Last updated: September 25, 2024
This Privacy Policy outlines how we handle your personal information when you use our App Gemz services. It's a crucial part of our End User License Agreement (EULA) and applies to the collection, processing, and transfer of your personal data. Any capitalized terms used in this Privacy Policy but not defined here have the same meaning as given in our End User License Agreement (EULA).
This Privacy Policy explains how we collect, use, share, and protect your personal information. It also outlines your rights regarding your data, as required by the EU General Data Protection Regulation (GDPR), the Brazilian General Data Protection Law (LGPD), the California Consumer Privacy Act (CCPA), and other applicable U.S. state laws. If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: appgemz.official@gmail.com.This Privacy Policy outlines how we collect and handle your personal information when you use our App Gemz services.
Improved Table of Contents
I. Privacy Notice
A. Policy Amendments
B. Contact Information and Data Controller Information
C. Data Collection Methods
D. SDKs and Tracking Technologies
E. Data Sharing
F. Data Retention
G. Security Measures
H. International Data Transfer
I. User Rights K Opt-Out Options
J. Eligibility and Children's Privacy
II. Jurisdiction-Specific Notices
A. California Residents
B. Colorado Residents
Rights under CPA
How to Submit a Request
C. Virginia Residents
D. Connecticut Residents
E. Utah Residents (Effective January 2024)
F. Nevada Residents
We may update this Privacy Policy from time to time. The most recent version is always available on our website, and the "Last Modified" date indicates when it was last updated. We will notify you of any significant changes and obtain your consent as required by applicable law. Any updates will take effect 30 days after they are posted. We encourage you to review this policy regularly to stay informed about our privacy practices.
Our company is incorporated under the laws of Pakistan and is responsible for your personal data.
You can contact us or our Data Protection Officer (DPO) using the following information.
By email: appgemz.official@gmail.com
Representative for data subjects in the EU and UK Contact Information:
We prioritize your privacy and data subject rights. To make exercising those rights (like accessing or deleting your data) easier, we've appointed, along with their local partners, as our privacy representative. You can still reach us at appgemz.official@gmail.com. with any questions. If you prefer to contact directly, we'll happily provide their details upon request
This section provides details about how we use your personal information, our legal justification for doing so, the difference between personal and non-personal data, and our technical data processing methods.
Non-Personal Data
When you use our website and services, we may collect non-personal, non-identifiable information. This data, which doesn't reveal your identity, includes aggregated usage information and technical details like your browser type, device, language preferences, time and date, and location.
Personal Data
We may also collect from you directly or indirectly during your access or interaction with the website or Services individually identifiable information namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below.
We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
DATA SET
PURPOSE AND OPERATIONS
LAWFUL BASIS
Registration Information:
We use this information to fulfill our contract with you, create your account, and allow you to use our services.
We may also use your personal information to send you marketing messages about our services, such as promotions and new features. However, we understand you may not always want to receive these updates. You can easily opt-out of receiving marketing communications from us by clicking the "unsubscribe" link at the bottom of any marketing email or by contacting us at appgemz.official@gmail.com
If you unsubscribe from marketing emails, we may still keep your contact information to send you important service-related updates like invoices and subscription information. When you register for our services, we process your information to fulfill our contract with you. We use your information for marketing purposes based on our legitimate interest in promoting our services.
Contact Information:
When you contact us, we may ask for information like your name, job title, company, email address, and any other details you choose to share. We will use this data to respond to your inquiry.
GPS Location Information:
Some features require access to your location. We use precise location information in the background while you use the app to find Wi-Fi networks and provide our services. We use this location information to provide our services.
To provide personalized Wi-Fi network recommendations based on your location, we may use your precise location information in the background, even when you're not actively using the app. You can adjust your device settings to manage background location permissions. We don't store your GPS location information on our servers.
All processing is done directly on your device. We'll only access your location when you actively grant permission through in-app notifications.
Push Notifications:
We may store a Firebase Cloud Messages token for push notifications. You can stop receiving push notifications by disabling them on your device or uninstalling the app. We store Firebase Cloud Messages tokens to send push notifications from our server. Because tokens are non-personal data, we don't need a specific legal basis to process them.
In-App Payment Information:
All payments made through our app or services are in-app purchases and follow the terms and privacy policies of the applicable play store.
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We use in-app payment processors. The app store provider handles all registration and payment information, and we don't store or process any personal data related to your payments. We receive an order number associated with a user ID that was created when you installed the app. The user ID is non-identifiable. Payment information is processed to fulfill our contract with you and provide the services you requested.
Log Data and Unique Identifiers:
If you encounter an error in the app, we may collect data like 'Log Data' or 'Crash Data' (through third-party service providers). This information includes your device's IP address, name, operating system version, app configuration, time and date of use, and other technical details. While log and crash data typically doesn't contain personal information, we treat it as such because it might be possible to identify you. We use this data to protect and improve our app and services.
List of Installed App:
When you install our app, we may collect information from your device, including a list of installed apps. This data may contain personal information, so we treat it as such. We use this data to maintain, support, improve, protect, and manage our app and services. We'll obtain your consent to process this data through in-app permissions.
Profiling Data:
While using our app, you may see ads. Our advertising partners may use SDKs to collect data about you for targeted advertising. To opt-out of interest-based advertising, you can adjust your device settings. Look for options related to "Privacy" or "Ads. If you disable interest-based advertising, you might still see ads in our app, but they won't be personalized. This might affect your overall experience. Our advertising partners use this data to deliver more relevant ads, including contextual, behavioral, and interest-based ads based on your activities, preferences, and other information we or our partners have. This also includes retargeting ads. We process this data based on your consent, which you can manage through our cookie settings or similar tools.
Photos and Videos:
To use our editing and animation features, you may be asked to provide photos or videos (collectively "Content"). We only use this content to provide our services and don't use it for any other purposes. We use this content to provide the editing and animation services you requested. To create animated photos with emojis, we'll use the original photos you provide. We keep your original photos and animations for as long as you use our services. We don't store your photos or videos on our servers. All processing happens directly on your device. We process this information based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services.
Microphone and audio:
To use the dialer feature in certain apps, you'll need to grant microphone permissions. To use our dialer, you'll need to enable microphone permissions in our app or your device settings. Disabling these permissions may affect the dialer's functionality. We only use the microphone to provide the dialer feature and don't store any audio recordings. We don't store any audio files or information captured by your microphone. All processing related to microphone permissions happens directly on your device. We process this information based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services.
Call log and Contacts:
To use the dialer feature in certain apps, you'll need to grant permissions to access your call log and contacts. To use our dialer and identify callers based on your contacts, you'll need to enable call log and contacts permissions in our app or your device settings. Disabling these permissions may affect the dialer's functionality. We don't store your contacts or call log on our servers. All processing related to these permissions happens directly on your device. We process this information based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services.
Bluetooth and Network:
When you use our app, we may collect information about nearby devices and your network connection history through your Bluetooth and network permissions. To use our services, you'll need to enable Bluetooth and network permissions in our app or your device settings. Disabling these permissions may affect the app's functionality. We process this information based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services.
Calendar:
Some of our apps offer new design features for your device. To apply these designs, we'll need access to your calendar. To apply the design features, we'll use your calendar permissions. You can enable or disable these permissions in our app or your device settings. Disabling them may affect the app's functionality. We don't store any calendar data on our servers. All processing related to calendar permissions happens directly on your device. We process this information based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services.
Health Data:
Certain apps may access and process health-related data. This data is processed solely on your device, and we don't transmit it to our servers or allow it to leave your device. We use this health-related data to provide specific features and improve our app's performance. We process this health-related data based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services. We don't store your contacts or call log on our servers. All processing related to these permissions happens directly on your device. We process this information based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services.
The specific processing operations for each purpose and legal basis listed in the table may vary. These operations often involve automated processes like collection, storage, use, transmission, deletion, or destruction. As explained in the Data Transfer section, transferring personal data to third-party countries is based on the same legal grounds mentioned in the table.
We may use personal data to prevent and detect illegal activities, fraud, identity theft, and other misuse of our services. This helps us enforce our terms, protect our databases and services, and reduce legal risks. This processing is based on our legitimate interests. We may collect different types of personal and non-personal data based on how you interact with our website and services. If we combine this information, we'll treat it as personal data.
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
We automatically process this information based on your consent, which you provide through in-app permissions. This consent is necessary to fulfill our contract with you and provide our services.
When you voluntarily share information with us, such as by contacting us, we process it according to this Privacy Policy.
Provided from third-parties.
We use cookies, software development kits (SDKs), and other tracking technologies to improve our services, personalize your experience, and analyze how our apps and services are used. The specific SDK we currently use, the purpose of the SDK, their privacy policy and opt-out controls are set forth in the table below:
NAME
PURPOSE
PRIVACY AND OPT OUT
Google Play
In-app billing
Google Play Privacy Policy: https://play.google.com/about/privacy-security-deception
https://policies.google.com/privacy?hl=en
Firebase
• Remote Config- data
• Storage and processing location
• Crash lytic data
• Cloud Messaging
• data encryption
• security purpose
• a/b testing
• in-app messaging
• predictions
• analytics
Firebase Privacy Policy: https://firebase.google.com/support/privacy
Advertisers:
• AdMob
• AdColony
• Applovin
• Chocolate Platform
• Facebook Audience Network
• Index Exchange
• Media.net
• Mobfox
• OpenX
• PubMatic
• Rubicon
• Sharethrough
• Yieldmo
And as may be updated from time to time (collectively “Advertisers”).
Our advertising partners use targeted advertising SDKs to collect information about your browsing activity across different websites and services. This data is used to show you relevant ads on our app and other third-party services. The information collected doesn't identify you personally and helps us measure the effectiveness of our advertising campaigns.
• AdColony: https://www.adcolony.com/privacy-policy/
• AdMob: https://policies.google.com/privacy?hl=en
• Applovin: https://www.applovin.com/privacy/
• Chocolate Platform: https://chocolateplatform.com/privacy-policy/
• Facebook Audience Network: https://www.facebook.com/about/privacy/
• Index Exchange: https://www.indexexchange.com/privacy/
• Media.net: https://www.media.net/privacy-policy/
• Mobfox: https://www.mobfox.com/privacy-policy/
• OpenX: https://www.openx.com/legal/privacy-policy/
• PubMatic: https://pubmatic.com/legal/privacy/
• Rubicon: https://www.rubicon.com/privacy-policy/
• Sharethrough: https://www.sharethrough.com/privacy-center
• Yieldmo: https://yieldmo.com/privacy-policy/
We share your data with third-party partners and service providers who help us deliver our services. Here's a list of the types of third parties we share data with:
CATEGORY OF RECIPIENT
DATA THAT WILL BE SHARED
PURPOSE OF SHARING
Advertisers
Online Identifiers
We display ads and content that are relevant to our app and your interests. This is part of our services.
Service Providers
All data
We may share your personal data with third-party service providers who help us deliver our services. These include cloud and hosting providers, analytics and marketing firms, payment processors, fraud prevention tools, tracking tools, and other service providers. We have contracts with these providers that limit their use of your data and require them to implement strong security measures. They are only allowed to use your data to provide the specific services we request.
Any acquirer of our business
All data
In the event of a corporate transaction (like a sale, merger, or acquisition), we may share your personal data with our affiliated companies or the acquiring company. The new entity will be subject to the terms of this Privacy Policy. Governmental agencies, or authorized third parties. Subject to law enforcement authority request. We may disclose your data to law enforcement, government agencies, or authorized third parties if required by law, such as for investigations related to terrorism, criminal activities, or other illegal actions that could harm us, you, or other users. We'll only share the necessary information to comply with these requests.
When we share data with third-party service providers and partners, we ensure they only receive the information needed to fulfill their specific role in providing our services. These partners are obligated to protect the data they receive and use it solely for the agreed-upon purposes while complying with all relevant data privacy laws. They may use non-personal data for their own purposes.
We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy, comply with applicable laws, or until you choose to opt-out. Our data retention practices follow relevant regulations. We may retain your personal data for longer periods under these circumstances:
To comply with legal, regulatory, tax, or accounting requirements.
To document our interactions in case of disputes or complaints.
If we anticipate potential litigation related to your data.
We are not obligated to keep your data for any specific duration, except as required by law. We may delete it at any time without prior notice."
Improved Text:
We prioritize the security of your information and have implemented strong physical, technical, and administrative measures to protect it from unauthorized access, misuse, disclosure, destruction, or loss. If you believe your privacy has been violated or if you suspect unauthorized access to your personal data, please contact us immediately. We'll investigate and take appropriate action, including notifying you and relevant authorities as required by law.
We use Google Cloud servers located in the EU, US, and Asia. Additionally, some processing activities may occur in Israel or other countries. When we transfer your personal data outside of your jurisdiction, we implement appropriate measures to ensure it's protected according to applicable laws.
