CCPA Privacy Notice Addendum

For California Consumers

This California section supplements the Privacy Policy and applies solely to California consumers. The Table below describes how we process California consumers’ personal information (excluding our personnel), based on definitions laid out in the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").

Not all of the items listed in the Table below are relevant to you. For example, we do not collect Social Security numbers from our users, but we may collect this data in the course of evaluating a job applicant.

Personal Information Processing Activities

Some of the information we collect also constitutes “sensitive personal information” under the CCPA, including information that reveals your social security, driver’s license, state identification card, or passport number, precise geolocation, racial or ethnic origin, sex life or sexual orientation, religious or philosophical beliefs, biometric information, and contents of your messages. We do not use sensitive personal information we collect for purposes other than providing and improving our services to you and protecting our services and our community, and we do not use sensitive personal information to infer characteristics about you.

How Long We Retain Your Information

We retain your personal information only for as long as we need it for legitimate business purposes and in accordance with applicable law. If you decide to stop using our services, you may close your account and your profile will no longer be visible to other members. Once your account is closed, we will delete your personal information as follows:

To protect the safety and security of our members, we implement a retention period of several years after account closure or account suspension. During this period, we retain your information in case we need to investigate illegal or harmful activities. Retaining information during this security retention period is based on our legitimate interests as well as those of potential third parties.

After the secure storage period ends, we delete your data and only retain limited information for specific purposes, as set out below:

a) We retain limited data to comply with legal data retention obligations: in particular, we store transaction data for 10 years to comply with tax and accounting regulations, credit card information for the entire period during which the user can dispute the transaction , and “traffic data”. /logs for one year to comply with legal data retention obligations. We also retain records of the consent participants provide to us for five years to confirm our compliance with applicable laws.

b) We retain limited information based on our business purposes: We retain customer service records and supporting data, as well as inaccurate download/purchase locations, for five years to support our customer service decisions, enforce our rights, and enable us to protect myself. in the event of a claim, information about the existence of past accounts and subscriptions that we delete several years after the closure of your last account to ensure correct and accurate financial forecasting and reporting, one year of profile data in anticipation of potential litigation, to establish, exercise or defend legal claims, as well as data necessary to prevent members who have been prohibited from opening a new account from opening a new account for as long as necessary to ensure the safety and vital interests of our members.

c) Finally, we retain information based on our business purposes when there is an unresolved or potential problem, claim or dispute that requires us to retain the information (particularly if we receive a valid legal subpoena or request to retain the data (in which case we will need to retain the data to comply with our legal obligations) or if the data is otherwise required as part of legal proceedings).

California Consumer Privacy Rights

Sales/Sharing Opt-out: We do not “sell” or “share” your personal information so no opt out choice is necessary. This means that we do not sell, share, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your personal information to another company for monetary or other valuable consideration or for cross-context behavioral advertising.

Know/Access: You have the right to request to learn more about the personal information we process about you and the right to request a copy of the specific pieces of personal information we have collected about you.

Correction: You have the right to request that we correct inaccurate information we hold about you.

Deletion: You have the right to request that we delete the personal information we have collected from you.

Non-Discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment.

How to Submit a Rights Request: We want you to be in control of your information and give you tools and options to access, correct, and delete your information. See Section 8 of our Privacy Policy to learn more about how you can manage your information.

You can also submit a request directly to us. To submit an access, correction or deletion request, click here. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. For example, submitting a request while logged into your account may be sufficient for verification, but sometimes we may ask you to provide proof of identity. You may also use an authorized agent to submit your request. If you do, we may ask for evidence that you have provided the agent valid power of attorney or other written permission to submit requests on your behalf, and we may also take steps to verify your identity. If you are an authorized agent seeking to make a request, please contact us as described above and include proof of your authorization.

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