PRIVACY POLICY

The protection of your personal data is important to DYNAMITO INC, and its subsidiaries (collectively, “Company" or "us“). For more information about our subsidiaries, see “How We Share Personal Information.” When you use any of our websites or mobile applications (the “Consumer Relations Platform“), we may collect information about you, including information that can be used to identify you (“Personal information“). In addition, we may collect personal information from your health plan, your employer’s self-funded health plan, your employer, a Health Center provider, your pharmacy, and/or other similar types of entities (your “Sponsor”) or from other third parties described in this Privacy Notice. We collect this data to provide you with the Pages and functionality you request (the “Pages”), as well as for the other purposes described in this Privacy Notice.

 

This Privacy Notice is intended to help you understand: (A) what Personal Information we collect, how we collect it, how we use it, and how we share it, (B) the choices you have with your Personal Information, and (C) how we protect your Personal Information when you use the Sites. Please take a moment to review the terms of this Privacy Notice, which is incorporated into the Terms of Use that govern your use of the Sites. By accessing the Platform or using the Sites, you expressly agree that we may collect, process, and share your information (including Personal Information) in accordance with this Privacy Notice and the Terms of Use.

 

 

• Information We Collect.

 

 

When you interact with our Platform or use the Pages, we may collect the following types of information.

 

1. Personal information

We may collect personal information that includes, but is not limited to, the following categories:

 

• Name;
• Date of Birth;
• Email address;
• Home address;
• Phone number;
• Payment information; and
• Geolocation data.

 

1. Usage Information

We may collect certain information automatically when you visit the Platform (“Usage Information”), including:

 

• The type of browser and its operating system;
• Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and which can sometimes be used to derive your general geographic area;
• Geolocation information;
• Other unique identifiers, including mobile device identification numbers;
• Pages you visited before and after visiting the Platform;
• Pages you view and links you click within the Platform;
• Information collected through cookies, web beacons and other technologies;
• Information about your interactions with email messages, such as the links you clicked and whether the messages were opened or forwarded; and
• Standard server log information.

 

Except as required by applicable law, we consider Usage Information to be Personal Information. However, Usage Information may be combined with your Personal Information. To the extent we combine Usage Information with your Personal Information, we will treat the combined information as Personal Information under this Privacy Notice.

 

1. How We Collect Information

 

We may collect personal information in the following ways:

 

1. From You

We may receive Personal Information directly from you, such as your name, contact information (e.g., email address, home and business addresses, and phone number), gender, and date of birth. You may also choose to provide Personal Information regarding your personal interests when you participate in various activities (e.g., attending an Event, participating in Forums, or participating in contests or sweepstakes or promotions). Additionally, you may be asked to provide Personal Information when you send us inquiries through the chat feature, email, or otherwise contact us.

 

1. From a Content Partner

We may receive Personal Information from a third party or external content provider, such as your participation in an Event.

 

1. Through Other Technologies

The Company and third parties we work with may use automated means to collect Usage Information about you, your computer or other device that you have used to access the Platform and the Pages. These automated means include technologies such as cookies, web beacons and similar technologies. These technologies help us analyze trends, administer the Pages, track your movements around the Platform, gather demographic information about our user base and provide you with relevant content. We may receive reports about individuals as well as in the aggregate through our use of these technologies and any third-party page providers acting on our behalf.

 

1. Cookies and tokens

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Sites may use HTTP cookies, HTML5 cookies, Flash cookies, and other types of local storage (such as browser-based or plug-in-based local storage). Your browser can tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You can also delete your Flash cookies or adjust your Flash cookie settings by visiting the Flash Storage Settings Manager on the Adobe Flash website. Please note, however, that without cookies you may not be able to use all the features of our Sites.

Our cookies, tokens, and similar technologies (collectively, “Tracking Technologies”) are also used to administer the Sites, including, but not limited to, for authentication, to remember your settings, to personalize the content and layout of the Sites for you, to contact you about the Sites, and to improve our internal operations and the content of our Pages. To learn more about cookies and similar tracking technologies, and how they may affect your privacy, please visit allaboutcookies.org.

