Privacy policy

 

Last updated: April 30, 2025

Xingmai Innovation Technology (Hong Kong) Limited and its affiliates ("Beatbot", "we", "us", or "our") respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy describes how Beatbot collects, uses, and discloses your personal information when you visit Beatbot.com (the "Site"), use our products and services, make a purchase from the Site, access or use our mobile application called "Beatbot" (the "App"), and otherwise interact with us (collectively, the "Services").

Before accessing and/or using any of the Services, please read this Privacy Policy carefully.  If necessary, please make appropriate choices in accordance with the guidelines in this Privacy Policy. If you do not provide certain personal information to us, we may not be able to provide relevant Services to you, or the use of our Services may be restricted, or the Services may not function as what is designed for.

 

If you have any questions about this Privacy Policy, please contact us through the contact details under the Section 12 Contact Us.

1. What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with us and our products and services. When we use the term “personal information”, we are referring to information that identifies, relates to, describes, or can be associated with you.

 

The following are the categories and specific types of personal information that we collect:

  • Contact information: including your name, address, phone number, email address, mailing address.
  • Transaction information: including consignee name, records of purchases and prices, shipping address, contact information, shipment tracking details, details of returns, and warranty details.
  • Payment Information: includinginvoice / payment records, payment amount, payment confirmation, payment date, billing address, payment method. Please note that we use third-party payment providers, including Paypal, Klarna and AfterPay, to process payments made to us. We do not receive or retain any personally identifiable financial information such as payment card numbers; rather, all such information is provided directly by you to our third-party payment providers. The payment providers’ use of your personal information is governed by their privacy policy.
  • Account information: including your first and last name, user name, email address, phone number, username, avatar, password, one-time verification code, and the products or services you purchased or have otherwise used.
  • Shopping information: including the items you view, put in your cart or add to your wishlist.
  • Customer support information: including the information you choose to include in communications with us, for example, when sending a message through the Services, as well as recordings of calls with us (where permitted by law).
  • Event, contest, promotion, and survey information: including information provided when you sign up for an event, enter a contest or promotion, complete a survey or submit a testimonial.
  • Product-specific information: we collect or otherwise facilitate the processing of the following types of information in connection with the App and products. 
    • Customer content: including any files, documents, audio, videos, images, data, or communications you choose to input, upload, or transmit to our Site, App, products and Services.
    • Pool-related services information: when you use our pool-related services, including AquaSense 2 Ultra, we may collect information about your pool and your activities around your pool, including the location of your pool, pool environment data, pool monitoring images and videos. Note that depending on where you live, the surveillance laws in effect in your jurisdiction, and how you use our Services, you may need to obtain explicit consent from individuals before using our products to create and save video or images of them or provide notice informing visitors to your pool that our products or Services are in use. It is your responsibility to ensure that you comply with all such applicable laws. Please also note, we are not aiming to obtain the information about the monitoring images and videos which may contain your sensitive information, actually we have developed features to avoid any sensitive information, the information captured/collected through the camera of the AquaSense 2 Ultra is not uploaded to our server by default. If you have concern about the privacy, you can choose to use the camera locally; or if you wish to use the our camera with our network services to make the camera more smart and useful, you can specifically choose to upload the information by click the button of “AI Visual Recognition” at the setting page of Aquasense 2 Ultra. When you choose to use the camera and upload the information, images and videos to our server, we will also review the information to anonymize any images and videos which may contain a person or any sensitive information (e.g. body shape) of a person.
    • Device Information: your login information, information related to your phone, Wi-Fi and Bluetooth, device type, device identifier, MAC address, and device serial number, may be collectedfor identifying the device currently in operation,smart hardware device connection, management functions and security control of the device. In the process of connecting devices, we need to enable your mobile phone's Bluetooth permission and WLAN permission for device communication and your mobile phone location permission to scan nearby devices and obtain the WiFi information currently connected to your mobile phone.
    • Version Information: including the version information of the App, phone model, and the firmware of your connected smart hardware device, in order to provide you with updates to the App and the smart hardware device.
    • Device SharingInformation: When you use the device sharing feature to share your device with a friend, we may collect your friend's App account information and information about the device you are sharing. Please note that when you use the device sharing feature, the shared user may also view your device information in their app interface at any time. To protect the security of your personal information, some personal information involved in certain devices may not be shared, depending on the device you are sharing.
    • System Permissions Description: For the purpose of product function implementation and safe and stable operation, we may request or use relevant system permissions, such as camera, album and location permissions. Please be assured that these permissions will not be enabled by default, and we will only request the relevant permissions from you and obtain the corresponding information (if involved) when you trigger the relevant business function. The permissions we request are only necessary to implement specific features, and you may revoke authorization of system permissions at any time. If you refuse or revoke your authorization of system permissions, you will not be able to use the corresponding features, but this will not affect your normal use of other features.
  • Information about your network:including the operating system, IP address, browser type, user ID and UUID, or your network (including, for example, a persistent device identifier or advertising ID).
  • Information about the way you use our services and interact with us:including the website from which you came, the website to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that individuals take on our services, which may record your actions down to the level of mouse movements, scrolling, clicks, and keystroke activity on our services.

To collect some of the personal information set forth above, we may need to request permission to access such personal information through your mobile device. You are in control of the permissions you grant us, and you may change your permission settings at any time in the setting dashboard of your device. Note that revoking permissions may affect the provision and performance of our Site, App, products, and Services.

2. How We Collect Your Personal Information

Depending on how you use the Services, we may collect or obtain your personal information from the following sources:

  • Informationyou provide to us. We collect personal information when you provide such information to us (e.g., when you register an account on our Site or App; when you contact us via email, telephone, or by any other contact methods).
  • Interaction information. We collect personal information during ordinary interaction with you (e.g., when we provide services to you).
  • Site or App. We collect personal information when you visit or use Site or App, or use any features or resources available on or through our Site or App.
  • Content and advertising information.If you interact with any third-party content or advertising on our Site or App, including third-party plugins and cookies, we allow the relevant third party providers to collect your personal information. In exchange, we receive personal information from the relevant third-party provider relating to your interaction with that content or advertising.
  • Informationyou make public. We may collect the content you publish, or otherwise manifestly made public about us through our Site, our App, your social media, or any other publicly available platforms.
  • Third party information.We collect personal information from third parties who provide it to us (e.g., single sign-on providers and other authentication services you use to connect to our services, third-party providers of integrated services, Beatbot’s customers, business partners, processors, and law enforcement authorities).
  • Informationautomatically collected. We and our third-party partners automatically collect information you provide to us and information about how you access and use our Site, App, products or other services when you use the Services, read our emails, or otherwise e interact with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources. 

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices.

3. How We Use Your Personal Information

  • Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to youraccount, purchases, returns, exchanges, subscriptions or other transactions, to create, maintain and otherwise manage your account or profile, to arrange for shipping, facilitate any returns and exchanges, to enable you to post reviews, and to provide a forum for discussion, asking questions, posting photos and reviews, and sharing experiences.
  • Marketing and Advertising.We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail (such as promotions, new product launches, and event invitations), and to show you advertisements for products or services tailored to your interests on the Site, social media and other websites.
  • Analytics and Personalization. We use personal information to conduct research and analyticsor (within some jurisdictions) profiling, including to improve our services and product offerings; to understand how you interact with the Site, the App, advertisements, and communications with you; to determine which of our products or services are the most popular; to improve our Services, and marketing campaigns; to personalize your experience; to save you time when you visit the Site; to customize the marketing and advertising that we show you; to understand how you use our App; to create a more personalized experience for you when you visit our stores; to provide services; to better understand our customers’ needs; and to provide personalized recommendations about our products and services.
  • Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity, including fraudulent transactions; attempts to manipulate or violate our policies, procedures, and terms and conditions; security incidents; and harm to the rights, property, or safety of Beatbotand our users, customers, employees, or others. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
  • Communicating with you. We use your personal information to communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback, to provide customer service and to improve our Services.
  • Legal Obligations. We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
  • Core Business Functions. We use personal information to support core business functions, including to maintain records related to business process management, loss and fraud prevention; to collect amounts owing to us; and to provide and maintain the functionality of our Sites, including identifying and repairing errors or problems.

4. How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy as described below.

  • Corporate affiliates. We may disclose personal information with our corporate affiliates, including our parent company, sister companies, and subsidiaries, for legitimate business purposes and the operation of the Site, App, and Services for you, in accordance with applicable law. These legal entities may use your personal information in the manner described in this Privacy Policy.
  • Service Providers. Wemay disclose certain personal information to service providers that perform services to support our core business functions and internal operations including: fulfilling orders; delivering packages; complying with your request for the shipment of products to or the provision of services by an intermediary; sending postal mail, e-mails, and text messages; analyzing customer data; providing marketing assistance; administering our Customer Reviews; supporting beacons; processing credit card and debit card payments; providing cloud storage; investigating fraudulent activity; conducting customer surveys; and providing customer service and support.
  • Business and marketing partners. We may disclose personal information with other business and marketing partners with whom we jointly offer products or services. We may obtain your consent where required by applicable law. Our business and marketing partners will use your information in accordance with their own privacy notices.
  • Advertising networks. To efficiently market our products and services to you, we may share personal information with so called advertising networks. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and similar technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. For more information about how these technologies work and certain choices you may have in relation to these technologies, please refer tothe Section of Cookies, Analytics and Tailored Advertising.
  • Public Forums. The Site provides the opportunity to post content in a public forum. For example, Beatbot allows you to post reviews, and provides you a forum for discussion, asking questions, posting photos and reviews, and sharing experiences. If you decide to submit information in the public forum, that information will be publicly available.
  • Other Third Parties. When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as through your use of social media widgets or login integrations, with your consent.
  • Corporate Transaction and Legal Obligations. In connection with a corporate transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

5. Third Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

6. Children’s Data Protection

The Services are not intended for children under 16 years of age. We do not knowingly collect any personal information from children under 16. If you are under 16, do not use the Services or provide any information about yourself on the Site, in the App or to us. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, you may contact us using the contact details set out below to request that it be deleted. As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

7. Security and Retention of Your Information

The information that we collect from you will be processed and stored primarily in the United States, European Union and China.

 

We retain personal data for a period for the sake of information collection described in this Privacy Policy, or we do so in compliance with locally applicable relevant legal requirements (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements). After fulfilling the purpose of personal data collection, or after we confirm your application of deletion or cancellation, or after we terminate the operation of corresponding products or services, we will stop retaining personal information and delete or anonymize it.

 

We are committed to guaranteeing the security of your personal information. To prevent unauthorized access, disclosure or other similar risks, we have implemented reasonable processes of physical, electronic and supervisory measures to protect the information we collect from your products and the Site. We will take all reasonable measures to protect your personal data.

 

Your information will be classified according to importance and sensitivity, and your personal information will be protected with the highest level of security. We guarantee that employees and third party service providers who access this information to help provide products and services to you have strict contractual confidentiality obligations; otherwise, they will be subject to disciplinary action or termination of cooperation. In summary, we will regularly review information collection, retention and processing practices, including physical security measures, to prevent any unauthorized access and use.

 

We will take all feasible measures to protect your personal information. However, you should be aware that the use of information via the Internet is not always secure. Therefore, we cannot guarantee the security or integrity of any personal data transmitted bidirectionally over the Internet.

 

8. Your Rights and Choices

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

  • Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
  • Right to Delete. You may have a right to request that we delete personal information we maintain about you.
  • Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
  • Withdrawal of Consent. Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
  • Right to Lodge a Complaint. If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

 

You need to provide sufficient information to enable us to verify your identity and ensure that the person making the requests is the subject of the requested information or is their legally authorized person.

 

We reserve the right to refuse to process meaningless/entangled repetitive requests, or requests for inappropriate technical tasks, or requests that compromise the privacy of others, or requests that are extremely impractical, or requests that are not required to be granted under local law. We may also reject some aspects of your requests if we believe that they may prevent us from using the data lawfully for the aforementioned anti-fraud and security purposes.

 

There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and Beatbot is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical or unreasonable.

 

We know that in different jurisdictions, there may be different laws and requirements for the data subject rights and requests, you can find them in the Jurisdiction Specific Section below.

 

9. International Users

Please note that we may transfer, store and process your personal information outside the country or region you live in, including the United States. Your personal information is also processed by staff and third party service providers and partners in these countries. If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

10. Cookies, Analytics and Tailored Advertising

Beatbot and its third-party partners and providers use cookies and similar technologies to automatically collect certain personal information when you visit or interact with the Site and Services to enhance navigation, analyze trends, administer the Sites, track users’ movements around the Sites, gather demographic information about our user base as a whole, and assist with our marketing efforts and customer service. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Services.

 

For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

12. Contact Us

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at privacy@beatbot.com.

 

13. Jurisdiction Specific Section 1: EU GDPR Supplementary Addendum

If you are Europe Union resident and the EU GDPR applies to you or your personal data, your personal information may rely on different legal grounds:

13.1 If we have entered into a contract with you and the processing is necessary for us to perform our contract with you or take steps at your request prior to entering into the contract, the lawful basis is that it is necessary per Article 6(1)(b) GDPR.

13.2 If the processing is necessary for us to comply with an applicable legal obligation under EEA or UK laws, the lawful basis is that it is necessary per Article 6(1)(c) GDPR.

13.3 In some cases, the processing is necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests, including where we may provide you with a positive user experience, seek to comply with the laws or regulations outside of the EEA or UK, to maintain the security and integrity of our Products and/or Services and related platforms and systems, operate and optimize our business, improve our Products and/or Services, develop new services, manage our relationships with users or consumers, and administer communities of users or consumers. In these cases, the lawful basis is that it is necessary per Article 6(1)(f) GDPR.

13.4 In some cases, we rely on your consent to process your personal data, per Article 6(1)(a) GDPR, including when we use non-essential cookies or other technologies to process your data, or we conduct direct marketing which is not relying on our legitimate interest. In these cases, you can withdraw your consent at any time with future effect by using the consent settings on our products and/or services or email us at privacy@beatbot.com.

 

Under EU GDPR, you can exercise the following rights:

  • Right to Access. You have the right to access the personal information that we hold about you, including details relating to the ways in which we use and share your information, and get a copy of your data.
  • Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
  • Right to Delete. The right to obtain from us the erasure of your personal data. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures.
  • Right of Portability. The right to receive your personal data in a structured, commonly used format and transmit the information to another data controller.
  • Restriction of Processing. The right to obtain from us the restriction of processing your personal data. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal data under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
  • The Right Not to Be Subject to A Decision Based Solely on Automated Processing, Including Profiling, which produces legal effects concerning you or similarly significantly affects you.
  • Object to Processing of Your Personal Data.This includes the right to object to our processing of your personal data for direct marketing and the right to object to our processing of our personal data where we are pursuing our legitimate interests or those of a third party. If we process your personal data based on our legitimate interests or those of a third party, you can object to this processing, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Where we use your personal data for direct marketing for our own products and services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications or through other means.
  • Right to Withdraw Your Consent if such data processing is based on consent. This will not affect the lawfulness of our use of your personal data before your withdrawal.
  • Right to lodge a complaint with a supervisory authority, for authorities in EEA, you can find the contact details by clicking the link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you are Europe Union resident, Beatbot will provide systematic approach to manage personal data deeply engages our people, management processes and information systems by applying a risk management methodology.

 

  1. Jurisdiction Specific Section 2: California Addendum

If you are a California resident and the California Consumer Privacy Act (hereinafter referred to as “CCPA”) and The California Privacy Rights Act (hereinafter referred to as “CPRA”) do not recognize an exemption that applies to you or your personal data, please see details as below:

 

Notice of Collection: Please see Section I above for information about the types of personal information we collect.

 

California Privacy Rights: Right to Know and Data Portability

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 (the “right to know”). Once we receive your request and confirm your identity (see 'Exercising Your Rights to Know or Delete' section below), 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.
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. 
    • The specific pieces of Personal Information we collected about you (also called a data portability request).

 

California Privacy Rights: Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 other laws and regulations, such as 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.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

 

California Privacy Rights: Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request to us using the information in the Contact Us section.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. To designate an authorized agent, please submit an original notarized authorization to our mailing address along with your request.

You may only submit a request to know twice within a 12-month period, if such restriction is permitted by law. Your request to know or delete must:

  • 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:
  • government-issued identification, or
  • student identification.
    • 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 Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

You do not need to create an account with us to submit a request to know or delete. 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 the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

 

California Privacy Rights: Response Timing and Format

We will confirm receipt of your request within ten (10) business days or any shorter timeframe required by law. If you do not receive confirmation within such timeframe, please  contact us using the information 14.1 in the Contact Us section.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt, or any shorter timeframe required by law. If we require more time as permitted by law, 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, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

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.

 

California Privacy Rights: Personal Information Sales Opt-Out and Opt-In Rights

We do not sell your Personal Information to third parties for profit or other valuable considerations. Therefore, we do not provide individuals the ability to “opt-out” of the sale of Personal Information because we do not engage in such activities.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

 

California Privacy Rights: Non-Discrimination

We will not discriminate against you for exercising any of your legal rights. Unless permitted by law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by law that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

 

Your Rights Under California’s “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at the information in the Contact Us section.

 

  1. Jurisdiction Specific Section 3:Other US States Addendum

Subject to the conditions under applicable laws, you have rights to request us to do followings:

- Confirm whether or not it is processing your personal data and provide copies of such data;

- Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of processing of the consumer's personal data, except this right is unavailable in Iowa and Utah;

- Delete personal data provided by or obtained about you;

- Opt out of the processing of your personal data for the purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

 

When you use our products and/or services, we may collect, use and disclose your personal information as described in the Sections 1,2, 3 and 4 above. Some of the laws that apply to our processing of personal data qualify our collection, use and disclosure of personal data for targeted advertising purposes as “selling” personal data.

You may opt out of targeted advertising and such selling in our products and/or services by clicking the button of “Your Privacy Choices” in the Site or by other means we told you in other scenarios.