Atly PRIVACY POLICY

Last Updated: December 28, 2023

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Steps Solutions Ltd. d/b/a Atly  (together, “Atly” “we”, “our” or “us”) use, collect and store Personal Data we collect, disclose, or receive from or about you (“User”, “you”) such as in the following use cases:

  1. When you make use of our App Atly ("App")
  1. When you create an account
  2. When you post content or create content and post it, including any location that is made up of one or more posts  ( a “Step” / or place) in our App
  3. When you make a comment or otherwise interact with a Step or place
  4. When you add content or respond to an existing Step or place, including by liking, posting, rating, or or adding tags
  5. When you make a search of ( a “Step” / or place)  in Atly’ App
  6. When you share content in our App and/or in social media channels
  7. When you create a Map in our App (e.g., Public Map, Restricted Map, Community Map, Secret Map)
  8. When you create content and post it in, or otherwise interact with (including by liking, posting, rating, or adding tags), a specific Map in our App Atly
  9. When you share your phone number and Contact List
  1. When you browse or visit our website, https://www.atly.com (“Website”);
  2. When you make use of, or interact with, our Website
  1. When you subscribe to the email list / newsletters / blog
  2. When you contact us (e.g. customer support)
  1. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
  2. When you request a demo or a free trial
  3. When we use the Personal Data of our service providers and suppliers
  4. When we use the Personal Data of our customers
  5. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
  1. When you import content from your social media platforms to Atly
  2. When you export Atly content to your social media platforms

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What Personal Data we collect, why we collect it, and how it is used
  2. How we protect, store and retain your Personal Data
  3. How we share your Personal Data
  4. Additional information regarding transfers of Personal Data
  5. Your Privacy rights
  6. Use by children
  7. Public information about your activity on the services
  8. How can I delete my account?
  9. Links to and interaction with third party product
  10. Interaction with third party products
  11. Log files
  12. Use of Analytics Tools
  13. Specific provisions applicable under California privacy law
  14. Contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of this Privacy Policy, as indicated above.  If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data we collect

Why is the data collected and for what purposes?

Legal basis (GDPR only)

Third parties with whom we share your data

Consequences of not providing the data

When you make use of our App

When you create an account

  • Google or Facebook log-in
  • Full name
  • Email address
  • Phone number
  • Birth date
  • Profile image
  • Information if you choose to upload, sync and/or import it from your device (e.g., pictures)
  • Any other data you decide to provide/supply
  • To create an account
  • To log-in to your account
  • To improve the App
  • To allow people to see each other
  • To connect with friends in the context of the App

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to create an account)

3rd party platforms such as for the following purposes:

  • Amazon (Cloud)
  • Mixpanel (Analyze product usage)

Cannot create an account

Cannot log-in to your account

Cannot improve the App

Cannot allow people to see each other

Cannot connect with friends in the context of the App

When you post content or create content and post it, including any location that is made up of one or more posts

  • User name
  • Password
  • Photo / Pictures
  • Camera details
  • IP Address
  • Location of a point of publishing the content
  • Information in or about the content you provide (like metadata)
  • Value, subject, description, comments, messages
  • Flairs Feedback and rating (such as, like)
  • Any other data you decide to provide/supply

  • To enable you to create content
  • To perform the service
  • To publish your content
  • To help you and other users to find points of interest
  • To view and/or interact with your and other users content
  • To enable you to find points of interest
  • To give you accurate search results
  • To personalize and improve our services

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to enable you to find points of interest)

3rd party platforms such as for the following purposes:

  • Amazon (Cloud)
  • Mixpanel (Analyze user usage)

Cannot enable you to create content

Cannot perform the service

Cannot publish your content

Cannot help you and other users to find points of interest

Cannot enable you to find points of interest

Cannot give you accurate search results

Cannot personalize and improve the services

  • Geolocation

  • To enable you to find points of interest
  • To post your Step or place

Important note: To create a Step or place you need to be in the place at the moment of creation, or otherwise select a location on the relevant map

Consent

Cannot enable you to find points of interest

Cannot post your Step or place

When you make a comment or otherwise interact with a Step or place

  • Full name
  • User name
  • Email address
  • Content of the comment
  • IP Address
  • Region
  • Device model and details
  • Any other data you decide to provide/supply

  • To process and sharing your comments
  • To enable you to comment points of interest
  • To personalize and improve our services

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. publish your reviews of Atly)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot process and publish your comments

Cannot enable you to comment points of interest

Cannot personalize and improve our services

  • Geolocation

  • To enable you to find points of interest
  • To post your comments in the Step or place

Consent

Cannot enable you to find points of interest

Cannot post your comments in the Step or place

When you add content or respond to an existing Step or place, including by liking, posting, rating, or adding tags

  • Full name
  • User name
  • Email address
  • Hashtags
  • Photos
  • Content of the comment (description, title name, value, rating)
  • IP Address
  • Region
  • Device model and details
  • Any other data you decide to provide/supply

  • To process and sharing your comments
  • To enable you to comment points of interest
  • To personalize and improve our services

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot process and publish your comments

Cannot enable you to comment points of interest

Cannot personalize and improve our services

Legitimate interest (e.g. publish your reviews of Atly)

  • Geolocation

  • To enable you to find points of interest
  • To post your content in an existing Step or place

Consent

Cannot enable you to find points of interest

Cannot post your content in an existing Step or place

When you make a search of Atly in Atly’ App

  • User name
  • Email address
  • IP Address
  • Region
  • Distinct ID
  • Clicked element ID
  • Keyword
  • Any other data you decide to provide/supply us

  • To enable you to find points of interest in your next searches.
  • To understand user preferences and to improve the services
  • To help you and other users to find points of interest
  • To view and/or interact with your and other users content

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to enable you to do find points of interest in Atly App)

3rd party platforms such as for the following purposes:

  •  Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot enable you to find points of interest

Cannot understand user preferences and to improve the services

Cannot help you and other users to find points of interest

Cannot enable you to find points of interest

When you share content in our App and/or in social media channels

  • User name
  • Email address
  • IP Address
  • Region
  • Device model and details
  • Content
  • Social media channel used to share the content
  • Any other data you decide to provide/supply

  • To process your request
  • To share with friend a Step or place
  • To share by social media channels a Step or place
  • To understand user preferences and to improve the services
  • To help you and other users to find points of interest
  • To view and/or interact with your and other users content

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to process your request)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot your request

Cannot share with a friend a Step or place


Cannot share by social media channels a Step or place

Cannot understand user preferences and to improve the services

Cannot help you and other users to find points of interest

Cannot enable you to find points of interest

When you create a Map in our App (e.g., Public Map, Restricted Map, Community Map, Secret Map)

  • User name (as the admin name)
  • Name of the map and the brief definition of the Map
  • IP Address
  • Device model and details
  • Content
  • Permissions settings
  • Admin users and co-admin users
  • Any other data you decide to provide/supply

  • To create a Map in our App
  • To administrate the Map
  • Depending on the type of Map that the administrator decides to create, to share the Map with the users of the App and allow them to create content
  • To understand user preferences and to improve the services
  • To help you and other users to find points of interest
  • To view and/or interact with your and other users content

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to process your request)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot create a Map in our App

Cannot administrate the Map


Cannot share by social media channels a Step or place

Depending on the type of Map that the administrator decides to create, cannot share the Map with the users of the App and allow them to create content

Cannot understand user preferences and cannot improve the services

Cannot help you and other users to find points of interest

Cannot view and/or interact with your and other users content

When you create content and post it in, or otherwise interact with (including by liking, posting, rating, or adding tags), a specific Map in our App Atly

  • User name
  • Photo / Pictures
  • Camera details
  • IP Address
  • Location of a point of publishing the content
  • Information in or about the content you provide (like metadata)
  • Value, subject, description, comments, messages
  • Flairs
  • Feedback and rating (such as, like)
  • Any other data you decide to provide/supply

  • To enable you to create content in a Map
  • To perform the service
  • To publish your content in a Map
  • To help you and other users to find points of interest in specific Maps
  • To view and/or interact with your and other users content in the Maps
  • To enable you to find specific Maps
  • To enable you to find points of interest
  • To give you accurate search results
  • To personalize and improve our services

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to enable you to create content in a Map)

3rd party platforms such as for the following purposes:

  • Amazon (Cloud)
  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)

Fabric (beta testing and bugs analysis)

  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot enable you to create content in a Map

Cannot perform the service

Cannot publish your content in a Map

Cannot help you and other users to find points of interest  in specific Maps

Cannot enable you to find specific Maps

Cannot enable you to find points of interest

Cannot give you accurate search results

Cannot personalize and improve the services

  • Geolocation

  • To enable you to find points of interest
  • To post your Step or place

Important note: To create a Step or place you need to be in the place at the moment of creation

Consent

Cannot enable you to find points of interest

Cannot post your Step or place

When you make use of, or interact with our Website

When you browse or visit our website

Cookies, Log files and Analytic tools

For user preferences and to improve the services

Consent

Legitimate interest (e.g. essential cookies)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)

  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot collect and store the information

Cannot use or access some parts of the website

When you subscribe to the email list / newsletters / blog

  • Full name
  • Email address
  • Any other data you decide to provide/supply

  • To add you to our mailing list

  • To send marketing communications

Consent

Legitimate interest (e.g. send you more information about Atly)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot add you to our mailing list

Cannot send you marketing communications

When you contact us (e.g. customer support)

  • Full name
  • Email address
  • Comment
  • Any other data you decide to provide/supply

  • To answer questions

  • To provide you support

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. respond to a query sent by you)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot assist you and respond your query

Cannot provide support

When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data

  • Full name
  • Email address
  • Company name
  • Any other data you decide to provide/supply

  • To establish a business connection
  •      To send marketing communications

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract (e.g. showing you certain products and features that you have shown an interest in).

Legitimate interest (certain B2B marketing communications)

SalesForce (CRM)

Cannot establish a business connection

Cannot send marketing communications

When you request a demo or a free trial

  • Full name
  • Email address
  • Company name and number
  • Phone number
  • Any other data you decide to provide/supply

  • To provide a demo or a free trial
  • To send marketing communications

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

SalesForce (CRM)

Cannot provide a demo or a free trial

When we use the Personal Data of our service providers and suppliers

  • Full name
  • Email address
  • Company name and number
  • Phone number
  • Any other data you decide to provide/supply

  • To contact our service providers

  • To perform the applicable agreement

e

Processing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot communicate with you

Cannot perform the applicable agreement

When we use the Personal Data of our customer

  • Full name
  • Email address
  • Company name
  • Phone number
  • Any other data you decide to provide/supply

  • Providing our services

  • Performing the agreement

Processing is necessary for the performance of a contract to which our customer is a party.

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).

Legitimate interest (e.g. send you contract-related communications)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot provide the services

Cannot communicate with you

Cannot perform the agreement

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

When you import content from your social media platforms to Step, and when you export Atly content to your social media platforms

  • Full name
  • Email address
  • Company name
  • Any other data you decide to provide/supply

  • Establishing a business connection

Consent

Legitimate interest (e.g. send you more information about Atly)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot establish a business connection

When you share your phone number and contacts

  • Users number
  • Contact List
  • Contact numbers
  • Contact names
  • Contact photos

  • Letting others with the users info in their contacts find them on Atly and follow their recs
  • Allowing the user to find their contacts and follow their recs

Consent

Legitimate interest (e.g. friend/contact chose to send them information about the app)

3rd party platforms such as for the following purposes:

  • Mixpanel (Analyze user usage)
  • Appsflyer (Online campaign tool)
  • Firebase (Push notifications)
  • Fabric (beta testing and bugs analysis)
  • Cognito (Authentication tool)
  • Google Analytics (Analyze user usage)

Cannot easily be found  by friends on Atly.

Connot easily find friends on Atly.

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking Atly to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them)..

  1. PERIOD OF STORAGE OF COLLECTED INFORMATION

The information we collect will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings.

  1. HOW WE PROTECT, STORE AND RETAIN YOUR INFORMATION

  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromisedas a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

  1. Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.  We have an internal data retention policy to ensure that we do not retain your personal data perpetually.

  1.  HOW YOUR PERSONAL INFORMATION IS SHARED

4.1 We share your information as follows:

In addition to the recipients described in Section 1, we may share your information as follows:

4.2 You may share your information as follows:

You may share a Step or place:

  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

Storage: Amazon (AWS) Ireland.

Access from Israel: It is covered by Israel’s Adequacy Decision and involves no data transfer issue. You can read more about this here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en/

  1. YOUR PRIVACY RIGHTS

  1. The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
  1. You can exercise your rights by contacting us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
  1. USE BY CHILDREN

We do not offer our products or services for use by children under the age of thirteen (13) years. We do not intend to collect Personal Data from anyone we know to be under thirteen (13) years. If you believe that we might have any such information, please contact us at [email protected]. If you are under thirteen (13), you may not use the App, or provide any information to the Website and/or App without involvement of a parent or a guardian. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his/her consent, then he or she should contact us as described below. If we become aware that a child under the age of 16 has provided us with personally identifiable information, we will delete such information from our files. Further, the Children’s Online Privacy Protection Act (“COPPA”) requires parental consent for collection of data from children younger than the age of 13 years old. For tips on protecting children’s privacy online, generally, please view the U.S. Federal Trade Commission (“FTC”) website at https://www.ftc.gov/privacy/privacyinitiatives/childrens.html. For the purposes of the GDPR, we do not intend to offer information society services directly to children. Regardless, in the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it.

  1. PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES

  1. Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly, and other interaction you have with public content (such as liking, saving, rating, tagging) on the Site or otherwise through the Services.

  1. Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

  1. Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

  1. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing [email protected]. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

  1. INTERACTION WITH THIRD PARTY PRODUCTS


We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “
Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

  1. LOG FILES

We may use log files. We use such information to analyze trends, administer the Site, to find bugs and enhance our product, track users’ movement around the Site, and gather demographic information.

  1. ANALYTIC TOOLS

We reserve the right to remove or add new analytic tools.

  1. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
  1. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our subscribers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

  1. We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

  1. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

  1. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].