 

You may be able to control the use of, or reject or disable, some tracking technologies at the individual browser level. If you reject or disable tracking technologies, you may still use our Platform and our Sites, but your ability to use some features may be limited. We use tracking technologies to identify your device and track your Internet session with our Sites. We also use Tracking Technologies that allow us to recognize your device when you return to the Platform within a certain period of time (as determined by us in our sole discretion) and automatically log you back into your account with us.

 

1. Pixels / Web Beacons

To control which servers collect information by automated means, we may place tags on our Platform called “web beacons.” Web beacons (sometimes called clear GIFs or web bugs) are small strings of code that provide a way for us to deliver a small (usually invisible) graphic image on a web page or in an email. Web beacons can recognize certain types of information on your computer, such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. We may also include web beacons in email messages to record whether an email has been opened or certain links in an email have been clicked.

 

iii. Online Analytics

We may use third-party analytics sites, such as Google Analytics, to evaluate your use of the Site, compile reports on website activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform. Google Analytics is a web analytics site provided by Google, Inc. (“Google”). Google Analytics places cookies on your computer to help the Website analyze how users use the Site. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of the Site, compiling reports on website activity for website operators and providing other sites relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on behalf of Google. Google will not associate your IP address with any other data held by Google. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. To learn more about Google Analytics, visit the Google website and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

 

1. From Public Sources and Third Parties

We also obtain Personal Information from public sources and records. We either collect this information ourselves or pay third parties to collect and compile it for us. In addition, we may pay third parties for data sets that contain Personal Information but are not publicly available.

 

1. Through “Just in Time” Disclosures

We may also provide “just-in-time” disclosures or additional information about our collection, use and disclosure of Personal Information. These may supplement or clarify our privacy practices or may provide you with additional choices about how we process your Personal Information.

 

 

• How we use Personal Information.

 

 

We may use the information we collect from you for the following purposes:

 

1. Provide you with the Pages

We may use the Personal Information we collect through your use of the Platform and the Pages for numerous purposes, including:

 

• Personalize the Pages for you;
• Respond to or comply with any of your requests;
• Manage and administer your account;
• Authenticate your identity;
• Identify you when you register;
• Provide you with Content, including, but not limited to, generating recommendations (such as recommended activities, Pages, benefits or rewards) and processing your preferences and requests;
• Track your use of the Site and the progress of the activities in which you participate;
• Track and show them with the rewards you earn;
• Administer newsletters and provide you with information about the Pages and activities in which you have chosen to participate or which may be of interest to you;
• Administer any contest or promotion, including winner notification and prize delivery;
• Communicate with you and respond to your questions and requests; and
• Improve the Platform and Pages.

 

1. Data Aggregation

In addition, we may use your Personal Information to create aggregated data records (collectively, “Aggregate Data”). Some of this Aggregate Data is anonymous and/or de-identified. We anonymize and de-identify the data by removing information (including any contact information) that would allow the remaining data to be linked to you. We may use Aggregate Data for internal purposes, such as analyzing patterns and program usage to improve our Pages. In addition, we may use Aggregate Data to analyze and understand demographic trends, user behavior patterns and preferences, and information that can help us enrich the content and quality of the Pages.

 

1. Compliance with Laws and Protection of Rights

We may use your Personal Information as necessary to comply with applicable laws. We may also use your Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

 

1. Analytics

We use analytics, machine learning and automated decision-making technologies (“Analytics”) to support our data processing activities.

 

Additionally, we use Analytics to provide personalized recommendations.

 

1. How We Share Personal Information

 

We will only disclose Personal Information to the following entities:

 

1. With an Event or Content Provider.

We may provide your name, contact information, and other Personal Information as part of our contract with any Content provider or an Event for which you register. We may also provide Personal Information associated with the activities you have chosen to participate in, your progress, and any rewards you have earned.

 

1. With a Third Party Provider

We may, without your consent, share Personal Information collected through our Site with third-party Site providers who act on our behalf or on our behalf in providing the Site. These third-party Site providers may need information about you to perform their functions. In cases of onward transfer of Personal Information from European Union or Swiss individuals received pursuant to the Privacy Shield (as defined below in the Privacy Shield section), the Company is responsible for ensuring that the third parties use, protect and share such Personal Information in accordance with this Privacy Notice.

 

1. Aggregate Data

We may provide Aggregated Data to third parties, including a provider of Events or Content. We may make anonymous Aggregated Data public on our site. We do not limit a third party's use of anonymized Aggregated Data other than to require that they do not attempt to make the Aggregated Data personally identifiable by combining it with other data.

 

1. Publicly

You have the option to participate in public portions of the Site (for example, message boards and community forums), you should have no expectation of privacy in any information you post in public areas of the Site, and your user name may be visible to others using the Site. You may also choose to participate in certain public contests, and some of your Personal Information may be posted on a winner's page, newsletter, or other announcement.

 

1. Private Messaging

You may choose to communicate with other users through the Sites and those other users may see certain Personal Information, such as your username and any other information you choose to share. If you send an email to a user or invite a non-user to join our Site, we will provide your name and email address to the intended recipient. Please do not provide us with another person's email address or any Personal Information unless that person has expressly agreed that you may do so or you are legally authorized to provide such Personal Information.

 

1. Commercial Transfers

In the event that we enter into or intend to enter into a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change in control or other disposition of all or any portion of our business, assets or stock, we may share Personal Information with third parties in order to facilitate and complete the transaction. If such a transaction occurs, the successor organization's use of your Personal Information will continue to be subject to this Notice and any privacy preferences you have expressed to us.

 

1. Compliance with Laws and Protection of Rights

We may disclose your Personal Information to comply with laws, court orders, or subpoenas. We may also disclose your Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others. We may also be required to disclose an individual's Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

 

1. Communications with You.

 

By registering on our Site, you agree to receive regular communications from us, as well as from your Sponsor and any relevant Connect Partners. With your consent, we may communicate with you by email, post, phone, text or SMS message.

 

1. Text Messaging and SMS Policy

You will have the option to opt-in to receive certain communications from the Company via text or SMS messages. By providing your express consent to receive text or SMS messages from the Company, you agree to our Terms of Use and acknowledge that you may receive alerts about your account, reminders to take certain actions, or details about new products and features.

 

To stop receiving text or SMS messages, you may reply to any message with STOP or send an email to unsubscribe@noelschajris.fan If you are subscribed to receive multiple types or categories of messages, you may need to opt out of each type or category of message separately. We may use third-party software to facilitate our text or SMS communications.

 

1. Promotional Emails

We may send you promotional emails about our Platform, Sites or other materials which we think may be of interest to you. If required by applicable law, we will obtain your consent before sending you marketing emails.

 

1. Drop out

You may opt out of promotional communications by clicking the link at the bottom of any promotional email, through your preferences on the Platform, or by contacting us at unsubscribe@noelschajris.fan.

 

1. Your Choices.

 

We respect your right to make choices about the ways in which we collect, use and share your Personal Information. The choices listed above are your choices about the delivery of cookies to your computer through our Site. In addition, we will sometimes ask you to indicate your choices at the time we collect your Personal Information. For example, we may provide you with the opportunity to “opt in” or “opt out” of receiving certain communications from us. In addition, we include an “unsubscribe” link in electronic newsletters or promotional emails we send you so that you can let us know if you no longer wish to receive such communications from us. When you make a request in this section, we may ask you for additional information to verify your identity. We may limit or deny your request if we are permitted or required to do so by law or if we are unable to verify your identity. We will respond to you within a reasonable time and, in any event, within the time limits set forth by applicable law.

 

You can exercise control over your Personal Data in the following ways:

 

1. Preferences expressed above

 

When you first register to use the Platform, you may set certain preferences regarding how we use your Personal Information and communicate with you. If you are a user of the Platform, you may change any previously expressed preferences regarding how we use your personal information by visiting the “Profile & Settings” in your account once you are logged in or by contacting us at customerservice@noelschajris.fan.

 

1. Consent

By registering and using our Platform, you expressly consent to our collection, use and disclosure of Personal Information in accordance with this Privacy Notice. If you provide additional Personal Information while using our Platform and pages, you further consent to our collection, use and disclosure of this Personal Information in accordance with this Privacy Notice.

 

You may have the right to withdraw your consent by sending an email to unsubscribe@noelschajris.fan. However, your withdrawal of your consent may restrict your ability to use the Platform and the Pages.

 

1. Update and Correction

If you are a Platform user, you may update or correct much of your Personal Information by visiting the “Profile & Settings” page once you are logged in. If you are unable to make the necessary updates or corrections there, please contact us. For Personal Information we receive from a Sponsor or Connect Partner, you may need to contact them directly to update or correct your Personal Information.

 

1. Your Publications

You may have limited rights to edit or delete any content you post, share or distribute on our site that includes your Personal Information, depending on the specific part of the page on which it is posted. For example, a user will not be able to edit or delete information posted in a public forum. To request removal of information you have made available on the Platform, please contact us at customerservice@noelschajris.fan. We will need: (i) a complete description of the content you would like to remove, and (ii) the web address(es) of the content you would like to remove. Please note that our compliance with this request does not ensure complete removal of the content or information you have posted on our Platform.

 

Nota: If you delete your content or remove your content from view by others, such information may still be stored in other databases, specifically, including those kept for archival purposes. While we will make every effort to comply with your request to remove some of your User Content, any content that has previously been shared with a third party with your consent will be subject to their own privacy policies and user agreements and we are unable to remove it. We will make no effort to recover deleted content to erase it from our archives. Users should be aware that any user-generated content they post may have been republished or distributed prior to its removal and may remain publicly available elsewhere on the Site.

 

1. Notice to European Union Residents

 

The following terms, obligations and rights apply only to individuals residing in the European Union (“UE“) or Switzerland if and to the extent we make our Platform or the Site available to such persons.

 

1. Legal Basis for Processing Information

If you are located in the EU or Switzerland, we rely on several legal bases to process your Personal Information. These legal bases include where:

 

• Processing is necessary to fulfill our contractual obligations, such as providing our Pages to you;
• You have given your prior consent, which you may withdraw at any time (for example, for marketing purposes or other purposes for which we obtain your consent from time to time);
• Processing is necessary to comply with a legal obligation, court order, or to exercise or defend legal claims;
• Processing is necessary for the purposes of our legitimate interests, such as improving, personalizing and developing our Sites, marketing new features or products that may be of interest and promoting safety and security as described above.

 

If you have any questions or would like further information regarding the legal basis on which we collect and use your Personal Information, please contact us by sending an email to customerservice@noelschajris.fan.

 

1. Rights under the General Data Protection Regulation

If you are located in the EU or Switzerland, you have the following rights with respect to your Personal Information that we hold:

 

• Right of access. The right to obtain access to your Personal Information.
• Right to rectification. The right to obtain rectification of your Personal Information without undue delay where such Personal Information is inaccurate or incomplete.
• Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• Right to restriction. The right to obtain restriction of our processing of your Personal Information in certain circumstances, such as where you contest the accuracy of the Personal Information, for a period enabling us to verify the accuracy of that Personal Information.
• Right to portability. The right to portability allows you to easily move, copy or transfer Personal Information from one organization to another.
• Right to object. You have the right to object to processing based on legitimate interests and direct marketing.

 

If you would like to exercise one of these rights, please submit a request using the Individual Data Rights Request form. Before acting on your request, we may request additional information to verify your identity. Please note that we may be legally or contractually prohibited from acting on your request. For example, if a statute requires us to retain elements of your Personal Information or if your Sponsor expressly requires us to obtain your consent before deleting Personal Information you have provided to us. If this is the case, we will respond to your request with an explanation and, if applicable, additional steps you can take.

 

You also have the right to lodge a complaint with your local data protection authority. You can find out more about how to contact your local data protection authority at

http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

1. Obligations to Data Protection Authorities (“DPA”)

We will respond promptly and appropriately to DPA requests regarding this Policy or compliance with applicable data protection privacy laws and regulations. Upon request, we will provide DPAs with the names and contact information of the persons designated to handle this process. With respect to transfers of Personal Information, we will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With respect to transfers of data to third parties, we will comply with the DPA's decisions relating thereto and cooperate with all DPAs in accordance with applicable law.

 

1. Contacting Our Data Protection Officer

To contact our designated Data Protection Officer, please email ______@noelschajris.fan.

 

1. Notice to California Residents

 

1. California Consumer Privacy Act

We comply with the California Consumer Privacy Act (“CCPA”). If you are a California resident, you have several additional rights available to you, including:

 

• The right to access your Personal Information;
• The right to obtain your Personal Information in a portable format;
• The right to have your Personal Information deleted from our databases; and
• The right to deny us the right to sell your Personal Information;

 

If you would like to make a request under the CCPA, please email us at __________@noelschajris.fan.

 

We will provide a list of the categories of Personal Information, if any, disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, along with the names and addresses of these third parties. This request may not be made more than once per calendar year. We reserve the right not to respond to requests sent other than to the email or mailing address specified above. Please include “California Privacy Rights” in the subject line and in your request. You must provide us with specific information about yourself so that we can accurately respond to the request.

 

The Site collects the following categories of personal information from its users:

 

Category	Example	Compiled
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.	SI
B. Categories of personal information listed in the California customer records statute (Cal. Civ. Code § 1798.80(e))   Note: Some personal information included in this category may overlap with other categories.	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial, medical, or health insurance information.	SI
C. Protected classification characteristics under federal or California law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, genetic information (including familial genetic information).	SI
D. Business Information.	Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming history or tendencies.	SI
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystrokes, gait, or other physical patterns, and sleep, health, or exercise data.	DO NOT
F. Internet or other similar network activity.	Browsing history, search history, information about a consumer's interaction with a website, application, or advertisement.	SI
G. Geolocation data.	Physical location or movements.	SI
H. Sensory data.	Audio, electronic, visual, thermal, olfactory or similar information.	DO NOT
I. Professional or employment-related information.	Current or past work history or performance evaluations.	DO NOT
J. Nonpublic education information (under the Family Educational Rights and Privacy Act (20 USC Section 1232g, 34 CFR Part 99)).	Educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class rosters, student schedules, student identification codes, student financial information, or student disciplinary records.	DO NOT
K. Inferences Drawn from Other Personal Information.	Profile that reflects a person's preferences, characteristics, psychological tendencies, predispositions, behavior, attitudes, intelligence, skills and aptitudes.	SI

 

1. Personal information does not include:

 

• Publicly available information from government records.
• Anonymous or aggregated consumer information.

 

1. Sale of Personal Information

 

We do not resell the Personal Information we collect from any consumer.

 

1. Nondiscrimination

 

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

 

• Denying goods or services.
• Charging you different prices or rates for goods or services.
• Provide you with a different level or quality of products or
• 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, and you may consent to receive, certain incentives permitted by the CCPA. Any CCPA-permitted incentive we offer will be reasonably related to the value of your Personal Information and will contain written terms describing the material aspects of the program. You may revoke your consent to participate in or receive such financial incentive at any time.

 

1. Access to Specific Information; Data Portability Rights.

 

You have the right to request that we disclose to you certain information 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: (A) the categories of Personal Information we collected about you; (B) the categories of sources of the Personal Information we collected about you; (C) our business or commercial purpose for collecting or selling that Personal Information; (D) the categories of third parties with whom we share that Personal Information; (E) the specific pieces of Personal Information we collected about you (also called a data portability request). If we sold or disclosed your Personal Information for a business purpose, we will provide you with two separate lists disclosing such sales or disclosures, identifying the categories of Personal Information each category of recipient purchased or otherwise obtained.

 

1. Rights of Deletion

 

You have the right to request that we delete your own Personal Information that we collect and maintain from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

 

An exception to your request may apply if it is necessary for us or our service providers to retain the information 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, or 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 harm the
• Exercise freedom of expression, ensure the right of another consumer to exercise their freedom of expression rights or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546, etc.).
• 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 deletion of the information would likely render impossible or seriously impair the achievement of the research, if you previously provided information
• Allow only internal uses that are reasonably aligned with consumer expectations based on their relationship with us.
• Comply with a legal obligation.
• Make other internal and legal uses of that information that are compatible with the context in which it was provided

 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (A) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (B) 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 that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requester's identity or authority to make the request.

 

1. Respond to your requests

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will provide our written response to that account. If you do not have an account with us, we will provide 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 are unable to comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and allows you to transmit the information from one entity to another 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 your request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

1. Do Not Track Signals

We do not recognize or respond to browser-initiated Do Not Track signals.

1. Data Protection.

 

1. Usually

We maintain reasonable administrative, physical, and technological measures to protect the confidentiality, privacy, and security of your Personal Information, based on the nature of the information provided. Unfortunately, no website, server, or database is completely secure or “hacker-proof.” Therefore, we cannot guarantee that the Personal Information you provide will not be disclosed, misused, or lost by accident or unauthorized acts of others.

1. Retention

We retain Personal Information after we stop providing Pages to you in order to monitor, detect and prevent fraud. We also retain Personal Information to comply with our tax, accounting and financial reporting obligations, where we are required to retain data by our contractual commitments (for example, with your Sponsor or a Connect Partner), and where data retention is required by law. When we retain data, we do so in accordance with the limitation periods and record retention obligations imposed by applicable law. Please note that we may delete your Personal Information at your sponsor's request or if we are contractually or legally required to do so.

If you have consented to receive marketing materials from us, we will retain your Personal Information for as long as we have your consent to send you marketing materials. In addition, we indefinitely retain anonymized, de-identified and/or aggregated data in a manner that removes identifiable Personal Information from it.

1. External Web Pages.

Our Platform or our pages may contain links to other websites, including sponsor pages and Connect partner pages. In addition, other users may post links or references to other websites. Please be aware that we are not responsible for the privacy practices of other websites, regardless of whether the link was provided by us or posted by a user on the Platform. The Company does not monitor the content, security or appropriateness of such external websites. As such, this Privacy Notice only applies to information collected by us on the Platform. We do not control and are not responsible for any use of your Personal Information by or through third-party websites. By linking to an external website, you assume the risk that the Personal Information you provide on that website may be viewed or used by third parties. When visiting any website, you should review that website's privacy policies and terms of use before providing any Personal Information.

1. Children's Information.

You must be at least thirteen (13) years old to access the Platform or the Pages. We do not request or collect Personal Information from anyone under the age of 13. If a user submitting Personal Information is suspected of being under the age of 13, we will require that user to close his or her account and will do so, as well as take steps to delete the information as soon as possible. If you are aware of anyone under the age of 13 using the Platform, please email us at customercare@noelschajris.fan so that we can take steps to prevent such access.

Although we do not collect Personal Information from individuals under the age of 13, third parties may provide us with information about these individuals. For example, a Sponsor or the individual's parent or legal guardian may provide us with such Personal Information. In the event that we receive Personal Information about individuals under the age of 13, we will process, store, and disclose such Personal Information in accordance with all applicable laws.

1. Contact the Company.

If you have any questions about this Notice or our privacy practices, please contact us at customerservice@noelschajris.fan.

1. Updates.

We may add features and/or functionality to our Site or Platform that may involve the collection, use or sharing of Personal Information in new ways. To inform you of these changes, we may update or revise this Privacy Notice. Accordingly, we reserve the right to update or modify this Privacy Notice at any time, without prior notice, by posting the revised version of this Privacy Notice on our Platform. Your continued use of our Platform or Site after we have posted the revised Notice constitutes your agreement to be bound by the revised Privacy Notice.

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