Privacy Policy

Last updated: May 9, 2023

Introduction

At Arena of Life LLC (“Company”, “we”, “us” or ‘our”), we understand that your privacy is important. That is why we have developed this privacy policy to explain how we collect, use, share (“process”) and protect your personal information when you use our services (“Services”), such as when you:

• Visit our website at https://www.arenaoflife.com, or any website of ours that links to this privacy notice;

• Download and use our self-awareness and personal development mobile app (Arena of Life), or any other application of ours that links to this privacy notice;

• Engage with us in other related ways, including any sales, marketing or events.

This policy is compliant with the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), as well as other relevant legislation. Should you be a South Africa citizen, we recommend that you refer to our POPIA Privacy policy by clicking here (https://arenaoflife.com/pro/additionalpolicies).

Questions or concerns? 

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@arenaoflife.com.

Brief overview of key points

What personal information do we use?

When you visit, use or navigate our Services, we may process personal information depending on how you interact with the Company and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?

We may process sensitive personal information, when necessary, with your consent or as otherwise permitted by applicable law.

Do we receive any information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so or we have your consent.

Sharing of your information with third parties?

We may share information in specific situations and with specific categories of third parties (which is explained in further detail below).

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to breach our security protocols and improperly collect, access, steal, or modify your information.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How can you exercise your rights?

The easiest way to exercise your rights is by filling out our data subject request form or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

What information do we collect?

In essence, we collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on our website or mobile app, express an interest in obtaining information about us or our products and Services, when you participate in activities on the website or mobile app, including participating in the Community chat forum, or otherwise when you contact us.

Personal information provided by you

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Name; 
• Phone number;
• E-mail address;
• Birth date;
• Usernames;
• Passwords;
• Subscription type;
• Billing addresses;
• Personal reflections.

Types of Services

Standard Subscription

You will have two options under the Standard subscription model i.e., a Standard subscription with access to 1 Arena or a Standard subscription with access to the 6 Arena Premium version subscription. Pricing will differ depending on which Standard subscription model an individual chooses to purchase. 

An Arena of Life account can be created by a Member who is 13 years and older by downloading the Arena of Life app on their device via their applicable app store and following the prompts to create an account. Once an account is successfully created and the Member chooses their subscription model, the Member will be able to create specific Arena/s in order to track their set goals. All personal information shared when using this Service will be shared consensually with Arena of Life and we undertake not to disclose this information to any third party without your consent. 

ArenaPro Subscription

Individuals who are 18 years and older will furthermore have the option of purchasing access to the ArenaPro Subscription. This subscription type is purchased by Professionals (i.e., trainers, coaches, mentors, supervisors, managers, business owners or directors etc.) (“Professional”). When a ArenaPro subscription is purchased, and the ArenaPro Terms (amongst other consent policies) are agreed to, the Professional is granted access to the ArenaPro web site hosted on the following web address: www.arenaoflifepro.com. The Professional may then purchase additional licenses to allow their invited member/s (i.e., trainee, mentee, employee etc.) (“ArenaPro Member”) to Share their Arenas with them via their ArenaPro site. 

Unused ArenaPro licenses purchased by the Professional will carry over to the next subscription period if the Professional renews their ArenaPro Subscription. In the event that the Professional does not renew their ArenaPro subscription upon expiry of the 12-month subscription term, then all unused licenses will be forfeited.

The ArenaPro Subscription is utilized by Professionals in order to keep track of the progress of their invited ArenaPro Member/s. The Professional can create customizable templates and Arena/s for their ArenaPro Members to use, which will be available to the ArenaPro Member once they have: (1) Downloaded the Arena of Life app from their app store; (2) Successfully created an Arena of Life account; (3) accepted the invite to Share their Arenas using the code provided and (4) given their consent to share the contents of their Arenas with the Professional. 

Pro-Subscriptions

The third type of membership is a Pro-Subscription account ((available to persons ages 13 and older, alternatively to persons who have reached the age of consent and who have legal capacity to conclude contracts within their state/country), which is created by a Professional for an ArenaPro Member and provided to a Member via an invitation.