EU Data Transfers
When transferring personal data collected within the EU to countries outside the EU that the European Commission hasn't deemed to provide adequate protection, we use [specify the mechanism used for data transfers, such as Standard Contractual Clauses (SCCs)]. This ensures that your data remains protected in accordance with EU data protection laws. It shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.
Your Data Rights
Data protection laws grant you certain rights regarding your personal data, depending on your jurisdiction. These rights may include:
Access: You can request a copy of the personal data we hold about you.
Rectification: You can request correction of any inaccurate personal data.
Erasure: You can request deletion of your personal data, subject to certain exceptions (e.g., legal requirements).
Restriction of Processing: You can restrict how we process your personal data.
Data Portability: You may have the right to request transfer of your personal data to another service provider.
Right to Object: You can object to how we process your personal data.
Right to Withdraw Consent: You can withdraw your consent for us to process your data (where applicable).
Exercising Your Rights
To submit a request to exercise your rights, please fill out the Data Subject Request Form ("DSR") available [here](link to DSR form) and send it to our email at: appgemz.official@gmail.com
Verifying Your Identity and Processing Requests
When you contact us to exercise your data rights, we'll need to verify your identity and locate your personal data. This process may take some time. Data privacy laws in your jurisdiction may provide you with additional rights related to your data.
You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint.
Interest-Based Advertising (IBA)
We don't sell your personal data. However, some of our apps may show you personalized ads. This involves sharing your data with third parties for targeted advertising purposes.
Opting Out of IBA
You can opt out of sharing your personal data for cross-contextual interest-based advertising in several ways:
Device Settings: Adjust your device's privacy settings to limit ad tracking.
Industry Opt-Out Tools: Use industry-standard tools like the Network Advertising Initiative (NAI) opt-out tool (https://thenai.org/opt-out/) or the Digital Advertising Alliance (DAA) opt-out tool (https://optout.aboutads.info/).
Protecting Children's Privacy
Our services are not intended for children under 16 in the EEA or 13 in the US. We don't knowingly collect or process children's information. If we discover that a child has shared information with us, we'll delete it immediately.
If you believe a child has provided us with information, please contact us at: appgemz.official@gmail.com
This revised text clarifies the age restrictions and emphasizes your commitment to protecting children's privacy. It also provides a clear and easy-to-find contact point for reporting concerns.
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 ("CCPA") effective November 2020, and as amended by the CPRA, effective January 1, 2023.
Your California Privacy Rights
The California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA), grant you certain rights regarding your personal information. These rights include:
Right to Know: You have the right to know what personal information we collect about you, the categories of personal information we collect, the purposes for which we collect it, whether we sell your personal information, and the categories of third parties with whom we share your personal information.
Right to Delete: You have the right to request that we delete your personal information that we have collected from you. However, there are certain exceptions, such as when we need to retain your information to comply with legal obligations, detect security incidents, prevent fraud, or exercise other legal rights.
Right to Opt-Out of the Sale of Your Personal Information: You have the right to opt-out of the sale of your personal information. Please note that we do not sell your personal information.
Right to Opt-In to the Sale of Your Personal Information (for Minors): If you are under 16 years old, we will not sell your personal information unless you opt-in to such sale.
Right to Non-Discrimination: You have the right to not be discriminated against for exercising any of your CCPA rights.
How to Exercise Your Rights
The CCPA section you've provided is excellent! Here's how you can integrate the link to your full privacy policy and slightly improve the wording for clarity:
How to Exercise Your Rights
To exercise any of your CCPA rights, you can submit a verifiable consumer request to us by emailing at appgemz.official@gmail.com. We may require you to verify your identity by providing additional information, such as your name, email address, and any account information you have with us. For more details about the verification process and how we handle your CCPA rights requests.
Shine the Light Law
Additional Information
For more information about your CCPA rights, you can also visit the California Attorney General's website at https://oag.ca.gov/privacy/ccpa.
Effective Date
This section is effective as of January 1, 2023, and applies to California residents only.
CCPA Privacy Notice:
Please replace "link" with the actual URL of your full privacy policy.
Improvements:
The wording in "How to Exercise Your Rights" is slightly improved for clarity.
The "Shine the Light Law" and "Additional Information" sections remain unchanged as they are well-written.
The "Effective Date" section remains unchanged.
By incorporating the link to your full privacy policy, you provide users with a central location for all CCPA-related information. Additionally, the minor wording adjustment enhances clarity in the verification process. This comprehensive CCPA section demonstrates your commitment to user privacy and compliance with California law.
Colorado Privacy Act (CPA) Rights
If you're a Colorado resident acting as an individual or household (not in a commercial or employment context), you have certain rights under the Colorado Privacy Act (CPA) regarding your personal data.
Right to Access: You can request information about the personal data we collect about you.
Right to Correct: You can request corrections to inaccurate personal data.
Right to Delete: You can request deletion of your personal data, subject to certain exceptions.
Right to Opt-Out: You can opt-out of the sale of your personal data and the use of your personal data for targeted advertising.
Right to Data Portability: You can request a copy of your personal data in a portable format.
Right to Opt-Out of Profiling: You can opt-out of certain types of profiling.
Exercising Your Rights
To exercise any of your CPA rights, please submit a verifiable consumer request to us by emailing us at appgemz.official@gmail.com. We may require you to provide additional information to verify your identity before we process your request.
Additional Information
For more information about your CPA rights, please visit the Colorado Attorney General's website at https://coag.gov/resources/colorado-privacy-act/.
Effective Date
This section is effective as of July 1, 2023, and applies to Colorado residents only.
Data Definitions
Personal Data: Information that is linked or reasonably linkable to an identified or identifiable individual. This does not include publicly available information, de-identified or aggregated consumer data, or information excluded from the CPA's scope (e.g., HIPAA-covered health information, FRCA-covered financial data, GLBA-covered financial data, Driver's Privacy Protection Act data, COPPA data, FERPA data, or certain employment data).
Sensitive Data: Includes racial or ethnic origin, religious beliefs, mental or physical health conditions, sex life or sexual orientation, genetic or biometric data that can uniquely identify you, or children's data. We do not process or collect sensitive data.
Data Collection and Processing
For details on the personal data we collect, the purposes for processing, and the categories of third parties we share data with, please refer to the following sections in our Privacy Policy.
Section I.C: Data Sets We Collect and For What Purpose
Section I.F: Data Sharing – Categories of Recipients We Share Personal Data With
Note:
This revised text provides a clear and concise overview of Colorado residents' CPA rights.
It defines personal data and sensitive data, aligning with CPA terminology.
It directs users to relevant sections of the privacy policy for more detailed information on data collection and sharing.
The effective date is accurately stated.
This section explains how to exercise your rights, appeal our decisions, and opt-out of data sales.
Right to Access/ Right to Know
You have the right to confirm whether and know the Personal Data we collected on you
Right to Correction
Right to Deletion
You have the right to request the deletion of your personal data. However, we may deny or partially deny this request if we need to retain the information for the following reasons:
Completing Transactions or Providing Services: We may need to retain your data to complete a transaction you initiated, provide a service you requested, or fulfill contractual obligations.
Security and Fraud Prevention: We may retain data to detect and prevent security breaches, fraud, or illegal activity.
Product Debugging: We may need to retain data to identify and fix errors in our products.
Exercising Rights: We may retain data to protect our or others' rights to free speech or other legal rights.
Legal Compliance: We may be required to retain data to comply with legal obligations.
Research: We may retain data for public interest research, subject to certain conditions and your prior consent.
Internal Uses: We may retain data for internal purposes that are reasonably aligned with your expectations.
Other Lawful Uses: We may retain data for other lawful purposes that are compatible with how you provided it.
If we're not required to retain your personal data for any of the reasons listed above, we'll delete or de-identify it and instruct our service providers to do the same. You do not need to create an account with us to submit a request to know or delete. Right to Portability You have the right to receive your personal data in a structured, commonly used, and machine-readable format. This allows you to easily transfer your data to another service provider. We'll provide your data in a format that's easily usable and allows you to transfer it to another service provider. Right to opt out from selling Personal Data.
You have the right to opt out of the sale of your personal data for targeted advertising, the sale of your data to third parties for profit, or profiling that affects you or other consumers. You can authorize someone else to opt out on your behalf using tools like DAA or NAI. We don't sell your personal information. However, we may share it with third parties for personalized advertising. If you want to opt out of this, please refer to Section I.K OPT OUT OPTIONS.
To manage your cookie preferences, click on 'Do Not Sell or Share My Personal Information' at the bottom of our website. Right to opt out from Targeted Advertising. You have the right to opt out of the sale of your personal data for targeted advertising, the sale of your data to third parties for profit, or profiling that affects you or other consumers.
You can authorize someone else to opt out on your behalf using tools like DAA or NAI. We don't sell your personal information. However, we may share it with third parties for personalized advertising. If you want to opt out of this, please refer to Section I.K OPT OUT OPTIONS. To manage your cookie preferences, click on 'Do Not Sell or Share My Personal Information' at the bottom of our website.
Right to opt out from Profiling
You have the right to opt out of the sale of your personal data for targeted advertising, the sale of your data to third parties for profit, or profiling that affects you or other consumers. You may authorize another person acting on your behalf to opt out, including by broad technical tools, such as DAA, NAI, etc. We do not profile you, thus we do not need to provide an opt-out.
Right to Appeal
If we deny your request, we'll notify you within 45 days and explain why. We'll also provide instructions on how to appeal our decision. If we deny the appeal, you may contact the Colorado Attorney General using this link: https://coag.gov/office-sections/consumer-protection/ or (720) 508-6000. We'll respond to your appeal within 60 days with a written explanation of our decision.
Duty not to violate the existing laws against discrimination or non-discrimination. Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. We do not discriminate our users.
Only you or a legally authorized representative can submit a request to access or delete your personal data. If someone else submits the request on your behalf, we'll need proof of authorization (like a power of attorney or probate documents).
Responding to Your Requests:
We strive to respond to your verifiable data requests within 45 days of receipt. You can submit up to two requests per year. In exceptional cases, we may need an additional 45 days to respond. We'll notify you within the first 45 days if an extension is necessary.
Appealing Our Decisions:
If you're unhappy with our response to your request, you have the right to appeal. To initiate an appeal, contact us at appgemz.official@gmail.com. within a reasonable timeframe (e.g., 30 days) and specify your intent to appeal. We'll provide a written explanation of our final decision within 60 days of receiving your appeal.
Filing a Complaint:
If our final decision doesn't address your concerns, you have the right to file a complaint with the Colorado Attorney General's Office: https://coag.gov/file-complaint/.
Improvements:
Clearer language: Replaces technical jargon with everyday terms for better user understanding.
Concise and organized: Streamlines the text for easier reading.
Actionable steps: Provides clear instructions for appeals and complaints.
Additional Tips:
You can consider including a link to your full privacy policy for further details on data rights.
Highlighting the timeframe for submitting appeals can empower users to act within their rights.
By incorporating these changes, you create a more user-friendly and informative experience for users exercising their data rights under the Colorado Privacy Act.
Receiving Our Response
If you have an account with us, we'll send our response to that account or via email. If you don't have an account, you can choose between mail or electronic delivery. You don't need to create an account to submit a request.
Scope of Our Response
Our response will cover the past 12 months of your interactions with us. If we can't fulfill your request, we'll explain why.
If you're a Virginia resident acting as an individual or household (not in a commercial or employment context), you have certain rights under the Virginia Consumer Data Protection Act (VCDPA) regarding your personal data. Personal data refers to information that can be linked or associated with a specific individual. It doesn't include de-identified data or publicly available information. Additionally, the VCDPA excludes certain types of data from the definition of personal data, such as:
HIPAA-covered health information
GBPA-covered financial data
Non-profit entity data
Higher education data
Employment data
FCRA-covered financial data
Driver's Privacy Protection Act data
COPPA data
FERPA data
VCDPA Data Processing and Sharing
For details on the types of data we process, the purposes for processing, and the categories of third parties we share data with, please refer to the following sections in our Privacy Policy:
Section I.C: Data Sets We Collect and For What Purpose
Section I.F: Data Sharing – Categories of Recipients We Share Personal Data With
Data Sales and Opt-Outs
Information about data sales and how to opt out is provided in Section I.K OPT OUT OPTIONS and the Data Subject Request Form.
Your VCDPA Rights and How to Exercise Them
The table under Section II.B "Additional Notice to Colorado Residents" details your rights under the VCDPA and how to exercise them.
Note:
This revised text provides clear guidance on where to find information about data processing, sharing, and opt-out options.
It directs users to the relevant sections in the privacy policy for more details.
