + parent + or + guardian + of + such + a + minor + and + consent + to + such + minor + dependent’s + use + of + the + Services. + If + we + learn + that + personal + information + from + users + less + than + 18 + years + of + age + has + been + collected, + we + will + deactivate + the + account + and + take + reasonable + measures + to + promptly + delete + such + data + from + our + records. + If + you + become + aware + of + any + data + we + may + have + collected + from + children + under + age + 18, + please + contact + us + at + + + + + support@openbeta.io + + + + . + + + + + +
+
+
+
+
+ 8. + WHAT + ARE + YOUR + PRIVACY + RIGHTS? +
+
+
+
+
+ In + Short:  + + + + + + Depending + on + your + state + of + residence + in + the + US + or + in + + + some + regions, + such + as + + + the + European + Economic + Area + (EEA), + United + Kingdom + (UK), + Switzerland, + and + Canada + + + , + you + have + rights + that + allow + you + greater + access + to + and + control + over + your + personal + information. + + +  You + may + review, + change, + or + terminate + your + account + at + any + time, + depending + on + your + country, + province, + or + state + of + residence. + + + + +
+
+
+
+
+ In + some + regions + (like + + + the + EEA, + UK, + Switzerland, + and + Canada + + + ), + you + have + certain + rights + under + applicable + data + protection + laws. + These + may + include + the + right + (i) + to + request + access + and + obtain + a + copy + of + your + personal + information, + (ii) + to + request + rectification + or + erasure; + (iii) + to + restrict + the + processing + of + your + personal + information; + (iv) + if + applicable, + to + data + portability; + and + (v) + not + to + be + subject + to + automated + decision-making. + In + certain + circumstances, + you + may + also + have + the + right + to + object + to + the + processing + of + your + personal + information. + You + can + make + such + a + request + by + contacting + us + by + using + the + contact + details + provided + in + the + section + + + " + + + HOW + CAN + YOU + CONTACT + US + ABOUT + THIS + NOTICE? + + + " + + + below. + +
+
+
+
+
+ We + will + consider + and + act + upon + any + request + in + accordance + with + applicable + data + protection + laws. + + + +
+
+   +
+
+ If + you + are + located + in + the + EEA + or + UK + and + you + believe + we + are + unlawfully + processing + your + personal + information, + you + also + have + the + right + to + complain + to + your + Member + State + data + protection + authority + or UK + data + protection + authority. +
+
+
+
+
+ If + you + are + located + in + Switzerland, + you + may + contact + the + Federal + Data + Protection + and + Information + Commissioner. +
+
+
+
+
+ Withdrawing + your + consent: + If + we + are + relying + on + your + consent + to + process + your + personal + information, + + + which + may + be + express + and/or + implied + consent + depending + on + the + applicable + law, + + + you + have + the + right + to + withdraw + your + consent + at + any + time. + You + can + withdraw + your + consent + at + any + time + by + contacting + us + by + using + the + contact + details + provided + in + the + section + + + " + + + HOW + CAN + YOU + CONTACT + US + ABOUT + THIS + NOTICE? + + + " + + + below + + + . + +
+
+
+
+
+ However, + please + note + that + this + will + not + affect + the + lawfulness + of + the + processing + before + its + withdrawal + nor, + + + when + applicable + law + allows, + + + will + it + affect + the + processing + of + your + personal + information + conducted + in + reliance + on + lawful + processing + grounds + other + than + consent. + + + +
+
+
+
+
+ Opting + out + of + marketing + and + promotional + communications: You + can + unsubscribe + from + our + marketing + and + promotional + communications + at + any + time + by + + + clicking + on + the + unsubscribe + link + in + the + emails + that + we + send, + + + + + + + or + by + contacting + us + using + the + details + provided + in + the + section + + + " + + + HOW + CAN + YOU + CONTACT + US + ABOUT + THIS + NOTICE? + + + " + + + below. + You + will + then + be + removed + from + the + marketing + lists. + However, + we + may + still + communicate + with + you + — + for + example, + to + send + you + service-related + messages + that + are + necessary + for + the + administration + and + use + of + your + account, + to + respond + to + service + requests, + or + for + other + non-marketing + purposes. + + + + + + + +