Once an invited ArenaPro Member has successfully downloaded the Arena of Life app on their device and accepted the General Terms of Service, this Privacy Policy and the Cookie Policy;  registered their account,  they will then proceed to activate the Share my Arenas invite code contained in the Professional's invite email. Once the ArenaPro Member has successfully given consent to share the contents of their Arenas with the Professional, the ArenaPro Member will have access to the Professional's Arena templates as well as other relevant resources and tools. In turn, the Professional will also have access to the ArenaPro Members profile, which includes the ArenaPro Member’s Arenas, goals, intentions, initiatives, and reflections (if consented to by the ArenaPro Member) as the two accounts will be linked. 

The ArenaPro Member must consent to the sharing of their personal information with the Professional prior to the Company permitting any ArenaPro Member information to be shared. In the event that the ArenaPro Member is 13-17 years old (“the minor”), the Company has implemented certain additional security measures whereby the parental consent of the minor’s parental guardian will be obtained prior to the minor being permitted to become an ArenaPro Member (in accordance with the relevant legal requirements). In addition, the minor will also be required to consent to the sharing of their personal information with the Professional. The minor will also be required to accept the Arena of Life General Terms of Service, Privacy Policy and the Cookie Policy prior to utilizing the Arena of Life platforms.

By consenting to Share their Arenas,  the ArenaPro Member (and a parental guardian in the case of a minor) acknowledges, understands and consents to their personal information being shared with the Professional (as the two accounts are linked).

The Professional may only request information from their ArenaPro Members which aligns to the services which the Professional has agreed to provide to the 

ArenaPro Member.

The ArenaPro Member is advised and cautioned not to divulge any personal information to the Professional which falls outside the scope of services offered by the Professional.

Should the ArenaPro Member feel that the Professional is acting in bad faith and/or requesting personal and/or sensitive personal information from a ArenaPro Member which goes beyond the Professional’s advertised scope of services, we urge the ArenaPro Member to refrain from providing the requested information to the Professional and to report the Professional to Arena of Life by sending an email to supprot@arenaoflife.com. 

Fees

• All standard subscription models can be purchased through the customers applicable app store. The standard subscriptions may be purchased as an annual subscription, or as a monthly subscription, where payment for the subscription is paid upfront at the beginning of the subscription period and will continue on an annual or month-to-month basis until you cancel your subscription (which cancellation is also done through your app provider).

• The ArenaPro subscription is offered on an annual basis (i.e., a 12-month subscription period) as is available for purchase by individuals 18 and older. 

• ArenaPro licenses are purchased by a Professional. They are purchased on an annual basis (i.e., payment is required upfront from the Professional for a 12-month period for each license purchased). Should the Professional elect to cancel its ArenaPro account prior to the expiration of the 12-month license period, all linked ArenaPro Member accounts shall also be cancelled.

Sensitive information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• health data;

• Information revealing race or ethnic origin;

• Information revealing religious or philosophical beliefs;

• Personal reflections, believes and intentions.

Payment Data.

Our third-party service providers may collect certain payment data from subscribers, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored with such third-party service provider (i.e., Google Play store, Apple store, Stripe etc.). You may find the privacy notice link for the third-party service provider on the relevant application on your device or on their website.

Application Data

If you use our mobile app, we may collect the following information if you choose to provide us with access or permission:

• Mobile device data: We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet protocol (IP) address (or proxy server). If you are using our app, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our app which you accessed. 

• Push notifications: We may request to send you push notifications regarding your account or certain features of the app. If you wish to opt out from receiving these types of communications, you may turn them off in your device settings.

This information is primarily needed to maintain the security and operation of our app, For troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In essence, information such as your Internet Protocol (“IP”) address and/or browser and device characteristics, is collected automatically when you visit our website.

We automatically collect certain information when you visit, use, or navigate the website or mobile app. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URL's, device name, country, location, information about how and when you use our services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and usage data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports [sometimes called “crash dumps”], and hardware settings).

• Device Data: we collect device data such as information about your computer, phone, tablet, or other device you use to access the services or mobile app. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification number, location, browser type, hardware model, Internet service provider and oh mobile carrier, operating system, and system configuration information.

How we process your information

In essence, we process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so that you can create and log into your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may Process your information to provide you with the requested service.

• To respond to user inquiries, offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products or services, changes to terms and policies, and other similar information.

