Privacy Policy of Preparity platform (the “Privacy Policy”)

Last updated: October 12, 2020

This Privacy Policy describes our policies and procedures on collection, use, transfer and disclosure of the personal data related to your use of the Platform and the Services, as well as describes the basis on which any personal data we collect from you, or that you provide us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We use your personal data to provide and improve the Platform and the Services. By accessing or using this Platform you agree to be bound by this Privacy Policy.

1.     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.

2.     Definitions

For the purposes of this Privacy Policy:

“Company” (referred to as either "the Company", "we", "us" or "our") means to Preparity OÜ; Sepapaja 6, Tallinn 15551, Republic of Estonia;

“Consumer”, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA forother than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose;

“Content” means any information, including but not limited to training materials, text, images, figures, charts, means of communications, articles, web-links, entertainment and other services, which the Company provides at the Platform or its associated subdomains;

“Cookies” mean small files that are placed on your computer, mobile device or any other device by a Platform, containing the details of your browsing history on that Platform;

“Data Controller”, for the purposes of the GDPR (General Data Protection Regulation), means the company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For the purpose of the GDPR, the Company is the Data Controller;

“Device” means any device that can access the Platform such as a computer, a cellphone or a digital tablet;

Do Not Track” (DNT) means 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;

“Facebook Fan Page” means a public profile specifically created by the Company on the Facebook social network;

“Personal Data” means any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you;

“Platform” means the online service platform Preparity, that is available at the website https://preparity.com/ and mobile device application https://app.preparity.com;

“Sale”, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration;

“Services” mean the online services related to assistance with preparation to consulting industry tests, which are available for the Users at the Platform at each particular period of time. The Services, inter alia, comprise the following services:

  • generating tests based on question databases that are close to the original tests used in specialized companies;
  • generating user-customized tests from question databases based on a system of specialized criteria;
  • training test materials and tracking the User's productivity statistics;
  • providing an online-meetings where Users and coaches can communicate with each other;
  • taking advantage of paid collaboration services for problem-solving training and other related topics;

“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 arranged by the Company to facilitate the Platform and the Services, to provide and assist with providing the Services on behalf of the Company, as well as to assist the Company in analyzing how the Platform is used. For the purpose of the GDPR, Service Providers are considered Data Processors;

“Third-party Social Media Service” means any website or any social network website via which the User can log in or create an account to use the Platform;

“Usage Data” means data collected automatically, either generated by the use of the Platform or from the Platform’s infrastructure itself (for example, the duration of a page visit);

“User (or you, etc.)” means an individual who accesses or uses the Platform and the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform and the Services, as applicable. Under GDPR (General Data Protection Regulation), you can be referred to as the data subjector as the User as you are the individual using the Platform;

“Visitor” means an individual who visits the Platform without registering or authorizing itself as a User.

3.     Collecting and Using Your Personal Data

3.1.        Collected Data

Personal Information

3.1.1.    Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience better and easier. While using our Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • email address;
  • first name and last name;
  • phone number;
  • address, state, province, ZIP/postal code, city;
  • bank account information required for purposes of payment for the use of the Platform and the Services;
  • Usage Data;
  • age;
  • gender;
  • country of residence;
  • education level and educational institution;
  • profile photo (avatar).

3.1.2.    When you make a payment with respect to the Services via bank transfer, we may ask you to provide information to facilitate this transaction and to verify your identity. Such information may include, without limitation:

  • date of birth;
  • passport or national ID card;
  • payment method;
  • bank card statement;
  • other information linking you to an address.

Usage Data

3.1.3.     Usage Data is collected automatically when you use the Platform and the Services.

3.1.4.     Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), type of your Device, browser type, browser version, the pages of the Platform that you visit, the time and date of your visit, the timespent on those pages, unique device identifiers and other diagnostic data.

3.1.5.     When you use the Platform by or via 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.

3.1.6.     We may also collect information that your browser sends whenever you visit the Platform or when you access the Platform by or via a mobile Device.

Information from Third-Party Social Media Services

3.1.7.    The Company allows you to create an account and log in to use the Platform and the Services via the following Third-party Social Media Services:

  • Google
  • Facebook

3.1.8.     If you decide to register at the Platform via a Third-Party Social Media Service or otherwise grant us access there to, we may collect Personal Data that is already associated with your Third-Party Social Media Service's account, such as your name, your email address, your activities or your contact list associated with that account.

3.1.9.     You may also have the option of sharing additional information with the Company via your Third-Party Social Media Service's account. If you choose to provide such information and Personal Data, during registration or otherwise, you agree to provide the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

3.1.10.  We use Cookies and similar tracking technologies to track the activity on the Platform and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the use of the Platform.

3.1.11.  You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Platform.

3.1.12.  Cookies can be "persistent" or "session" Cookies. Persistent Cookies remain on your personal computer or mobile Device when you go offline, while session Cookies are deleted as soon as you close your web browser. Learn more about cookies: All About Cookies, available at: https://www.termsfeed.com/blog/cookies/.

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

    Necessary / Essential / Strictly Necessary Cookies

Type: Session Cookies

Administered by: us

Purpose: These Cookies are essential to provide you with the Services available at the Platform and to enable you to use some of its features. They help to authenticate Users and prevent fraudulent use of Users’ accounts. Without these Cookies, the Services that you have asked for cannot be provided, and we only use these Cookies in order to provide you with those Services.

    Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: us

Purpose: These Cookies identify if Users have accepted the use of Cookies on the Platform.

    Functionality Cookies

Type: Persistent Cookies

Administered by: us

Purpose: These Cookies allow us to remember choices you make when you use the Platform, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Platform.

    Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: third parties

Purpose: These Cookies areused to track information with respect to traffic to the Platform and how Users use the Platform. The information gathered via these Cookies may directly or indirectly identify you as an individual Visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the Device you use to access the Platform. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Platform to see howour Users react to them.

    Targeting and Advertising Cookies

Type: Persistent Cookies

Administered by: third parties

Purpose: These Cookies are used to demonstrate advertising that is likely to be of interest to you based on your browsing habits. These Cookies, as served by our Content and/or advertising providers, may combine information they collected from the Platform with other information they have independently collected relating to your web browser's activities across the network of websites. If you choose to remove or disable these targeting or advertising Cookies, you will still see advertising, but they may not be relevant to you.

Your Choices Regarding Cookies

3.1.14.  If You prefer to avoid the use of Cookies on the Platform, first you must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this Platform. You may use this option for preventing the use of Cookies at any time.

3.1.15.   If You do not accept our Cookies, you may experience some inconvenience in your use of the Platform and some features may not function properly.

3.1.16.  If You'd like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the help pages of your web browser.

3.1.17. You can learn more about cookies: https://www.termsfeed.com/blog/cookies/

3.1.18. If you have any questions about this Cookies Policy, You can contact us by email: dpo@preparity.com/

3.2.        Use of Your Personal Data

3.2.1.     The Company may use Personal Data for the following purposes:

  • to provide access to and maintain functioning of the Platform, including to monitor using of the Services.
  • to manage your account: to manage your registration as the User of the Platform. Your Personal Data can provide you access to different functionalities of the Platform that are available to you as a registered User.
  • for the performance of a contract: fulfillment, compliance with and securing performance of the contract, under which you acquire the Services or any other contract with us entered into at the Platform or in connection with using the Services.
  • to contact you: to contact you by email, or other equivalent forms of electronic communication, such as 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 offerd products, services and events which 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.

3.2.2.     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 the Platform, in connection of payment processing or communication with you.
  • for business transfers: We reserve the right to 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 aportion of our business to another company.
  • with affiliates: We may share Your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • with Business partners: We may share your information with our business partners to offer you certain products, services or promotions.
  • with other Users: when you share personal information or otherwise interact in the public areas with other Users, such information may be viewed by all Users and may be publicly distributed outside. If you interact with other Users or register via Third-Party Social Media Service, your contacts at such Third-Party Social Media Service may have access to your name, profile, pictures and description of your activity. Similarly, other Users will be able to view description of your activity, communicate with you and view yourprofile.

3.3.        Retention of Your Personal Data

3.3.1.     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.

3.3.2.     The Company will also retain Usage Data for internal analysis purposes. Usage Datais generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Platform, or we are legally obligated to retain this data for longer time periods.

3.4.        Transfer of Your Personal Data

3.4.1.     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. By using the Platform you expressly provide consent for such transfer of the information, even if any such place of collection or storage of your information has more rigorous data protection standards.

3.4.2.     The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

3.5.        Disclosure of Your Personal Data

Business Transactions

3.5.1.    If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide you the notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

3.5.2.    Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law orin response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

3.5.3.    The Company reserves the rights todisclose your Personal Data in reasonable belief that such action is necessary to:

  • comply with alegal obligation;
  • protect and defend the rights or property of the Company;
  • prevent or investigate possible wrong doing in connection with the Platform and the use of the Services;
  • protect the personal safety of Users or the public;
  • obtain protect against legal liability.

3.6.        Security of Your Personal Data

3.6.1.     We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receiveit.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

3.7.        Detailed Information on the Processing of Your Personal Data

3.7.1.     Service Providers have access to your Personal Data only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

3.7.2.    We may use Third-Party Service Providers to monitor and analyze the use of our Platform.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports Platform traffic. Google uses the data collected to track and monitor the use of our Platform. 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 Platform 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

Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile Device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245

For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Matomo

Matomo is a web analytics service. You can visit their privacy policy page here: https://matomo.org/privacy-policy

Clicky

Clicky is a web analytics service. Read the privacy policy for Clicky here: https://clicky.com/terms

Statcounter

Statcounter is a web traffic analysis tool. You can read the privacy policy for Statcounter here: https://statcounter.com/about/legal/

Flurry Analytics

Flurry Analytics service is provided by Yahoo! Inc.

You can opt-out from Flurry Analytics service to prevent Flurry Analytics from using and sharing your information by visiting the Flurry's Opt-out page: https://developer.yahoo.com/flurry/end-user-opt-out/

For more information on the privacy practices and policies of Yahoo!, please visit their privacy policy page: https://policies.yahoo.com/xa/en/yahoo/privacy/index.htm

Mixpanel

Mixpanel is provided by Mixpanel Inc.

You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/

For more information on what type of information Mixpanel collects, please visit the terms of use page of Mixpanel: https://mixpanel.com/terms/

Unity Analytics

Unity Analytics is provided by Unity Technologies.

For more information on what type of information Unity Analytics collects, please visit their privacy policy page: https://unity3d.com/legal/privacy-policy

Hotjar

Their privacy policy can be viewed at https://www.hotjar.com/legal/policies/privacy/

Google Tag Manager

Their privacy policy can be viewed at https://policies.google.com/privacy

TheChecker

Their privacy policy can be viewed at https://thechecker.co/privacy-policy

Email Marketing

3.7.3.    We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use third party email marketing Service Providers to manage and send emails to you.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

AWeber

AWeber is an email marketing sending service provided by AWeber Communications.

For more information on the privacy practices of AWeber, please visit their Privacy policy: https://www.aweber.com/privacy.htm

GetResponse

GetResponse is an email marketing sending service provided by GetResponse.

For more information on the privacy practices of GetResponse, please visit their Privacy policy: https://www.getresponse.com/legal/privacy.html

MailJet

Their Privacy Policy can be viewed at https://www.mailjet.com/privacy-policy/

Zendesk

Their Privacy Policy can be viewed at https://www.zendesk.com/company/customers-partners/privacy-policy/

4.     Payments

4.1.        The Company may provide the Services at the Platform on the paid basis. In that case, we may use third-party services for payment processing (e.g. payment processors).

4.2.        We will not collect or disclose your payment card details. We provide such information directly to our third-party payment processors, which collect and use your Personal Data in accordance with their relevant Privacy Policies. 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.

Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

WePay

Their Privacy Policy can be viewed at https://go.wepay.com/privacy-policy

WorldPay

Their Privacy Policy can be viewed at https://www.worldpay.com/en-gb/privacy-policy

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Braintree

Their Privacy Policy can be viewed at https://www.braintreepayments.com/legal/braintree-privacy-policy

FastSpring

Their Privacy Policy can be viewed at http://fastspring.com/privacy/

2Checkout

Their Privacy Policy can be viewed at https://www.2checkout.com/policies/privacy-policy

Sage Pay

Their Privacy Policy can be viewed at https://www.sagepay.co.uk/policies

Square

Their Privacy Policy can be viewed at https://squareup.com/legal/privacy-no-account

Go Cardless

Their Privacy Policy can be viewed at https://gocardless.com/en-eu/legal/privacy/

Elavon

Their Privacy Policy can be viewed at https://www.elavon.com/privacy-pledge.html

Verifone

Their Privacy Policy can be viewed at https://www.verifone.com/en/us/legal

Moneris

Their Privacy Policy can be viewed at https://www.moneris.com/en/Privacy-Policy

WeChat

Their Privacy Policy can be viewed at https://www.wechat.com/en/privacy_policy.html

Alipay

Their Privacy Policy can be viewed at https://render.alipay.com/p/f/agreementpages/alipayglobalprivacypolicy.html

LHV

Their Privacy Policy can be viewed at https://www.lhv.ee/en/principles-of-processing-customer-data

TransferWise

Their Privacy Policy can be viewed at https://transferwise.com/ru/privacy-policy

4.3.        When you pay for the Services at the Platform via bank transfer, we may ask you to provide information to facilitate this transaction and to verify your identity.

5.     Usage, Performance and Miscellaneous

5.1.        We may use third-party Service Providersto improve functioning of the Platform and the use of the Services.

Mouseflow

Mouseflow is a session replay and heatmap tool that shows how visitors click, move, scroll, browse, and pay attention at the Platform. This service is operated by ApS.

Mouseflow service may collect information from your Device.

The information gathered by Mouseflow is held in accordance with its Privacy Policy: https://mouseflow.com/privacy/

FreshDesk

FreshDesk is a customer support software. The service is operated by Freshworks, Inc.

FreshDesk service may collect information from your Device.

The information gathered by FreshDesk is held in accordance with its Privacy Policy: https://www.freshworks.com/privacy/

Hotjar

Their Privacy Policy can be viewed at https://www.hotjar.com/legal/policies/privacy/

6.     GDPR Privacy Regime

6.1.        Legal Basis for Processing Personal Data under GDPR

6.1.1.     We may process Personal Data under the following conditions:

  • consent: you provide your consent with respect of processing your Personal Data for one or more specific purposes, set out in this Privacy Policy.
  • performance of a contract:  processing Personal Data is necessary for purposes of performance under a contract with you and/or for any pre-contractual obligations thereunder.
  • legal obligations: processing Personal Data is necessary for purposes of compliance with Company’s legal obligations.
  • vital interests: processing Personal Data is necessary for purposes of protection your or another individual’s vital interests.
  • 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 PersonalData is necessary for purposes of the legitimate interests pursued by the Company.

6.1.2.     If you have any questions or suggestions regarding exercise of your rights in connection with processing your Personal Data under the GDPR, please feel freecontact us at: dpo@preparity.com.

6.2.        Your Rights under the GDPR

6.2.1.     The Company undertakes to respect the confidentiality of your Personal Data and to take all reasonable efforts to procure the exercise of your rights on use and protection of your Personal Data.

6.2.2.     If you are within the EU, you are entitled under this Privacy Policy and under the relevant statutory provisions:

  • to request for access to your Personal Data. The right to access, request to correct or erase your personal information. You have the right to access, to correct or erase your Personal Data directly via our customer support service. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data that is held about you by the Company.
  • to request for correction of the Personal Data. You have the right to request correction of any personal information that is that is held about you by the Company.
  • to object processing your Personal Data. You have the right to object to the processing of your Personal Data on grounds relating to your particular situation and ask the Company to stop processing your Personal Data if is being processed for the purpose of direct marketing, the Company’s own legitimate interest or in carrying out a task in the public interest/for an official authority.
  • to request erasure of your Personal Data. You have the right to ask us to erase or remove your Personal Data when there is no sufficient reason for us to continue processing it.
  • to request transfer of your Personal Data. We will provide to you, or to a third-party that you have chosen, your Personal Data ina structured, commonly used, machine-readable format. Please note that this right only applies to automated information, for that you initially provided consent to use it, or where we used the information to perform a contract with you.
  • to 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 Platform.

6.2.3.     You may exercise your rights of access, correction, withdrawal, and objection by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will take all reasonable efforts to provide a response as soon as possible.

6.2.4.     You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. If you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

6.3.        Facebook Fan Page

Data Controller for the Facebook Fan Page

6.3.1.     The Company is the Data Controller of your Personal Data collected while using the Platform. As operator of the Facebook Fan Page, the Company and the operator of the social network Facebook shall be deemed as Joint Controllers.

6.3.2.     The Company entered into contract with Facebook that defines, inter alia, the terms for use of the Facebook Fan Page. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

6.3.3.     Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal Data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road,Menlo Park, CA 94025, United States.

6.4.        Facebook Insights

6.4.1.     We use the Facebook insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about the Users.

6.4.2.     For this purpose, Facebook places a Cookie on the Device of the User visiting our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end ofthis period.

6.4.3.     Facebook receives, records and processes the information stored in the Cookie, especially when the User visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

6.4.4.      For more information on the privacy practicesof Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

7.     CCPA Privacy

7.1.        Your Rights under the CCPA

7.1.1.     If you are a resident of California, you have the following rights under this Privacy Policy and the relevant statutory provisions:

The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.

The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.

The right to know about your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:

  • the categories of the Personal Data collected;
  • the sources from which the Personal Data was collected;
  • the business or commercial purpose for collecting or selling the Personal Data;
  • categories of third parties, with whom we share the Personal Data;
  • the specific pieces of the Personal Data we collected about you;

The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer's rights, including by:

  • denying goods orservices to you;
  • charging different prices or rates for goods or services, including the use of discountsor other benefits or imposing penalties;
  • providing a different level or quality of goods or services to you;
  • suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

7.2.        Exercising Your CCPA Data Protection Rights

7.2.1.     In order to exercise any of your rights under the CCPA, and if you are a California resident, You can email or contact us within our customer support service.

7.2.2.     The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

7.3.        Do Not Sell My Personal Information

7.3.1.     We do not sell personal information. However, the Service Providers, with which we have partnership relationships (for example, our advertising partners) may use technology at the Platform that sells personal information as defined by the CCPA law.

7.3.2.     If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales, as defined under CCPA law, you may do so by following the instructions below.

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

7.4.        Platform

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

  • From Our "Cookie Consent" notice banner

7.4.2.     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.

8.     "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

8.1.        Our Platform does not respond to Do Not Track signals.

8.2.        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.

9.     Your California Privacy Rights (California's Shine the Light law)

9.1.        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.

9.2.        If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

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

10.1.      California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

10.2.      To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.

10.3.      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.

10.4.      The Company does not intentionally, or knowingly, process personal information from individuals under the age of 18. When necessary, Users under the age of 18 will be told not to submit any personal details. We will make every effort to delete any details of such Users where a parent or guardian has informed us that these details have been collected. If you are under the age of 18 and a registered user of our Platform, you may request that we remove content and information that you post on our Platform. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to dpo@preparity.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, since the content and information may remain in our databases, may remain visible in a manner that does notidentify you, or may have been re-posted by another user. There may be other circumstances in which applicable laws do not require or allow removal even if requested.

11.  Links to Other Platforms

11.1.      Our Platform 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.

11.2.      We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

12.  Changes to this Privacy Policy

12.1.      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.

12.2.      We will let you know via email and/or a prominent notice on Our Platform, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

12.3.      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.

12.4.      This Privacy Policy may be modified at any time; the date of the most recent changes or revisions will appear on this page. Your continued use of our Platform will constitute your acceptance of any changes or revisions to the Privacy Policy on this page. If you do not agree to the Privacy Policy, please do not use this Platform.

12.5.      We reserve the right to amend this Privacy Policy at our sole discretion. Major changes to the Privacy Policy will be posted on the Platform or included in an email notification to you. It is therefore important that you keep your contact data up to date.

13.  Contact Us

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