+
+
+
+
+ Account + Information +
+
+
+
+
+ If + you + would + at + any + time + like + to + review + or + change + the + information + in + your + account + or + terminate + your + account, + you + can: + + + +
+
    +
  • + + + Log + in + to + your + account + settings + and + update + your + user + account. + + +
    • +
+
+ + + + +
+
    +
  • + + + Contact + us + using + the + contact + information + provided. + + +
    • +
+
+ + + + +
+
+ Upon + your + request + to + terminate + your + account, + we + will + deactivate + or + delete + your + account + and + information + from + our + active + databases. + However, + we + may + retain + some + information + in + our + files + to + prevent + fraud, + troubleshoot + problems, + assist + with + any + investigations, + enforce + our + legal + terms + and/or + comply + with + applicable + legal + requirements. + + + + + + + + + + +
+
+
+
+
+ If + you + have + questions + or + comments + about + your + privacy + rights, + you + may + email + us + at + + support@openbeta.io + + . + + + + +
+
+
+
+
+ 9. + CONTROLS + FOR + DO-NOT-TRACK + FEATURES +
+
+
+
+
+ Most + web + browsers + and + some + mobile + operating + systems + and + mobile + applications + include + a + Do-Not-Track + ( + + + "DNT" + + + ) + feature + or + setting + you + can + activate + to + signal + your + privacy + preference + not + to + have + data + about + your + online + browsing + activities + monitored + and + collected. + At + this + stage, + no + uniform + technology + standard + for + + + recognizing + + + and + implementing + DNT + signals + has + been + + + finalized + + + . + As + such, + we + do + not + currently + respond + to + DNT + browser + signals + or + any + other + mechanism + that + automatically + communicates + your + choice + not + to + be + tracked + online. + If + a + standard + for + online + tracking + is + adopted + that + we + must + follow + in + the + future, + we + will + inform + you + about + that + practice + in + a + revised + version + of + this + Privacy + Notice. + + + + +
+
+
+
+
+ California + law + requires + us + to + let + you + know + how + we + respond + to + web + browser + DNT + signals. + Because + there + currently + is + not + an + industry + or + legal + standard + for + + + recognizing + + + or + + + honoring + + + DNT + signals, + we + do + not + respond + to + them + at + this + time. + + + + +
+
+ + + + +
+
+
+
+
+ 10. + DO + UNITED + STATES + RESIDENTS + HAVE + SPECIFIC + PRIVACY + RIGHTS? +
+
+
+
+
+ In + Short: If + you + are + a + resident + of + + + California, + Colorado, + Connecticut, + Delaware, + Florida, + Indiana, + Iowa, + Kentucky, + Minnesota, + Montana, + Nebraska, + New + Hampshire, + New + Jersey, + Oregon, + Tennessee, + Texas, + Utah, + or + Virginia + + + , + you + may + have + the + right + to + request + access + to + and + receive + details + about + the + personal + information + we + maintain + about + you + and + how + we + have + processed + it, + correct + inaccuracies, + get + a + copy + of, + or + delete + your + personal + information. + You + may + also + have + the + right + to + withdraw + your + consent + to + our + processing + of + your + personal + information. + These + rights + may + be + limited + in + some + circumstances + by + applicable + law. + More + information + is + provided + below. + +
+
+
+
+
+ Categories + of + Personal + Information + We + Collect +
+
+
+
+
+ We + have + collected + the + following + categories + of + personal + information + in + the + past + twelve + (12) + months: +
+
+
+
+ + + + + + + + + + + + + +
+ Category + + Examples + + Collected +
+
+ A. + Identifiers +
+ 		+
+ Contact + details, + such + as + real + name, + alias, + postal + address, + telephone + or + mobile + contact + number, + unique + personal + identifier, + online + identifier, + Internet + Protocol + address, + email + address, + and + account + name +
+ 		+
+
+
+
+ + + + + + YES + + + + + +
+
+
+
+
+
+ + +
+ + + + + + + + +
+
+ B. + Personal + information + as + defined + in + the + California + Customer + Records + statute +
+ 		+
+ Name, + contact + information, + education, + employment, + employment + history, + and + financial + information +
+ 		+
+
+
+
+ + + + + NO + + + + + + + + +
+
+
+
+
+
+ + +
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
+
+ + + + C + + + . + Protected + classification + characteristics + under + state + or + federal + law + +
+ 		+
+ Gender, + age, + date + of + birth, + race + and + ethnicity, + national + origin, + marital + status, + and + other + demographic + data +
+ 		+
+
+
+
+ + + + + + + NO + + + + + + +
+
+
+
+
+
+ + + + D + + + . + Commercial + information + +
+ 		+
+ Transaction + information, + purchase + history, + financial + details, + and + payment + information +
+ 		+
+
+
+
+ + + + + + + NO + + + + + + +
+
+
+
+
+
+ + + + E + + + . + Biometric + information + +
+ 		+
+ Fingerprints + and + voiceprints +
+ 		+
+
+
+
+ + + + + NO + + + + + + + + +
+
+
+
+
+
+ + + + F + + + . + Internet + or + other + similar + network + activity + +
+ 		+
+ Browsing + history, + search + history, + online + + + behavior + + + , + interest + data, + and + interactions + with + our + and + other + websites, + applications, + systems, + and + advertisements + +
+ 		+
+
+
+
+ + + + + + + NO + + + + + + +
+
+
+
+
+
+ + + + G + + + . + Geolocation + data + +
+ 		+
+ Device + location +
+ 		+
+
+
+
+ + + + + + + NO + + + + + + +
+
+
+
+
+
+ + + + H + + + . + Audio, + electronic, + sensory, + or + similar + information + +
+ 		+
+ Images + and + audio, + video + or + call + recordings + created + in + connection + with + our + business + activities +
+ 		+
+
+
+
+ + + + + + + NO + + + + + + +
+
+
+
+
+
+ + + + I + + + . + Professional + or + employment-related + information + +
+ 		+
+ Business + contact + details + in + order + to + provide + you + our + Services + at + a + business + level + or + job + title, + work + history, + and + professional + qualifications + if + you + apply + for + a + job + with + us +
+ 		+
+
+
+
+ + + + + + + NO + + + + + + +
+
+
+
+
+
+ + + + J + + + . + Education + Information + +
+ 		+
+ Student + records + and + directory + information +
+ 		+
+
+
+
+ + + + + + + NO + + + + + + +
+
+
+
+
+
+ + + + K + + + . + Inferences + drawn + from + collected + personal + information + +
+ 		+
+ Inferences + drawn + from + any + of + the + collected + personal + information + listed + above + to + create + a + profile + or + summary + about, + for + example, + an + individual’s + preferences + and + characteristics +
+ 		+
+
+
+
+ + + + NO + + + + +
+
+
+
+
+ + + + L + + + . + Sensitive + personal + Information + + + + + + +
+
+
+
+ + + + NO + + + +
+
+
+
+
+
+ + + +
+
+
+
+
+ We + may + also + collect + other + personal + information + outside + of + these + categories + through + instances + where + you + interact + with + us + in + person, + online, + or + by + phone + or + mail + in + the + context + of: + + + +
+
    +
  • + Receiving + help + through + our + customer + support + channels; + + + +
    • +
+
+ + + + +
+
    +
  • + Participation + in + customer + surveys + or + contests; + and + + + +
    • +
+
+ + + + +
+
    +
  • + Facilitation + in + the + delivery + of + our + Services + and + to + respond + to + your + inquiries. + + + +
    • +
+
+ + + + We + will + use + and + retain + the + collected + personal + information + as + needed + to + provide + the + Services + or + for: + + + +
+
    +
  • + Category + A + - + + As + long + as + the + user + has + an + account + with + us + + + + +
    • +
+
+ + + + + + +
+ + + + +
+ + + + +
+ + + + +
+ + + + +
+ + + + +
+ + + + +
+
    +
  • + Category + + + H + + + - + + As + long + as + the + user + has + an + account + with + us + + + + +
    • +
+
+ + + + +
+ + + + +
+ + + + +
+ + + + + + + +
+ Sources + of + Personal + Information +
+
+
+
+
+ Learn + more + about + the + sources + of + personal + information + we + collect + in + + + " + + + WHAT + INFORMATION + DO + WE + COLLECT? + + + " + + + + + +
+
+
+
+
+ How + We + Use + and + Share + Personal + Information +
+
+
+
+
+ + + + Learn + more + about + how + we + use + your + personal + information + in + the + section, + + + " + + + HOW + DO + WE + PROCESS + YOUR + INFORMATION? + + + " + + + + +
+
+
+
+
+ + + + +
+
+ Will + your + information + be + shared + with + anyone + else? +
+
+
+
+
+ We + may + disclose + your + personal + information + with + our + service + providers + pursuant + to + a + written + contract + between + us + and + each + service + provider. + Learn + more + about + how + we + disclose + personal + information + to + in + the + section, + + + " + + + WHEN + AND + WITH + WHOM + DO + WE + SHARE + YOUR + PERSONAL + INFORMATION? + + + " + + + +
+
+
+
+
+ We + may + use + your + personal + information + for + our + own + business + purposes, + such + as + for + undertaking + internal + research + for + technological + development + and + demonstration. + This + is + not + considered + to + be + + + "selling" + + + of + your + personal + information. + + + + +
+
+
+
+
+ We + have + not + disclosed, + sold, + or + shared + any + personal + information + to + third + parties + for + a + business + or + commercial + purpose + in + the + preceding + twelve + (12) + months. + We will + not + sell + or + share + personal + information + in + the + future + belonging + to + website + visitors, + users, + and + other + consumers. + + + + + + + + + +
+
+
+
+
+ Your + Rights +
+
+
+
+
+ You + have + rights + under + certain + US + state + data + protection + laws. + However, + these + rights + are + not + absolute, + and + in + certain + cases, + we + may + decline + your + request + as + permitted + by + law. + These + rights + include: + + + +
+
    +
  • + Right + to + know + whether + or + not + we + are + processing + your + personal + data + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + access your + personal + data + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + correct inaccuracies + in + your + personal + data + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + request + the + deletion + of + your + personal + data + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + obtain + a + copy of + the + personal + data + you + previously + shared + with + us + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + non-discrimination + for + exercising + your + rights + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + opt + out + of + the + processing + of + your + personal + data + if + it + is + used + for + targeted + advertising + + + (or + sharing + as + defined + under + California’s + privacy + law) + + + , + the + sale + of + personal + data, + or + profiling + in + furtherance + of + decisions + that + produce + legal + or + similarly + significant + effects + ( + + + "profiling" + + + ) + + + +
    • +
+
+ + + + +
+
+ Depending + upon + the + state + where + you + live, + you + may + also + have + the + following + rights: + + + +
+
    +
  • + Right + to + access + the + categories + of + personal + data + being + processed + (as + permitted + by + applicable + law, + including + Minnesota’s + privacy + law) + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + obtain + a + list + of + the + categories + of + third + parties + to + which + we + have + disclosed + personal + data + (as + permitted + by + applicable + law, + including + + + California's + and + Delaware's + + + privacy + law) + + + +
    • +
+
+ + + +
+
    +
  • + Right + to + obtain + a + list + of + specific + third + parties + to + which + we + have + disclosed + personal + data + (as + permitted + by + applicable + law, + including + + + Minnesota's + and + Oregon's + + + privacy + law) + + + + +
    • +
+
+ + + + +
+
    +
  • + Right + to + review, + understand, + question, + and + correct + how + personal + data + has + been + profiled + (as + permitted + by + applicable + law, + including + Minnesota’s + privacy + law) + + + +
    • +
+
+ + + +
+
    +
  • + Right + to + limit + use + and + disclosure + of + sensitive + personal + data + (as + permitted + by + applicable + law, + including + California’s + privacy + law) + + + +
    • +
+
+ + + +
+
    +
  • + Right + to + opt + out + of + the + collection + of + sensitive + data + and + personal + data + collected + through + the + operation + of + a + voice + or + facial + recognition + feature + (as + permitted + by + applicable + law, + including + Florida’s + privacy + law) + + + +
    • +
+
+ + + + +
+
+ How + to + Exercise + Your + Rights +
+
+
+
+
+ To + exercise + these + rights, + you + can + contact + us + + + by + submitting + a  + data + subject + access + request, + + + + + + by + emailing + us + at + + support@openbeta.io + + , + + + + + + + + + + + + + + or + by + referring + to + the + contact + details + at + the + bottom + of + this + document. + + + + + + +
+
+
+
+
+ Under + certain + US + state + data + protection + laws, + you + can + designate + an + + + authorized + + + agent + to + make + a + request + on + your + behalf. + We + may + deny + a + request + from + an + + + authorized + + + agent + that + does + not + submit + proof + that + they + have + been + validly + + + authorized + + + to + act + on + your + behalf + in + accordance + with + applicable + laws. +
+
+
+
+
+
+ Request + Verification +
+
+
+
+
+ Upon + receiving + your + request, + we + will + need + to + verify + your + identity + to + determine + you + are + the + same + person + about + whom + we + have + the + information + in + our + system. + We + will + only + use + personal + information + provided + in + your + request + to + verify + your + identity + or + authority + to + make + the + request. + However, + if + we + cannot + verify + your + identity + from + the + information + already + maintained + by + us, + we + may + request + that + you + provide + additional + information + for + the + purposes + of + verifying + your + identity + and + for + security + or + fraud-prevention + purposes. +
+
+
+
+
+ If + you + submit + the + request + through + an + + + authorized + + + agent, + we + may + need + to + collect + additional + information + to + verify + your + identity + before + processing + your + request + and + the + agent + will + need + to + provide + a + written + and + signed + permission + from + you + to + submit + such + request + on + your + behalf. + + + + +
+
+
+
+
+ Appeals +
+
+
+
+
+ Under + certain + US + state + data + protection + laws, + if + we + decline + to + take + action + regarding + your + request, + you + may + appeal + our + decision + by + emailing + us + at + + + + support@openbeta.io + + + + . + We + will + inform + you + in + writing + of + any + action + taken + or + not + taken + in + response + to + the + appeal, + including + a + written + explanation + of + the + reasons + for + the + decisions. + If + your + appeal + is + denied, + you + may + submit + a + complaint + to + your + state + attorney + general. + + + + + + + + + + + + +
+
+
+
+
+ California + + + "Shine + The + Light" + + + Law + +
+
+
+
+
+ California + Civil + Code + Section + 1798.83, + also + known + as + the + + + "Shine + The + Light" + + + law, + permits + our + users + who + are + California + residents + to + request + and + obtain + from + us, + once + a + year + and + free + of + charge, + information + about + categories + of + personal + information + (if + any) + we + disclosed + to + third + parties + for + direct + marketing + purposes + and + the + names + and + addresses + of + all + third + parties + with + which + we + shared + personal + information + in + the + immediately + preceding + calendar + year. + If + you + are + a + California + resident + and + would + like + to + make + such + a + request, + please + submit + your + request + in + writing + to + us + by + using + the + contact + details + provided + in + the + section + + + " + + + HOW + CAN + YOU + CONTACT + US + ABOUT + THIS + NOTICE? + + + " + + + + + + + + + + + + + + + + + + + + + + + + +
+
+
+
+
+ 11. + DO + WE + MAKE + UPDATES + TO + THIS + NOTICE? +
+
+
+
+
+ In + Short: Yes, + we + will + update + this + notice + as + necessary + to + stay + compliant + with + relevant + laws. +
+
+
+
+
+ We + may + update + this + Privacy + Notice + from + time + to + time. + The + updated + version + will + be + indicated + by + an + updated + + + "Revised" + + + date + at + the + top + of + this + Privacy + Notice. + If + we + make + material + changes + to + this + Privacy + Notice, + we + may + notify + you + either + by + prominently + posting + a + notice + of + such + changes + or + by + directly + sending + you + a + notification. + We + encourage + you + to + review + this + Privacy + Notice + frequently + to + be + informed + of + how + we + are + protecting + your + information. + +
+
+
+
+
+ 12. + HOW + CAN + YOU + CONTACT + US + ABOUT + THIS + NOTICE? +
+
+
+
+
+ If + you + have + questions + or + comments + about + this + notice, + you + may + + + + + + email + us + at + + support@openbeta.io + + + + + + +
+
+
+
+
+ 13. + HOW + CAN + YOU + REVIEW, + UPDATE, + OR + DELETE + THE + DATA + WE + COLLECT + FROM + YOU? +
+
+
+
+
+ + + + Based + on + the + applicable + laws + of + your + country + + + or + state + of + residence + in + the + US + + + , + you + may + + + have + the + right + to + request + access + to + the + personal + information + we + collect + from + you, + details + about + how + we + have + processed + it, + correct + inaccuracies, + or + delete + your + personal + information. + You + may + also + have + the + right + to + + + withdraw + your + consent + to + our + processing + of + your + personal + information. + These + rights + may + be + limited + in + some + circumstances + by + applicable + law. + To + request + to + review, + update, + or + delete + your + personal + information, + please + + + fill + out + and + submit + a  + + + data + subject + access + request + + + + . +
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+ + + \ No newline at end of file