• To enable user to user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

What legal basis do we rely on to process your information

In essence, we only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you

The General Data Protection Regulation (“GDPR”) and UK GDPR requires us to explain the valid legal basis we rely on in order to process your personal information. As such, we may rely on the following legal basis to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of a contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligation to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Develop and display personalized and relevant advertising content for our users;

• Analyze how services are used so that we can improve them to engage and retain users;

• Diagnose problems and/or prevent fraudulent activities;

• Understand how our users use our products and services so we can improve user experience.

• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or Regulatory agency, exercise or defend our legal rights, or disclosure information as evidence in litigation in which we are involved

• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you

we may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at anytime.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• if collection is clearly in the interest of an individual and consent cannot be obtained in a timely way;

• for investigations and fraud detection and prevention;

• for business transactions provided certain conditions are met;

• if it is contained in a witness statement and the collection is necessary to access, process, or settle an insurance claim;

• for identifying injured, ill, or deceased persons and communicating with next of kin;

• if we have reasonable grounds to believe an individual has been, is, or maybe victim of financial abuse;

• if it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or province;

• if disclosure is required to comply with the subpoena, warrant, the court order, all rules of the court relating to the production of records;

• if it was produced by an individual in the course of the employment, business, or profession and the collection is consistent with the purposes for which the information was produced;

• if the information is publicly available and is specified by the regulations.

When and with whom do we share your personal information

In essence, we may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, consultants, and other third-party service providers.

We may share your data with third party vendors, service providers, contractors, or agents (i.e., third parties) who perform services for us all on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Cloud Computing Services;
• Data Analytics Services;
• Data Storage Service Providers;
• Payment Processes;
• Performance Monitoring Tools;
• Testing Tools;
• User Account Registration And Authentication Services;
• Website Hosting Service Providers.

We may also need to share your personal information in the following situations:

Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

What is our stance on third-party websites

In essence, we are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

Our website may link to third party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us, and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third party websites, services or applications. The inclusion of a link towards a third party website, service, or application does not imply an endorsement by us stop we cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

Do we use cookies and other tracking technologies

In essence, we may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice (https://arenaoflife.com/cookie_policy).

How long do we keep your information

In essence, we keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention. Is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which the user has an account with us. Once a member has cancelled and/or failed to renew their account with us, we shall retain their data for a period of 60 days. Upon the expiration of the 60-day period, we shall delete all data linked to the Member’s account from our database/s.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do we keep your information safe

In essence, we aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to breach our security and improperly collect, access, steal, or modify your information. Although we do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

What are your privacy rights

In essence, in some regions such as the European Economic Area (“EEA”), United Kingdom (“UK”), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at anytime.

In some regions (Like the EEA, UK and Canada), you have certain rights under applicable data protection laws. These may include the right to:

• Request access and obtain a copy of your personal information;
• Request rectification or erasure;
• Restrict the processing of your personal information; and
• Of applicable, data portability.

In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

If you are located in Switzerland, the contact details of the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. 

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be expressed and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before it is withdrawn nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can do so as follows: 

1. Standard Subscription: Should the Member decide to cancel their subscription, cancellation must be done through the intermediary used to install and purchase the app (i.e., Google Play Store, Apple store are some examples). Please note that should the Member cancel their membership prior to the end of a paid for year (“the cancellation year”) or paid for month (“the cancellation month”), the Member will still have paid access to the app until the end of the cancellation year or cancellation month (whichever is applicable). Once the Member has cancelled their subscription with such third party, the Member shall continue to have access to their account for a further 7-day period within which the member may save all its personal information contained in the Arena of Life App. Following the expiry of the 7-day period, the app features and content will no longer be accessible until a future subscription is purchased. Furthermore, after the expiration of the 7-day period (either due to the cancellation of the Member’s account or the non-renewal of the Member’s account), Arena of Life will retrain the data linked to the Member’s account for 60 days and thereafter, all data linked to the Member’s account will be deleted from Arena of Life’s database/s. If a Member wants to delete their account after cancelling their subscription, they can do so using the delete button on their profile page. 

