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Privacy Policy

Effective Date: January 01, 2024

We are software development company Roximus Limited (“We“, “Us“, “Company“) and we are committed to safeguarding your privacy and ensuring the secure and responsible use of your personal information. This Privacy Policy is designed to inform you about the types of information we collect, how we use it, and the measures we take to protect your data while you enjoy the exciting features offered by ArtLab AI. Your trust is of utmost importance to us, and we are dedicated to providing transparency regarding our data practices.

Before accessing our Website at https://ai-art-gen.com/ or using the app (collectively referred to as the "Services," which encompass the Website and App “ArtLab AI”), please take a moment to read this policy carefully. If you do not agree with the terms outlined in this Privacy Policy, we kindly ask you to stop using the app immediately. Your continued use of ArtLab AI implies your acceptance of the terms and conditions outlined in this Privacy Policy.

If you have any questions, please contact us:

  • Roximus Limited, registration number HE353633, (“Contractor”), with its principal place of business registered at Pentelis, 16, 2401, Nicosia, Cyprus
  • Email: [email protected].

1. Data Subject, Data Controller and Data processors

1.1. Users as Data Subjects:

As users of our Website and/or the App, you are recognized as data subjects under the General Data Protection Regulation (GDPR). This means that any information we collect about you, whether personal or non-personal, is treated with the utmost respect and in compliance with applicable data protection laws. Your rights regarding the control and processing of your data are of significant importance to us.

1.2. Roximus Limited as Data Controller:

Roximus Limited, the developer and publisher of the App and the owner of the Website, assumes the role of the data controller. This implies that we determine the purposes and means of processing the personal data collected through the app. We are committed to handling your data responsibly, ensuring its security, and adhering to the principles outlined in this Privacy Policy.

1.3. Data Processors:

To enhance your experience and provide you with the best possible service, we may share certain information with third-party providers, affiliated entities, contractors, government entities, and authorities, collectively referred to as data processors. These entities are entrusted with specific tasks related to hosting, maintenance, analytics, marketing, or compliance with legal requirements.

We want to emphasize that any sharing of information is conducted in strict compliance with applicable data protection laws. We take comprehensive measures to ensure that these data processors handle your information with the same level of care, confidentiality, and security as we do. It is important to note that we do not sell your personal information to third parties for any purpose.

When processing your data, we may use the following data processors:

Name Services Type of shared data Location Privacy policy
AppsFlyer Ltd. Analytics and marketing service provider Tracker; Usage Data USA https://www.appsflyer.com/legal/privacy-policy/
Amplitude, Inc. Analytics and marketing service provider Tracker; Usage Data USA https://amplitude.com/privacy
Google Inc. Firebase Cloud Messaging IP addresses, mobile device UUID, the user's Powertech Multi-Factor Authentication ID, a function ID. USA https://firebase.google.com/support/privacy?hl=en
Facebook (Meta Platforms, Inc.) Analytics and marketing service provider Tracker; Usage Data USA https://www.facebook.com/business/m/privacy-and-data
TikTok Inc. Analytics and marketing service provider Tracker; Usage Data USA https://www.tiktok.com/community-guidelines/en/privacy-security/
AppLovin Corporation App monetization solution Device information USA https://www.applovin.com/privacy/
Stability AI LTD AI-generated content provider User's text request or user’s uploaded photo England https://stability.ai/privacy-policy

1.3.1. Stability AI Integration

Our App is powered by the Stable Diffusion AI platform developed by Stability AI and released under a Creative ML OpenRAIL-M license, which means that when you interact with our App and make requests, your input and queries are processed by the Stable Diffusion AI. This is essential for providing the advanced features and services that our App offers.

We encourage you to take a moment to familiarize yourself with Stable Diffusion AI's privacy policy. This will provide you with comprehensive insights into how Stable Diffusion AI manages and protects your information. Your understanding of their practices is crucial to ensuring a transparent and secure experience while using our App.

1.3.2. International Data Transfer

In the event of transferring personal data from the European Economic Area (EEA) to countries lacking an adequate level of data protection, we rely on one of the following legal bases: (i) Implementation of Standard Contractual Clauses approved by the European Commission, or (ii) Adherence to adequacy decisions made by the European Commission regarding specific countries (details accessible here).

2. Your data that we collect and process

Information You Provide Us Directly
Visual and text records The app processes images or text requests you upload, including images of your face, to generate the picture. The app's technologies prevent unique identification or authentication of a single user.
Personal Information Your name, surname, email address, and phone number, received when you contact us or make in-app purchases.
Activity Information Related to your app usage, including technical access to your camera or photos (if configured) for saving generated files or analyzing uploaded pictures. The app does not collect, store, or use pictures or files from your device unless explicitly uploaded or shared.
Information that is collected and processed automatically
Personal Information Received when you visit, use, and interact with the app, including order information from in-app purchases and the Identifier for Advertisers (IDFA) on your mobile device. Billing, processing and charging for in-app purchases organized on the App Store side, we cannot access or use your credit or debit card information.
Log Data Specific information transmitted by your mobile device, such as device identifier, user preferences, operating system details, and data about interactions with the App and or the Website. Additionally, data from your web browser, such as IP address, browser type, referring/exit pages, URLs, pages visited, and other relevant engagement details.
Analytics Usage We use online analytics tools like Amplitude and AppsFlyer, employing cookies to assess user interactions with our services and enhance your app experience.
Location Data Collection of location-related data, varying in precision based on your device's nature and configuration. Technologies like GPS and IP address provide insight into your present location.
Ad-related Information Data about ads viewed, including date and time served, "click" or "conversion" events, ad content, type (e.g., text, image, video), placement within the app, and user responses.
In-App Events Analytics tools automatically record in-app information, such as tutorial steps, leveling up, payments, in-app purchases, custom events, and progression events. The methods for limiting the processing of user data are also noted.

If you have any questions or concerns regarding the data collection outlined above, please refer to the "Contact Us" section of this Privacy Policy for information on how to reach out to us.

3. Purposes and Legal grounds of Processing Personal Data

3.1. In the pursuit of providing you with a seamless experience, we process your Personal Information for the following purposes:

  • Service Access and Oversight: To provide and oversee access to the Services.
  • Service Enhancement and Maintenance: To enhance, maintain, or rectify any aspect of the Services, internally or in collaboration with relevant third parties as needed.
  • Communication and Information Updates: To inform you about features or aspects of the Services that we believe may be of interest to you.
  • User Support: To address your inquiries, feedback, comments, or questions.
  • Administrative Communications: To transmit administrative information, such as updates regarding the Services or modifications to our terms, conditions, and policies.
  • Interaction Analysis and Program Development: To analyze your interactions with our Service and forge new programs and services.
  • Security Measures: To prevent fraud, criminal activities, or misuse of our Service and safeguard the security of our IT systems, architecture, and networks.
  • Legal Compliance and Safeguarding Rights: To adhere to legal obligations and legal procedures and safeguard our rights, privacy, safety, property, and those of our affiliates, you, and other third parties.
  • Aggregated Information Usage: We may compile and use aggregated Personal Information for evaluating service efficacy, introducing features, conducting research (internal or shared with relevant third parties), and similar endeavors and periodic analysis of overall user behavior and attributes, sharing aggregated information with third parties or making it widely accessible.

3.2 Legal Basis for Processing:

Our processing of your personal data is based on legal foundations aligned with the specific purposes for which we collect and intend to use your personal data. The legal grounds include:

  • Consent: We process your personal data if you have provided explicit consent.
  • Legal Obligation: Processing may occur when required to adhere to legal obligations.
  • Legitimate Business Interests: Processing aligned with our legitimate business interests.

Specific Legal Foundations for Data Processing:

  • Communications (Legitimate Interest): Processing for effective communication, arranging meetings, calls, or virtual sessions. Recordings stored within our corporate system.
  • Marketing and Public Relations (Consent): Utilizing cookies for marketing research, analyzing visitor characteristics, evaluating marketing communications, and tailoring them to identified trends. Using personal data for sharing promotional materials, service updates, email notifications, and newsletters.
  • Automated Processing (Legitimate Interest): Essential cookies and third-party services automatically process data to gain insights into user preferences and enhance the overall website or app experience.
  • Security Measures (Legitimate Interest): Processing personal data to uphold website or app security, thwart fraudulent activities, and protect the rights and interests of our Company and third parties, including Intellectual Property rights.

We remain dedicated to upholding data protection principles, ensuring transparent and lawful processing based on appropriate legal grounds.

4. Data Storage and Security Measures

4.1 Data Retention:

Your personal data is retained only for the duration necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is stipulated or permitted by law. We are committed to ensuring that your data is not held for longer than is essential for the specified purposes.

4.2 Data Deletion and Anonymization:

Once the legitimate business requirement to process your personal data no longer exists, we take appropriate action, which may involve the deletion or anonymization of the information. In situations where immediate deletion is not feasible, such as when data is stored in backup archives, we securely store the information. This ensures it remains isolated from any additional processing. We maintain this secure state until the point when deletion becomes viable.

As a user, you have the right to restrict us from processing your data by submitting a data erasure request or a notice prohibiting the processing of your data. It's important to understand that taking such action will prevent us from processing your data and may lead to the deletion of your data. This could result in a loss of access to the Services and may also restrict our ability to respond effectively to your inquiries.

4.4 Ensuring Your Data Security:

We prioritize the implementation of stringent security measures to safeguard your personal data throughout its lifecycle. These measures include protection against unauthorized or unlawful processing, accidental loss, destruction, or damage.

Pay attention, no method of transmitting data over the Internet or storing it electronically can ensure absolute security, as there is no system that is 100% secure. While we make every effort to safeguard your personal data, we cannot provide a guarantee of its absolute security. If, unfortunately, there is a compromise of your personal information due to a breach of security, we are committed to promptly notifying you in accordance with applicable law.

5. Children Rights

Our Services are designed for users aged 18 and above, and we do not intentionally collect or request any personal information from individuals under the age of 18. It is explicitly stated that no person under the age of 18 should provide any personal information through the Services. If you are under the age of 18, refrain from using the Services or providing any information, including your email address, through its features. In the event that we become aware of the collection of personal information from an individual under the age of 18 without verified parental consent, we will promptly delete that information. If you suspect that we may have information from or about a child under 18, please contact us immediately.

6. Push Notification

From time to time, we might send push notifications through our mobile applications, keeping you informed about application upgrades or updates related to our services. You retain the control to customize and cease such communications and notifications by adjusting the settings on your device.

Your data will be retained for the duration stipulated by applicable legislation or for a reasonable period until the purpose of processing concludes, or in accordance with legal periods of limitation. In some instances, we may persist in storing your personal data beyond the original purpose of use, either as mandated by other laws or with your separate consent. If you grant us permission to retain your personal data for an extended period, upon the expiration of this additional time or once the processing purpose ceases, the data will be promptly deleted, destructed, or anonymized. Your consent holds significance in determining the continued storage of your data beyond its initial purpose.

7. Your Data Subject’s Rights

As an individual whose data is processed, you hold the following rights:

  • Right to Access: You can request access to your personal information, seeking details on its processing, purpose, duration, and any third parties with access.
  • Right to Rectification: If you find inaccuracies in your personal information, you have the right to request corrections.
  • Right to Erasure: You can request the deletion of your data if its processing is no longer necessary or lacks legal grounds. We will comply unless legislation requires otherwise.
  • Right to Restrict Processing: If you dispute the accuracy of your data or wish to restrict processing for other reasons, you can request this.
  • Right to Withdraw Consent: You have the right to withdraw your consent for data collection and processing at any time, without affecting prior lawful processing.
  • Right to Lodge a Complaint: You can file a complaint with the supervisory authority if you believe your rights are not being respected.
  • Right to Data Portability: You have the right to data portability.

We commit to responding to your rights-related requests within one month of receipt. However, if an overwhelming number of requests is received, the response time may be extended by an additional two months. In such cases, we will notify you of the extension and provide reasons for the delay within one month of receiving the request.

8. How to Opt-out

8.1. Manage Marketing Tracking Preferences

You have the ability to control how your activity is tracked, especially if you prefer not to receive personalized ads based on your interests from third-party service providers. Here's how you can manage your tracking preferences:

  1. Navigate to Settings > Privacy > Tracking.
  2. Toggle the permission to track on or off for specific apps.
  3. Control whether apps can request permission to track your activity.

If you wish to prevent apps from prompting you for permission or accessing your device's Advertising Identifier, follow these steps:

  1. Go to Settings > Privacy > Tracking.
  2. Disable the "Allow Apps to Request to Track" switch.

By turning off this setting, you won't receive prompts from apps seeking to track your activity. Each app requesting permission while this setting is off will be treated as if you selected "Ask App Not to Track." For more information, visit https://support.apple.com/en-us/HT212025 or check the Settings > Privacy > Tracking section on your device.

To disable Apple's ad targeting, go to Settings > Privacy > Apple Advertising, and set the "Personalized Ads" switch to the "off" position. Further details can be found at https://support.apple.com/en-us/HT202074. Alternatively, you can visit https://youradchoices.com for similar options.

Please note that opting out of certain interest-based advertising doesn't prevent you from receiving contextual ads based on other non-personal information, such as content-related ads from other digital products you use.

8.2. Opt-out of Location Data Processing

If you prefer not to allow third-party service providers to use your precise location data or street-level location information, follow these steps:

For iOS 11 or later:

  1. Turn off Location Services for the relevant product at "Settings > Privacy > Location Services."
  2. Select the applicable app and set the "Share My Location" status to "Never." For additional details, visit https://support.apple.com/en-us/HT203033.

9. CALIFORNIA RESIDENT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request: a) the categories of personal information that is processed; b) the categories of sources from which personal information is obtained; c) the purpose for processing of user personal data; d) the categories of third parties with whom we may share your personal information; e) the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above. Be informed that according to CCPA personal information does not include de-identified or aggregated consumer information.
DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.
OPT-OUT OPTIONS. If you don’t want us to process your personal information any more, please contact us through [email protected]. Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CALIFORNIA PRIVACY RIGHTS.

  • The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months. Please, note that we shall not be required to provide personal information to you more than twice in a 12-month period.
  • The right to prohibit sale of information means that you have the right to request that we stop the processing of your data for direct marketing purposes either by asking us to cease processing all data about you or asking us not to send you direct marketing communications. We generally do not sell your Personal Information for profit.
  • The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
  • The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
  • The right to opt out of automated decision-making technologies means your right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
  • The right to restrict the use of your sensitive information means directly contacting us to stop such processing of your sensitive personal information for such purposes. We do not process any sensitive personal information to infer characteristics about you.
  • The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. Please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information if we need it to, among other things: (a) complete the transaction for which the personal information was collected, or (b) fulfill the terms of a written warranty or product recall; (c) detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (d) debug to identify and repair errors that impair existing intended functionality; (e) comply with the California Electronic Communications Privacy Act; (f) enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; (g) comply with a legal obligation.
  • Otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information, etc.
  • The rights to portability means your right to receive your personal information in an electronic and structured form to you or to another party.
SALE OF DATA. We do not sell any of your personal data to third parties.

10. COLORADO RESIDENT NOTICE

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will provide you with the required information in an alternative format that you can access.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.
DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email . When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

COLORADO PRIVACY RIGHTS.

  • The right of access means the right to know if a controller is processing the consumer’s data.
  • The right to portability provides the ability for you to receive the data in their right to access in a portable and machine-readable format, where technically feasible, that enables you to transmit the data to another entity without hindrance. Please note that you may only exercise the right to data portability twice per calendar year.
  • The right to opt-out means your right to object to the processing of your personal data for such purposes as (1) the sale of your personal data. Please note that we do not sell any of your personal data to third parties; (2) Targeted advertising, or (3) Profiling to help make decisions that produce legal or similarly notable effects concerning a consumer.
  • The right of correction means your right to request that we rectify inaccurate information about you.
  • The right of deletion means that you can ask us to delete or stop processing your personal data.
  • The right of appeal means that if you are not satisfied with resolving your privacy request, you can initiate an appeal procedure described below.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts.

If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee.

If we refuse to take action on your request, you can follow the appeal procedure within 30 days after receiving such refusal sending your appeal to this email [email protected]. adding in the subject of email “Appeal to answer on privacy request”.

We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time.

If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps we are unable to verify your identity, we reserve the right to decline your rights request.
SALE OF DATA. We do not sell any of your personal data to third parties.

11. VIRGINIA PRIVACY NOTICE

The following section pertains exclusively to residents of Virginia. It outlines our practices regarding the collection, utilization, and sharing of Personal Data belonging to Virginia residents, in our capacity as a business operating under the Virginia Consumer Data Protection Act ("VCDPA"). Additionally, it outlines your rights in relation to your Personal Data. Please note that the term "Personal Data" used in this section holds the definition ascribed to it by the VCDPA, with the exception of information exempted from the VCDPA's scope.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.
DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

VIRGINIA PRIVACY RIGHTS. As a resident of Virginia, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

  • Correct inaccuracies in the consumer’s personal data that is collected by the controller.
  • Confirm if the controller is actually processing their personal data or request a copy of the personal data.
  • Delete personal data provided by or obtained about the consumer.
  • Obtain copies of the personal data collected by the controller.
  • Opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.
  • The right to restrict processing of your sensitive personal information. We do not process any sensitive personal information to infer characteristics about you.
  • You have the right to be free from discrimination related to your exercise of any of your Virginia privacy rights.
  • Appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts.

If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee.

If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email [email protected]. adding in the subject of email “Appeal to answer on privacy request”.

We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time.

If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps we are unable to verify your identity, we reserve the right to decline your rights request.
SALE OF DATA. We do not sell any of your personal data to third parties.

12. CONNECTICUT PRIVACY NOTICE

This notice outlines the manner in which we, acting as a "Controller" under Connecticut's Data Protection Act ("CTDPA"), collect, utilize, and disclose your personal data, as well as the rights you have concerning your personal data, including sensitive personal data. In this context, "personal data'' and "sensitive data'' carry the definitions provided in the CTDPA and do not encompass information excluded from the scope of the CTDPA.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.
DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. Before processing most requests, we will need to verify your identity and confirm that you are a resident of the State of Connecticut. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

If you are submitting a request on behalf of a Connecticut resident, including a minor child, we will also need sufficient information to verify that the individual is the person about whom we collected personal data, and that you are authorized to submit the request on their behalf.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CONNECTICUT PRIVACY RIGHTS. As a resident of Connecticut, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

  • Right to know. You have the right to verify whether we are processing your personal data or not.
  • Right to deletion. You have the right to request the deletion of your personal data under certain circumstances. If you make such a request, we will assess whether we are legally obligated to comply or if there are reasons that limit the scope of the deletion. If there are any reasons, we will provide you with an explanation in our response.
  • Right to access. The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible.
  • The right to opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.
  • The right to ppt out of profiling. You have the right to choose not to have your personal data processed for profiling purposes that could lead to decisions with significant legal or similar effects on you. If you wish to exercise this right, you can opt out of such profiling activities.
  • The right to appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”.

If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.