CCPA Notice

Last update: January 20, 2020

WHAT IS CCPA?

The California Consumer Privacy Act (CCPA) is a piece of consumer privacy legislation which came into affect on January 1, 2020 regulating how businesses can handle the personal information of California residents. CCPA creates new rights of California consumers relating to the access to, deletion of, and sharing of personal information that is collected by businesses.

WHAT RIGHTS CCPA PROVIDES ME?

The CCPA provides California residents with 5 core rights to data privacy:

1. Right to opt out.

Under CCPA each California resident can request any business stops selling personal information to third parties.

Do we sell your personal information?
No, we do not sell your personal information.

We are not making money from selling your personal information. Particularly, in the last 12 months we have not sold personal information about you, but we have disclosed some categories of personal information we collect, explained in Privacy Policy, to our subsidiary in Belarus, Mobile Analytics LLC, and to the third parties for business purpose.

Our business purpose includes:

• Registration of new customers,
• Processing and delivering of orders including managing payments, fees and charges, collecting and recovering money owed to us,
• Managing relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey,
• To enable you to partake in a prize draw, competition or complete a survey,
• Administration and protection of our business, website/products (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data),
• Delivering of relevant website content and advertisements to you and measuring or understanding of the effectiveness of the advertising we serve to you,
• Usage of data analytics to improve our website, products/services, marketing, customer relationships and experiences,
• Making suggestions and recommendations to you about goods or services that may be of interest to you.

To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see our Cookie Policy for more information including how you may be able to exercise your rights to opt-out of cookies or Contact us to disable cookies.

2. Right to be informed.

You have a right to be informed about what categories of personal information we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.

3. Right to disclosure.

You can request us to disclose what personal information we have collected on you in the past 12 months.

We can assure you that our Privacy Policy is an relevant document where you can find information about what personal information we have collected about you over the past 12 months and intend to collect (paragraph 2), sources of your personal information (paragraph 3) and how we use your personal information (paragraph 4). We regularly update our Privacy Policy, at least once every 12 months, so you always have complete and up-to-date information about how we handle your personal information.

You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.

When providing information under the right of access, we will provide you with the following information:

• The categories of personal information we are collecting about you,
• The categories of sources of the personal information,
• The purpose for collecting your personal information,
• The categories of any third parties with whom we share your personal information,
• The specific pieces of personal information collected about you.

4. Right to deletion.

You can request us to delete the personal information we have collected on you in the past 12 months.

We fully recognize you right to deletion, however, we would like to note that in some cases we are obliged to keep you personal information for certain period of time. For instance, if we need to provide services to you, detect or resolve issues security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.

5. Right to equal services and prices.

California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights.

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

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

HOW TO EXERCISE MY RIGHTS?

If you wish to exercise any of the rights specified above, please contact us at [email protected] using the following form.

Mandatory verification: We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to disclosure and/or the right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to disclosure and/or right to deletion, particularly where we are unable to verify your identity.

RESPONSE TIMING AND FORMAT

We endeavor 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, at your option.

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 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.

CHANGES TO OUR CCPA NOTICE

We reserve the right to amend this CCPA notice at our discretion and at any time. When we make changes to this CCPA notice, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.