2. ArenaPro Subscription: should a Professional wish to cancel their ArenaPro Subscription with Arena of Life, the Professional will need to cancel their account from the site profile (https://arenaoflifepro.com/) and thereafter send an email to Arena of Life at support@arenaoflife.com to request that all data attached to the ArenaPro and linked ArenaPro Member account/s be deleted from Arena of Life’s database. The Professional’s access to the ArenaPro will continue until the end of the cancellation year. Thereafter, the Professional will be granted the 14-day grace period in which it will retain access to the ArenaPro and can save any data contained therein should it wish to do so. Once the 14-day grace period has expired, the Professional will lose access to the ArenaPro account. No unused licenses purchased will be refunded to the Professional should they terminate their subscription.  Following the expiration of the 14-day grace period (either due to the cancellation of the Professionals account or the non-renewal of the Professional account), Arena of Life will retain the data linked to the Professional’s account for 60 days and thereafter, all data linked to the Professionals account will be deleted from Arena of Life’s database/s. 

3. ArenaPro Membership: The ArenaPro Member may, at any time, terminate their linked account by de-activating the unique invitation code which they used to Share their Arenas. Once the invitation code is de-activated through the App profile, the ArenaPro Member’s account will immediately be de-linked from the Professional’s ArenaPro account. This means that the ArenaPro Member will immediately cease sharing its personal information with the Professional and the Professional will lose the right to access the ArenaPro Member’s personal information. Thereafter, the ArenaPro Member’s account will remain active for a 14-day period wherein the ArenaPro Member may save its personal information as contained on its profile. Once the 14-day period has expired, all the ArenaPro Member’s information within the app that is connected to the Professional and its templates will be deleted from the Arena of Life database. Any non-connected information within the app added by the Member will be retained on Arena of Life's database for a further 60 days, and thereafter all information related to the ArenaPro Member's account will be deleted from Arena of Life database/s.

In the event that the ArenaPro Member is 13-17 years old (“the minor”), the Company has implemented certain additional cancellation measures whereby the parental guardian is able to cancel the ArenaPro Member account directly with the Professional (via the original invitation email and link provided therein). Once the account has been terminated, the ArenaPro Member or their parental guardian may send an email to support@arenaoflife.com and an email to the Professional and request that their personal information be deleted. Should the ArenaPro Member fail to request the deletion of its data, Arena of Life will retain the data for a 60-day period and thereafter all data relating to the ArenaPro Member will be deleted from Arena of Life's database/s. 

If a Professional cancels an ArenaPro Member’s account prior to the expiration of the license period, the ArenaPro Member will be notified of the cancellation and the effect of the change. The effect will be the deletion of any connected Templates and/or Arenas provided by the Professional, and any content or information shared and associated with those connected Arenas in 14 days. To provide the ArenaPro Member with adequate time to adjust to the effect of the change, they will be given (and notified of) a free 14-day extension period in which they will receive continued access to the contents of their shared data and may save such data. During this time, the Professional will not have access to any data that the ArenaPro Member has inputted as the cancelation will de-activate and disconnect the account and any associated Arenas in the ArenaPro account.

Upon expiration of the 14-day grace period, or when the ArenaPro Member changes their account type, whichever comes first, the ArenaPro Member will lose access to any content or information associated with the previously connected Template and/or Arenas.

Please note that upon your request to terminate your account, we will deactivate your account information (after the expiration of the 14-day grace period) from our active databases however, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with the applicable legal requirements. Should you wish that your personal information be deleted from Arena of Life’s database, do so via your profile or you may send an email to support@arenaoflife.com and request the deletion of all data related to your account. Should the ArenaPro Member fail to request the deletion of its data, Arena of Life will retain the data for a 60-day period and thereafter all data relating to the ArenaPro Member will be deleted from Arena of Life's database/s. 

Cookies and similar technologies: most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies if you chose to remove cookies or reject cookies, this could affect certain features or services of our Services. 

If you have questions or comments about your privacy rights, you may e-mail us at support@arenaoflife.com. 

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a do-not-track (“DNT”) feature or setting you can activate to signal your privacy preferences not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanisms that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in future, we will inform you about that practice in a revised version of this privacy policy.

Do California residents have specific privacy rights

In essence, yes if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request removal of unwanted data that you publicly post on our Services. To request removal of such data, please contact us using the contact information provided below and include the e-mail address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA privacy notice

The California Code of Regulation defines a “resident” as:

(1) Every individual who is in the state of California for other than a temporary or transitory purpose; and

(2) every individual who is domiciled in the state of California who is outside the state of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents”.

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past 12 months: