Privacy Policy

International Shades of Beauty Privacy Policy 

Last updated: June 08, 2021 

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 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 


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. 


For the purposes of this Privacy Policy: 

Account means a unique account created for You to access our Service or parts of  our Service. 

Business, for the purpose of the CCPA (California Consumer Privacy Act), 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. Company (referred to as either “the Company”, “We”, “Us” or “Our” in this  Agreement) refers to Pearls Management LLC, 4075 Linglestown Rd, Suite 126,  Harrisburg, PA 17112. 

For the purpose of the GDPR, the Company is the Data Controller. 

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 for other 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. 

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: Pennsylvania, 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. 

Personal Data is 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. 

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. 

Service refers to the Website. 

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. For the purpose of the GDPR, Service Providers  are considered Data Processors. 

Third-party Social Media Service refers to any website or any social network  website through which a User can log in or create an account to use the Service. 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 International Shades of Beauty, accessible from 

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. 

Under GDPR (General Data Protection Regulation), You can be referred to as the  Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data 

Types of Data Collected 

Personal Data 

While using Our Service, 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 in order to pay for products and/or services within the  Service 

Usage Data 

When You pay for a product and/or a service 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 
  • Bank card statement 
  • Other information linking You to an address 

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.

Information from Third-Party Social Media Services 

The Company allows You to create an account and log in to use the Service through the  following Third-party Social Media Services: 

  • Google 
  • Facebook 
  • Twitter 

If You decide to register through or otherwise grant us access to a Third-Party Social Media  Service, 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. 

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

Tracking Technologies and Cookies 

We use Cookies and similar tracking technologies to track the activity on Our Service and  store certain information. Tracking technologies used are beacons, tags, and scripts to  collect and track information and to improve and analyze Our Service. The technologies We  use may include: 

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. 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  Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies. 
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash  Cookies) to collect and store information about Your preferences or Your activity on our  Service. Flash Cookies are not managed by the same browser settings as those used for  Browser Cookies. For more information on how You can delete Flash Cookies, please  read “Where can I change the settings for disabling, or deleting local shared objects?”  available at flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_sha red_objects_ 
  • Web Beacons. Certain sections of our Service and our emails may contain small  electronic files known as web beacons (also referred to as clear gifs, pixel tags, and  single-pixel gifs) that permit the Company, for example, to count users who have visited  those pages or opened an email and for other related website statistics (for example,  recording the popularity of a certain section and verifying system and server integrity). 

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: Cookies: What Do They  Do?. 

We use both Session and Persistent Cookies for the purposes set out below: 

Necessary / Essential Cookies 

Type: Session Cookies 

Administered by: Us 

Purpose: These Cookies are essential to provide You with services available through  the Website and to enable You to use some of its features. They help to authenticate  users and prevent fraudulent use of user accounts. Without these Cookies, the  services that You have asked for cannot be provided, and We only use these Cookies  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  Website. 

Functionality Cookies 

Type: Persistent Cookies 

Administered by: Us 

Purpose: These Cookies allow us to remember choices You make when You use the  Website, 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 Website. Tracking and Performance Cookies 

Type: Persistent Cookies 

Administered by: Third-Parties 

Purpose: These Cookies are used to track information about traffic to the Website  and how users use the Website. 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 Website. We may also use these Cookies to test  new pages, features or new functionality of the Website to see how our users react  to them. 

For more information about the cookies we use and your choices regarding cookies, please  visit our Cookies Policy or the Cookies section of our Privacy Policy. 

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. 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, 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, 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 through a Third Party Social Media Service, Your contacts on the Third-Party Social Media Service may 

see Your name, profile, pictures and description of Your activity. Similarly, other users  will be able to view descriptions of Your activity, communicate with You and view Your  profile. 

  • With Your consent: We may disclose Your personal information for any other purpose  with Your consent. 

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. 

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. 

Disclosure of Your Personal Data 

Business Transactions 

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be  transferred. We will provide notice before Your Personal Data is transferred and becomes  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. While We  strive to use commercially acceptable means to protect Your Personal Data, We cannot  guarantee its absolute security. 

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. 


We may use third-party Service providers to monitor and analyze the use of our Service. 

Google Analytics 

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: 

Email Marketing 

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 Email Marketing Service Providers to manage and send emails to You. 


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: 


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. 


Their Privacy Policy can be viewed at 


Their Privacy Policy can be viewed at 


Their Privacy Policy can be viewed at account 

When You use Our Service to pay a product and/or service via bank transfer, We may ask  You to provide information to facilitate this transaction and to verify Your identity. 

GDPR Privacy 

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. 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the  processing, and in particular whether the provision of Personal Data is a statutory or  contractual requirement, or a requirement necessary to enter into a contract. 

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 under this Privacy Policy, and by law if You are within the EU, to: 

  • Request 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. 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 We hold about You. 
  • Request 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. • Object to 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 object where We are processing  Your Personal Data for direct marketing purposes. 
  • Request 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. • Request the transfer of Your Personal Data. We will provide to You, or to a third party You have chosen, 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 

You may exercise Your rights of access, rectification, cancellation and opposition 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 try our best to respond to You as soon as  possible. 

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 Privacy 

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

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. 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. 

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. 

Category B: Personal information categories listed in the California Customer  Records statute (Cal. Civ. Code § 1798.80(e)). 

Examples: A name, signature, Social Security number, physical characteristics or  description, address, telephone number, 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. Some personal information included in this category may overlap with  other categories. 

Collected: Yes. 

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: No. 

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: No. 

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.

Under CCPA, personal information does not include: 

  • Publicly available information from government records 
  • Deidentified or aggregated consumer information 
  • Information excluded from the CCPA’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 for payment processing, or other third-party  vendors that We use to provide the Service to You. 

Use of Personal Information for Business Purposes or Commercial Purposes We may use or disclose personal information We collect for “business purposes” or  “commercial purposes” (as defined under the CCPA), 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. 
  • 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. 

Please note that 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 for Business Purposes or Commercial  Purposes 

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. 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. 

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. 

Sale of Personal Information 

As defined in the CCPA, “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.

Please note that the categories listed below are those defined in the CCPA. 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. 

We may sell and may have sold in the 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 

Share of Personal Information 

We may share 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 

Sale of Personal Information of Minors Under 16 Years of Age We do not knowingly collect personal information from minors under the age of 16 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. 

We do not sell the personal information of Consumers We actually know are less than 18  years of age, unless We receive affirmative authorization (the “right to opt-in”) from either  the Consumer who is between 13 and 16 years of age, or the parent or guardian of a  Consumer less than 13 years of age. Consumers who opt-in to the sale of personal  information may opt-out of future sales at any time. To exercise the right to opt-out, You (or  Your authorized representative) may submit a request to Us by contacting Us. 

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with  personal information, please contact Us with sufficient detail to enable Us to delete that  information.

Your Rights under the CCPA 

The CCPA provides California residents with specific rights regarding their personal  information. If You are a resident of California, You have the following rights: 

  • 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. • The right to request. Under CCPA, 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. Once We receive and confirm Your request, We will  disclose to You:  
  • The categories of personal information We collected about You 
  • The categories of sources for the personal information We collected about You • Our business or commercial purpose for collecting or selling that personal  information 
  • The categories of third parties with whom We share that personal information • The specific pieces of personal information We collected about You • If we sold Your personal information or disclosed Your personal information for a  business purpose, We will disclose to You:  
  • The categories of personal information categories sold 
  • The categories of personal information categories disclosed 
  • The right to say no to the sale of Personal Data (opt-out). You have the right to  direct Us to not sell Your personal information. To submit an opt-out request please  contact Us. 
  • The right to delete Personal Data. You have the right to request the deletion of Your  Personal Data, subject to certain exceptions. Once We receive and confirm Your request,  We will delete (and direct Our Service Providers to delete) Your personal information  from our records, unless an exception applies. We 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, including by:  
  • Denying goods or services to You 
  • Charging different prices or rates for goods or services, including the use of  discounts or 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 

Exercising Your CCPA Data Protection Rights 

In order to exercise any of Your rights under the CCPA, and if You are a California resident,  You can contact Us: 

By email: 

By visiting this page on our website: 

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 

We 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. 

Any disclosures We provide will only cover the 12-month period preceding the verifiable  request’s receipt. 

For data portability requests, We will select a format to provide Your personal information  that is readily useable and should allow You to transmit the information from one entity to  another entity without hindrance. 

Do Not Sell My Personal Information 

You have the right to opt-out of the sale of Your personal information. Once We receive and  confirm a verifiable consumer request from You, we will stop selling Your personal  information. To exercise Your right to opt-out, please contact Us. 

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  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 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 need to opt out on  every browser that You use. 


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: • The EDAA’s opt-out platform • The DAA’s opt-out platform: 

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.

“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. 

Children’s Privacy 

Our Service does not address anyone under the age of 13. We do not knowingly collect  personally identifiable information from anyone under the age of 13. If You are a parent or  guardian and You are aware that Your child has provided Us with Personal Data, please  contact Us. If We become aware that We have collected Personal Data from anyone under  the age of 13 without verification of parental consent, We 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. 

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 information provided below.

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

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. 

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. 

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 contact us: 

By email: 

By visiting this page on our website: