<p>We respect your right to privacy and will only process your Personal Data in accordance with applicable data protection and privacy laws.</p>
<p>In this Privacy Policy, "we," "us," "its" and "our" refer to Mapillary AB ("<strong>Mapillary</strong>"), organized under the laws of Sweden.
Please read carefully this Privacy Policy ("<strong>Policy</strong>") relating to your submission of Content (as defined in Mapillary’s Terms of Use) to and use of Mapillary applications, services and websites.
Other terms used with a capital initial letter are defined in the associated Terms of Use or the associated Mapillary Marketplace Terms.</p>
<p>
<strong>A.
Introduction</strong>
</p>
<p>This Policy explains how Mapillary collects, stores, uses and discloses information from you when you submit Content to and use Mapillary products, services, mobile applications and websites.
This Policy applies to users of the Mapillary "<strong>Service</strong>", defined as the services, APIs, and functionality we make available either through our website at www.mapillary.com and related site pages, including https://www.mapillary.com/app (the "<strong>Website</strong>"), via private sites or repositories, or through third party sites that utilize our services and functionality, as well as through our mobile application (the "<strong>App</strong>").</p>
<p>This Policy does not apply to websites, applications, or services that do not display or link to this Policy or that display or link to different privacy statements.
nor does this Policy apply to practices of companies that we do not control or to people we do not employ or manage.</p>
<p>It may be possible for you to browse certain parts of the Website without telling us who you are or revealing any information that enables us to directly identify you as an individual.
However, you may lose anonymity once you give us Personal Data about you.
In particular and as applicable, this applies to any Personal Data you voluntarily submit in your bio/profile page and the geolocation data indexed to photos submitted.</p>
<p>
<strong>B.
Information Collected</strong>
</p>
<p>We collect information in various ways when you use our Service and as set forth in this Privacy Policy and the Terms of Use.
Some of this information may be Personal Data attributable to you.
As used in this Policy, "<strong>Personal Data</strong>" means any information (either alone or in combination with other information we hold) that directly or indirectly may be used to identify or identifies you as an individual, such as your name, address and physical location, account numbers, email addresses, or telephone numbers.</p>
<p>If there is data that could be understood as Personal Data included in Content, e.g.
faces of individuals or license plates of vehicles, we use automatic blurring of faces and plates to avoid any identification of individuals before posting on the Website.
As this is an automated process, we welcome any requests or comments if there is something we missed, by e-mail to support@mapillary.com.</p>
<p>As well as Personal Data, we also collect some information that is not personally identifying, including aggregate information, which is data we collect about use of the Service or about a group or category of users from which it is not possible to identify you (“Nonpersonal Data”.
together with Personal Data, collectively "Information").</p>
<p>
<em>Personal Data</em>
</p>
<p>When you register for an account, and in the course of your use of the Service, we collect and process the following Personal Data attributable to you as a user:</p>
<ul>
<li>your sign-on credentials (email and hashed password);</li>
<li>email address;</li>
<li>username (user ID);</li>
<li>any profile or biographical information you elect to provide;</li>
<li>if you elect to sign-on through Facebook, Google, Twitter or OpenStreetMap, we may receive your username, email address, profile picture, and language preference;</li>
<li>your phone number and home address (for sending equipment or prizes or if you are a Marketplace Driver);</li>
<li>any Personal Data revealed in your Content either on the Service or via our Blog or Forum;</li>
<li>IP-address and cookies;</li>
<li>data regarding your usage of the Website or the App;</li>
<li>statistics of activities including number of images uploaded or edited;</li>
<li>geolocation data included in Content that you have submitted;</li>
<li>if applicable, financial information, including credit card and/or bank account numbers, that you provide to us in exchange for your commercial use of the Service as agreed in writing separately between us (collected by Stripe, our third party payments provider).
and</li>
<li>live geolocation data (within the scope of the Mapillary Marketplace or Capture Projects (to log progress of projects once allocated, mileage and time sheet information).</li>
<li>where you sign up as a Marketplace Driver we collect and process your name, occupation, a photograph of your driving license, a profile photo of your face, vehicle information (type, make, model, year) and photographs of your vehicle.</li>
</ul>
<p>If you visit our website without being a registered user of the Service, we collect and process the following Personal Data attributable to you:</p>
<ul>
<li>geolocation data (where permitted by browser/with your consent);</li>
<li>pixel tags and web beacons.
and</li>
<li>IP-address and cookies.</li>
</ul>
<p>
<em>Nonpersonal Data</em>
</p>
<p>When you use our Service, we automatically collect Nonpersonal Data sent to us by your computer, mobile device or other access device, such as a device ID or unique identifier, device type, model and brand, geo-location information, computer, network and connection information, access times, operating system and browser version, type and language, app crash data, and the website you visited before our Website.
We also collect Nonpersonal Data about your usage and activity on the Service, and in the form of Metadata (as that term is defined in the Mapillary Terms of Use).
This Policy does not restrict or limit our collection and use of Nonpersonal Data.</p>
<p>
<em>Cookie Policy</em>
</p>
<p>The Service may utilize "cookies", which are small text files placed on your computer or device.
We may also use pixel tags, web beacons and other similar technologies.
Such devices are used to help analyze our web page flow, customize our services and optimize our user interfaces, and measure promotional effectiveness.
Our analytics cookies collect data such as the identity of the applicable internet service provider, the user's IP address of his or her terminal device, the type of browser software and operating system in use, the date and time of site access, the website address, if any, from which the user linked to the Website, and other similar traffic-related information sent by a device (i.e.
device type, device model, device brand and computer network).
We may also aggregate such information with similar data collected from other users and disclose such aggregate information to third parties.
Certain features are only available through the use of cookies, and generally we need to use cookies to help identify and maintain your signed-in status.
You are always free to decline cookies via your browser settings, although doing so may interfere with your use of the Service.
You may encounter cookies from non-affiliated third parties on certain pages of the service.
To learn more about cookies, please visit allaboutcookies.org.</p>
<p>Here is a list of the cookies that will be used and installed as essential, as well as those analytics cookies that may be used and installed on your computer or device with your consent (optional).</p>
<p>
<strong>Purpose</strong>
</p>
<p>
<strong>Source</strong>
</p>
<p>
<strong>Type</strong>
</p>
<p>User authentication</p>
<p>Mapillary</p>
<p>Essential</p>
<p>Site analytics</p>
<p>Google</p>
<p>Optional</p>
<p>User authentication—these cookies allow us to customize the Website based on your login status (i.e.
whether you're signed in or signed out of your Mapillary account).</p>
<p>Site analytics—these cookies help us to understand how visitors use our Website, so we can improve how the Website works.</p>
<p>
<strong>C.
Our Use of Information</strong>
</p>
<p>We use Information collected through our Service for the purposes and as described in this Policy, as disclosed to you on our App and as set forth in the Terms of Use.
We process your Personal Data and your Nonpersonal Data to operate, maintain, customize, measure and improve our Service (including to train the face and plate blurring algorithm) and to fulfill the purposes disclosed when you provided your information to us (through the Terms of Use).
The Content you provide may be used to create map data and images that we license to users, customers and researchers.
It may also be used to provide ‘sample’ sets of image data in a blurred format to members of the public.
In order to protect the personal integrity of individuals caught in the data, we automatically blur any faces and vehicle license plates in any submitted Content before it is posted to the Website.
This processing is done on the basis of our legitimate interest of properly providing and improving our Service.</p>
<p>We process the Personal Data listed in section B (a) and (e) to make sure that only registered users have access to our Service.
This processing is done on the basis of that it is necessary for us to fulfil our obligations to you in our Terms of Use.</p>
<p>We also process the Personal Data listed in section B (a) and (b) in order to connect you with other users that are interested in purchasing Content from you, or that you are interested in purchasing Content from and the Personal Data listed in section B (n) to ensure that only those appropriately certified can become Marketplace Drivers.
This processing is done on the basis of that it is necessary for us to fulfil our obligations to you in our Terms of Use and Driver Addendum.</p>
<p>Furthermore, we process the Personal Data listed in section B (a) and (b) to respond to your comments and questions and provide the customer support you request.
This processing is done on the basis of that it is necessary for us to fulfil our obligations to you in our Terms of Use.</p>
<p>We process the Personal Data listed in section B (b), (f) and (j) to provide leaderboards based on the amount of content you have uploaded and to provide you with any prizes when you reach Content milestones.
This processing is done on the basis of our legitimate interest of properly providing our Service.</p>
<p>We process the Personal Data listed in section B (a), (b) and (l) to resolve disputes, collect fees and enforce our terms and policies.
This processing is done on the basis of our legitimate interest of overseeing, monitoring and properly policing our Service.</p>
<p>We process the Personal Data listed in section B (g) - (k) to analyze user behavior in order to understand user preferences, for product development and training purposes, to troubleshoot problems and to enhance your experience and enjoyment using our Service and Website.
This processing is done on the basis of our legitimate interest of improving and developing our Service.</p>
<p>We process the Personal Data listed in section B (a) and (b) to communicate with you about new events, offers and other news about our products and services offered by us and, as applicable, our selected partners and send you Service-related information, including confirmations, invoices (as applicable), technical notices, updates, security alerts and support and administrative messages.
This processing is done on the basis of that it is necessary for us to fulfil our obligations to you in our Terms of Use, and, in regard to direct marketing, our legitimate interest of providing you with such communication.</p>
<p>Within the scope of Capture Projects and the Mapillary Marketplace, we process your live geolocation data (section B (m)), whilst you are collecting images for a Requester/Organization.
This live geolocation data is only processed to provide our Services within Capture Projects and the Mapillary Marketplace, and to facilitate the Requester’s/Organization’s supervision of the task they have assigned to you.
Such processing is done on the basis of your explicit consent.</p>
<p>If you visit our Website we process the Personal Data listed in section B (o) - (p) to analyze the flow of visitors to our Website, to customize our Service and optimize user interfaces and to measure promotional effectiveness.
This processing is done on the basis of our legitimate interest of developing and improving our Website and Service.</p>
<p>
<em>Face and plates included in submitted Content</em>
</p>
<p>If any Personal Data attributable to you is included in submitted Content, we will process such Personal Data in order to properly provide our Service.
This processing is done on the basis of our legitimate interest of providing our Service.
In order to protect your personal integrity, we automatically blur any faces and vehicle license plates in any submitted Content before it is posted to the Website.</p>
<p>
<em>Retention policy</em>
</p>
<p>We only store your Personal Data as long as it is needed for the purpose for which it was collected.
In relation to our registered users we will keep the Personal Data listed in section B II(1) of this Policy only as long as you are registered as a user.
However, after you de-register as a user we may process such Personal Data as is necessary for us to fulfill an agreement with you, or such Personal Data as we are required to keep by law.</p>
<p>In order for us to provide our Service and for the purposes described in this policy, we will keep any submitted Content, as well as data and statistics regarding your use of the Service and geolocational data included in the Content, indefinitely.
However, at your request, we will remove all information in relation to such Content, data and/or statistics, which connects it to you as a user.
Furthermore, we do not store the live geolocational data we collect from Marketplace Drivers after the completion of the project or task to which the live geolocational data pertains in any other form than the metadata accompanying any images contributed.</p>
<p>In relation to visitors of our Website, all Information that we process connected to cookies are stored in accordance with our cookie policy (see section B above).</p>
<p>Personal faces and vehicle license plates in all submitted Content are automatically blurred when submitted Content arrives at our servers, in order to respect and protect the personal integrity of any persons pictured. </p>
<p>
<em>General</em>
</p>
<p>We may use and provide data and information to our partners and customers for commercial purposes after we have removed your name or any other Personal Data from it, or have combined it with other people's data in a way that it is no longer associated with you.</p>
<p>We also may combine your Information with information we collect from other sources to improve our products and services.
Content (as defined in the Terms of Use) may be exposed to public search engines and publicly available search results and via third party sites and applications that access the Service.
Nothing in this Privacy Policy should be construed to prevent us from charging a fee to parties who wish to access Content or to use the Service (although access to the Service for Non-Commercial Use, as defined in the Terms of Use, is free of charge).</p>
<p>You have the option of submitting Content anonymously as the user name and e-mail address you submit may certainly be created specifically to avoid identifying you as an individual.
If you do not submit a valid e-mail address however, this may interfere with your use of the Service through a loss of relevant notifications.
However, we cannot guarantee absolute anonymity and make no guarantee that other users will never be able to determine your identity, such as (without limitation) by observations of your activity, the manner in which you express yourself, and other patterns of conduct or behavior.
Moreover, all of your activities on the Service will be traceable by others users to your username, from which your actual identity may be known.
Notices may be sent to other users regarding suspicious activity and policy violations and refer to usernames and specific items.
Please understand that if your username identifies you or is linked to an e-mail address, other users will be able to personally identify your activities.</p>
<p>Further, we may use Personal Data to respond to legal requirements, in connection with a merger, sale of assets, or other similar corporate transactions, to respond to claims that Content violates the rights of others, or to protect the rights, property, or safety or any person.</p>
<p>
<em>Your choices regarding our use of your Personal Data for marketing purposes</em>
</p>
<p>If you no longer wish to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in any such message, or by emailing us at support@mapillary.com.
We aim to comply with such request(s) as soon as reasonably practicable.
Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you administrative messages.
you cannot opt-out from receiving administrative messages.</p>
<p>
<strong>D.
Personal Data within Capture Projects and the Mapillary Marketplace</strong>
</p>
<p>This Policy applies to such processing of Personal Data over which Mapillary is the data controller pursuant to the GDPR.
However, for Marketplace or Capture Projects, Mapillary, and the Organization/Requester for which images are collected, will be joint controllers in relation to the processing of Personal Data within the scope of such Services.</p>
<p>When two or more parties are joint controllers in regard to processing of Personal Data, as in the case of Personal Data processed within the scope of Capture Projects or the Mapillary Marketplace, the joint controllers are to determine their respective responsibilities according to the GDPR.
This determination is made through an internal arrangement between the joint controllers.
The internal arrangement in force between Mapillary and the Organization/Requester that you collect images for can be found in Mapillary’s Terms of Use.</p>
<p>Mapillary processes Personal Data under this joint controllership for the purposes and on such legal basis as set out in section C above, and as otherwise stipulated in this Policy.
You can always contact Mapillary at support@mapillary.com if you have any questions regarding your Personal Data processed under joint controllership, or if you wish to exercise any of your rights under this Policy or the GDPR.
For the purposes and legal basis of the Requester/Organization, we refer you to their respective privacy policy.</p>
<p>If the Requester/Organization is a private individual acting in their private capacity, Mapillary is instead the sole data controller of Personal Data processed within the scope of the Mapillary Marketplace or Capture Projects, and this Policy (except for this section D) applies to that processing.</p>
<p>
<strong>E.
Sharing Information</strong>
</p>
<p>We do not disclose, sell or rent your Personal Data to third parties for their marketing purposes without your prior consent.
If you do consent but later change your mind, you may contact us and we will cease any such activity.
We only share your Personal Data as follows:</p>
<p>(i) at your direction and control via your normal and intended operation of the Service, or with your consent, for example, when you agree to our sharing your Personal Data with other selected third parties for their own marketing purposes subject to their separate privacy policies;</p>
<p>(ii) with service providers, consultants or similar contractors, Requesters/Organizations (within the scope of Capture Projects or the Mapillary Marketplace), or third parties who provide services or content in connection with our Service in order to support or enhance our or such parties’ products and services or our or such parties’ business operations, or to make available and consummate initiated transactions;</p>
<p>(iii) to comply with laws or respond to lawful requests and legal process or to enforce or apply our terms of use/service, license terms, or other agreements between us, and to protect the rights, safety and property of Mapillary, our agents, employees, customers, members, and others;and</p>
<p>(iv) under written obligations of confidentiality, in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.</p>
<p>We may also share and disclose Nonpersonal Data for the same purposes as described above.</p>
<p>When other companies, e.g.
our service providers, process your Personal Data on our behalf, we always enter into binding data processing agreements that ensure that your Personal Data always enjoys the same level of protection as under this Policy.</p>
<p>
<strong>F.
No Guarantee of Security</strong>
</p>
<p>We apply appropriate technical and organizational safeguards and take all reasonable steps to help protect your Personal Data in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
However, no one can create a completely secure website, app or service and third parties may unlawfully intercept, steal or access transmissions or private communications.
Therefore, we cannot guarantee that your Information or private communications that you transfer over the internet to us will always be secure or remain confidential.</p>
<p>
<strong>G.
Password</strong>
</p>
<p>Your password deserves careful thought and protection.
Use unique numbers, letters, and special characters and do not disclose your password to anyone.
You shall not share your password or your personal sign-in credentials with others, and please remember that you are responsible for all actions taken in the name of your account.
If you lose control of your password, you may lose substantial control over your Personal Data and may be subject to legally binding actions taken on your behalf.
If your password has been compromised for any reason, you should immediately access your profile to change your password and notify us immediately at support@mapillary.com.</p>
<p>
<strong>H.
International Transfers</strong>
</p>
<p>We may process Information on servers located in a number of countries.
Accordingly, we may share Information with our service providers and affiliated companies for such companies to carry out any of the activities specified in this Policy.
We may also subcontract processing to or share Information with third parties located in countries other than your home country.
Information collected within the European Economic Area, for example, be transferred to, and processed by our affiliates or other third parties identified above that are located in, a country outside of the EEA.
However, regardless of country, we will always process Information in accordance with this Policy.
In respect to our service providers, we will always enter into a data processing agreement that ensure that their processing gives the same level of protection to your Personal Data as this Policy.</p>
<p>In addition to the above, any transfer of Personal Data from the EEA to a third country outside the EEA, will only be made if permitted by the applicable EU Personal Data protection regulation.
This means that we will only initiate such transfer of Personal Data if the receiving country outside the EEA has been deemed by the EU Commission to ensure an appropriate level of protection, if we have entered into the Commission’s standard data protection clauses with the receiving company, or if there are other safeguards in place that permits such a transfer.
You can receive a copy of such safeguards by e-mailing support@mapillary.com.</p>
<p>
<strong>I.
Children</strong>
</p>
<p>The Services are not directed at or intended for children under sixteen (16) years of age, and we do not knowingly collect Personal Data from such children.
If you believe that we might have any Personal Data from a child under 16 years of age, please contact us at support@mapillary.com.</p>
<p>
<strong>J.
Policy Changes</strong>
</p>
<p>We may amend this Policy from time to time.
If we make any changes to this Policy, we will post the amended terms on Mapillary.com, change the "Last Updated" date above, and where appropriate, notify you by email or via our other notification mechanisms.</p>
<p>
<strong>K.
Your Information, Rights and Choices</strong>
</p>
<p>You have the right to ask us not to process your Personal Data for marketing or promotional purposes.
We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes.
You may also opt out of receiving promotional emails from us by following the instructions in the emails themselves or by emailing support@mapillary.com.
If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.</p>
<p>You can see, review and change your Personal Data by logging into the Service or by contacting us at support@mapillary.com.
You should promptly update your Personal Data if it changes or is inaccurate.</p>
<p>You have the right to receive confirmation on whether or not we process Personal Data concerning you, and in such cases get access to such Personal Data and also information regarding the Personal Data and how we process it.</p>
<p>You have the right to have inaccurate Personal Data concerning you rectified without undue delay.
Taking into account the purposes of the processing, you also have the right to have incomplete Personal Data about you completed.</p>
<p>You have, under certain circumstances, the right to have Personal Data concerning you erased, for example if the Personal Data are no longer necessary in relation to the purposes for which they were collected or if the Personal Data have been unlawfully processed.</p>
<p>You have the right to withdraw a consent provided by you at any time by contacting us.
If your consent is withdrawn, we will no longer process your Personal Data for the purpose that you had given your consent to.</p>
<p>In some circumstances you have the right to obtain restriction of the processing of your Personal Data.
For example if you contest the accuracy of the Personal Data, you can also require that we restrict the processing of your Personal Data for such a period that enables us to verify the accuracy of the Personal Data.</p>
<p>You have the right to object to processing of your Personal Data that is based on our legitimate interests.
If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your Personal Data.</p>
<p>You have the right to receive the Personal Data relating to you and that you have provided to us, in a commonly used electronic format.
You have the right to transmit that data to another controller (data portability).</p>
<p>You may always contact Mapillary at support@mapillary.com if you have any questions or comments regarding our processing of your Personal Data.
You also have the right to complain about the processing of your Personal Data by lodging a complaint to the relevant data protection authority.</p>
<p>You may delete your account any time by emailing support@mapillary.com.
Deletion is your sole means of terminating your account.
We will in our own discretion keep Nonpersonal Data and explicitly the images submitted and the associated geolocation data which is required, if any, to maintain the uninterrupted and intended Mapillary Solution functionality.
This Nonpersonal Data may be stored under a new username not attributable to you.</p>
<p>In addition to the above, you may opt-out of providing Information via the App to Mapillary at any time by uninstalling the App using the standard uninstall process available on your mobile device or via the mobile application marketplace or store.</p>
<p>Please note that once you make a public posting, you may not be able to change or remove it.</p>
<p>
<strong>L.
Questions</strong>
</p>
<p>If you have any questions about this Policy, please contact us at support@mapillary.com.</p>
<p>
<strong>CALIFORNIA PRIVACY RIGHTS</strong>
</p>
<p>If you are a California resident, California law may provide you with certain rights regarding our use of information about you.</p>
<p>A. “Do Not Track” under the California Online Privacy Protection Act.
We support “do not track” (a preference you may be able to set in your web browser to inform websites that you do not want to be tracked).
We are not aware of any processes for others collecting information about your activities on our websites over time and across third party websites, apps, or other online services, nor do we knowingly collect information about your activities over time across third party sites and services.</p>
<p>B. California's "Shine the Light" law (Civil Code Section § 1798.83).
This law permits users of our website that are California residents to request certain information regarding our disclosure of personal information, as defined by the Shine the Light law, to third parties for their direct marketing purposes.
To make such a request, please send an email to us at privacy@mapillary.com.</p>
<p>C. California Consumer Privacy Act (CCPA).
This part (C) serves as a privacy notice for California residents and applies solely to residents of California.
Any terms defined in the CCPA have the same meaning when used in this part (C).
Note that provision of this CCPA notice is not an admission on our part that we are a “business” within the meaning of the CCPA, and nothing in this policy may be construed as such an admission.</p>
<p>
<em>Personal Information we collect</em>
</p>
<p>We collect certain “Personal Information,” as defined by the CCPA and as listed in section B of the main body of the Privacy Policy and have done so within the last 12 months.</p>
<p>Personal Information does not include: (a) publicly available information from government records.
(b) deidentified information or aggregate consumer information.</p>
<p>We obtain the categories of Personal Information listed in section B of the main body of the Privacy Policy listed above from the following categories of sources:</p>
<ul>
<li>directly from you or publicly available sources.</li>
<li>indirectly when you use our services (eg cookies when using our website).</li>
<li>from the sources listed in this policy.</li>
</ul>
<p>
<em>Our use of Personal Information</em>
</p>
<p>We may use and have disclosed the Personal Information we collect for the following purposes:</p>
<ul>
<li>to fulfill or meet the reason you provided the Personal Information.
For example, if you share your name and contact information to request a price quote or ask a question about our offerings, we will use that Personal Information to respond to your inquiry.
If you provide your Personal Information to purchase a access to our service, we will use that information to process your payment and facilitate delivery.</li>
<li>to provide, support, personalize, and develop our website, products, and services.</li>
<li>to create, maintain, customize, and secure your account with us.</li>
<li>to process your requests, transactions, and payments.</li>
<li>to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.</li>
<li>to help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.</li>
<li>for testing, research, analysis, and product development.</li>
<li>to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.</li>
<li>as described to you when collecting your Personal Information or as otherwise set forth in the CCPA.</li>
<li>detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.</li>
<li>debugging to identify and repair errors that impair existing intended functionality.</li>
<li>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 Information held by us is among the assets transferred.</li>
</ul>
<p>We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes as those set out above, or in section C in the main body of the Privacy Policy above, without providing you notice.</p>
<p>We do not sell Personal Information as the term “sell” is defined in the CCPA.</p>
<p>
<em>Sharing Personal Information</em>
</p>
<p>We may disclose any or all of the categories above of your Personal Information to third parties for a business purpose, as set forth in this policy, and we have done so in the last 12 months.</p>
<p>We disclose your Personal Information for a business purpose to the categories of third parties set out in section E in the main body of the Privacy Policy above.</p>
<p>
<em>Your rights and choices</em>
</p>
<p>You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months.
Once we receive and confirm your verifiable consumer request, we will disclose to you (unless an exception applies):</p>
<ul>
<li>the categories of Personal Information we collected about you.</li>
<li>the categories of sources for the Personal Information we collected about you.</li>
<li>our business or commercial purpose for collecting that Personal Information.</li>
<li>the categories of third parties with whom we share that Personal Information.</li>
<li>the specific pieces of Personal Information we collected about you (also called a Personal Data portability request).</li>
<li>if we disclosed your Personal Information for a business purpose, a list of disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.</li>
</ul>
<p>We do not provide these Personal Data access and portability rights for B2B Personal Information to the extent such an exception remains in effect under the CCPA.</p>
<p>
<em>Deletion request rights</em>
</p>
<p>California residents have the right under the CCPA to request that we delete any of their Personal Information that we have collected and retained, subject to certain exceptions.
Once we receive and confirm a verifiable consumer request (see below), we will delete (and direct our service providers to delete) relevant Personal Information from our records, unless an exception applies (such as the B2B exception referenced above).</p>
<p>We may deny California residents’ deletion request if doing so is permitted or required by applicable law, or if retaining the Personal Information is necessary for us or our service provider(s) to:</p>
<ul>
<li>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 the requesting individual, or otherwise perform our contract with a requesting individual.</li>
<li>detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.</li>
<li>debug products to identify and repair errors that impair existing intended functionality.</li>
<li>exercise free speech, ensure the right of another to exercise their free speech rights, or exercise another right provided for by law.</li>
<li>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 Personal Information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.</li>
<li>enable solely internal uses that are reasonably aligned with consumer expectations.</li>
<li>comply with a legal obligation.</li>
<li>make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.</li>
</ul>
<p>
<em>Verifiable consumer request</em>
</p>
<p>To exercise the access, Personal Data portability, and deletion rights under the CCPA described above, please submit to us a verifiable consumer request as set forth above.</p>
<p>Only a California resident may make a verifiable consumer request related to their Personal Information.
A California resident may also make a verifiable consumer request on behalf of their minor child.</p>
<p>A verifiable consumer request for Personal Data access or portability can only be made twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify the California resident about whom we collected Personal Information or an authorized representative, and contain sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.</p>
<p>Making a verifiable consumer request does not require you to create an account on our website.
However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.</p>
<p>We will endeavour to respond to a verifiable consumer request within 45 days of its receipt.
If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account.
If you do not have an account with us, we will deliver our written response by mail or electronically.</p>
<p>Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.
The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For Personal Data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the Personal Information from one entity to another entity without hindrance.</p>
<p>We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.</p>
<p>
<em>Non-discrimination</em>
</p>
<p>We will not discriminate against you for exercising any of your CCPA rights.
Except as permitted by the CCPA, we will not:</p>
<ul>
<li>deny you goods or services.</li>
<li>charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.</li>
<li>provide you a different level or quality of goods or services.</li>
<li>suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.</li>
</ul>