It highlights the availability of information about VCDPA rights in the specified section.
By incorporating these improvements, you're ensuring that users can easily find the information they need regarding the VCDPA and their rights.
Responding to Your Requests
We strive to respond to your verifiable data requests within 45 days of receipt. In exceptional cases, we may need an additional 45 days to respond. We'll notify you within the first 45 days if an extension is necessary.
Appealing Our Decisions
If you're unhappy with our response to your request, you have the right to appeal. To initiate an appeal, contact us at appgemz.official@gmail.com. within a reasonable timeframe (e.g., 30 days) and specify your intent to appeal. We'll provide a written explanation of our final decision within 60 days of receiving your appeal.
Filing a Complaint with the Virginia Attorney General
If our final decision doesn't address your concerns, you have the right to file a complaint with the Virginia Attorney General's Office: https://www.oag.state.va.us/consumercomplaintform.
Improvements:
Clearer language: Replaces technical jargon with everyday terms for better user understanding.
Concise and organized: Streamlines the text for easier reading.
Actionable steps: Provides clear instructions for appeals and complaints.
Direct link to complaint form: Includes a direct link for user convenience.
By incorporating these changes, you create a more user-friendly and informative experience for users exercising their VCDPA rights. We'll provide information in response to your request at no cost, up to twice a year. Excessive or repetitive requests may incur a fee. If we can't verify your identity using reasonable methods, we may ask for additional information. If verification fails, we may not be able to fulfill your request.
If you're a Connecticut resident acting as an individual or household (not in a commercial or employment context), you have certain rights under the Connecticut Data Privacy Act (CTDPA) regarding your personal data.
Improved Text:
Personal data refers to information that can be linked or associated with a specific individual. It doesn't include de-identified data or publicly available information. Additionally, the CTDPA excludes certain types of data from the definition of personal data, such as.
HIPAA-covered health information
GBPA-covered financial data
Non-profit entity data
Higher education data
Employment data
FCRA-covered financial data
Driver's Privacy Protection Act data
COPPA data
FERPA data
For information about the personal data we process, the purposes for processing, and the categories of third parties we share data with, please refer to Sections I.C and I.F of our Privacy Policy. Information about data sales and how to opt out is provided in Section I.K and the Data Subject Request Form. The table under Section II.B details your CTDPA rights and how to exercise them.
We'll respond to your request within 45 days. In certain cases, we may extend this deadline by an additional 45 days. We'll notify you of any extension within the initial 45-day period and explain the reason for the delay.
Responding to Your Requests
We strive to respond to your verifiable data requests within 45 days of receipt. In exceptional cases, we may need an additional 45 days to respond. We'll notify you within the initial 45 days if an extension is necessary and explain the reason.
Appealing Our Decisions
If you're unhappy with our response to your request, you have the right to appeal. To initiate an appeal, contact us at appgemz.official@gmail.com. within a reasonable timeframe (e.g., 30 days) and specify your intent to appeal. We'll provide a written explanation of our final decision within 60 days of receiving your appeal.
Filing a Complaint with the Connecticut Attorney General
If our final decision doesn't address your concerns, you have the right to file a complaint with the Connecticut Attorney General's Office:
Phone: (860) 808-5318
Improvements:
Clearer language: Replaces technical jargon with everyday terms for better user understanding.
Concise and organized: Streamlines the text for easier reading.
Actionable steps: Provides clear instructions for appeals and complaints.
Direct link to complaint form: Includes a direct link for user convenience.
We'll provide information in response to your request at no cost, up to twice a year. Excessive or repetitive requests may incur a fee. If we can't verify your identity using reasonable methods, we may ask for additional information. If verification fails, we may not be able to fulfill your request.
If you're a Utah resident acting as an individual or household (not in a commercial or employment context), you have certain rights under the Utah Consumer Privacy Act (UCPA) regarding your personal data. For information about the personal data we process, the purposes for processing, and the categories of third parties we share data with, please refer to Sections I.C and I.F of our Privacy Policy. Information about data sales and how to opt out is provided in Section I.K and the Data Subject Request Form. Further, the table above under Section II.B “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.
Nevada Data Sales Opt-Out
Nevada law grants residents the right to opt out of the sale of certain personal information. While we don't currently sell personal information as defined by Nevada law, you can still submit a request to opt-out. This ensures your preference is recorded and applied if our practices change in the future.