Privr Privacy Policy

Introduction

Skyline Media LLC (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we might collect from you or that you might provide when you visit the website www.privr.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.

• In email, text, and other electronic messages between you and this Website.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any nonparty (including our affiliates and subsidiaries); or

• Any nonparty (including our affiliates and subsidiaries), including through any application or content (including advertising) that might link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you consent to the practices described in this policy. We may change this policy from time to time (see Changes to Our Privacy Policy). We consider your continued use of this Website after we make changes to be acceptance of those changes, so please check this policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18-years old. No one under 18-years old may provide any information to or on the Website. We do not knowingly collect personal information from children under 18-years old. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you might use. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

Information We Collect About You

We collect several types of information from and about users of our Website, including the following categories of information:

• Identity Data includes username or similar identifier and gender.

• Contact Data includes email address.

• Financial Data includes payment card details. We store only very limited, if any, Financial Data. Otherwise, all Financial Data is stored by our payment processor, Segpay, and you are encouraged to review its privacy policy, which is located at https://segpay.com/consumer-privacy-policy/, and contact Segpay directly for responses to your questions.

• Transaction Data includes details about payments from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, ISP name, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website, including your webcam and microphone.

• Device Data includes the type of mobile device (“Device”) you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and IP address.

• Profile Data includes your username and password, including password hints and other information for authentication and account access, purchases made b you, your interests, preferences, feedback, and survey responses. Some information you choose to give us might be considered “special” or “sensitive” in certain jurisdictions, for example, your sex life and sexual orientation. By choosing to submit special or sensitive information, you hereby consent to our processing of that information.

• Usage Data includes information about how you use our Website, products, and services.

• Location Data includes your current location disclosed by IP address and information about proxies.

• Google Login Data includes your email address if you choose to link your Google account with us to facilitate account creation and logon process.

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use, and share Aggregated Data including statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information that will be used under this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless you voluntarily provide it. Nor do we collect any information about criminal convictions and offenses.

Where we need to collect personal information by law, or under the terms of a contract we have with you and you do not provide that information when requested, we might not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How We Collect Information About You

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the Website. Information collected automatically might include Technical, Device, and Usage Data and information collected through cookies, web beacons, and other tracking technologies.

• From nonparties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website might include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide Financial Data before placing an order through our Website.

• Your search queries on the Website.

You also may provide information to be published or displayed (“posted”) on public Website areas or transmitted to other Website users or nonparties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other Website users with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including Technical, Device, Usage, and Location Data.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please note that we do not recognize or respond to any do not track signals (DNT). For more information about DNT, visit www.allaboutdnt.com.

Except for Location Data, the information we collect automatically is only statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection might include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you might be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Web Beacons. Pages of our Website and our emails might contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by nonparties, including advertisers, ad networks and servers, content providers, and application providers. These nonparties might use cookies alone or with web beacons or other tracking technologies to collect information about you when you use our Website. They might associate the information collected with your personal information or they might collect information, including personal information, about your online activities over time and across different websites and other online services. They might use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Our Website uses Google Remarketing, a service of Google LLC, to advertise on third-party websites to you after you visited our Website. We and Google use cookies to inform, optimize, and serve ads based on your past visits to our Website. Cookies and similar technologies are also used to perform the analysis of website usage as a basis for creating interest-based advertisements. The data arising in this context can be transmitted by Google to a server in the US for evaluation and stored there. If you use a Google Account, depending on the settings in your Google Account, Google may link your Google web and app browsing history to your Google Account and use information from your Google Account to personalize ads. If you don’t want this association with your Google Account, you’ll need to log out of Google before you can access our contact page.

We do not control these nonparties’ tracking technologies or how they might be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To identify you as a visitor or user on our Website.

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To provide you with notices about your subscription, including expiration and renewal notices.

• To determine your current location.

• To facilitate account creation and logon process if you choose to register or log in to our Website using your Google account.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Website or any products or services we offer or provide through it.

• To allow you to participate in interactive features on our Website, including live video chat.

• To ensure that we present our Website content in the most effective manner for you and for your computer or device.

• To administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.

• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.

• To use data analytics to improve our Website, products or services, marketing, or customer relationships and experiences.

• To protect our Website, employees, or operations.

• To deliver relevant advertisements (including targeted advertising) to you and measure or understand the effectiveness of the advertising we serve to you.

• To assist law enforcement and respond to subpoenas.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

We may also use your information to contact you about our own and nonparties’ goods and services that might be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or email us at [email protected]. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may use nonpersonal information for any business purpose.

Disclosure of Your Information

We may disclose Aggregated Data about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other nonparties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all Skyline Media LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Skyline Media LLC about our Website users is among the assets transferred.

• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal information to nonparties:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Skyline Media LLC, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

The categories of personal information we may disclose include:

• Identity Data;

• Contact Data;

• Financial Data;

• Transactional Data;

• Technical Data;

• Device Data; and

• Profile Data.

Consent to Personal Information Transfer

We are based in the United States of America. We may process, store, and transfer the personal information we collect, in and to a country outside your own, with different privacy laws that might or might not be as comprehensive as your own. If you are located outside the United States, your personal information might at times be accessible by persons who are located worldwide including in countries that the European Commission or other geopolitical regions have not determined to provide the same adequate level of data protection in your country, province, territory, or geopolitical region.

By submitting your personal information or engaging with our Website, you hereby consent to this transfer, storing, or processing, including the transfer of your information across international boundaries to jurisdictions anywhere in the world as permitted by law.

If you are a Canadian resident or otherwise located in Canada, please note that personal information transfers outside of Canada might result in your information becoming accessible to foreign jurisdiction’s law enforcement or other authorities.

If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), please note that your information will be transferred outside of those areas, including to the United States. Nevertheless, whenever we transfer your personal information out of the EEA, Switzerland, or UK, we will use reasonable efforts to ensure a similar degree of protection is afforded to it by ensuring that the recipient third party agrees to contractual clauses or other appropriate safeguards.

Your Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site might then be inaccessible or not function properly. You can opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

• Promotional Offers from the Company. If you do not wish to have your Contact Data used by the Company to promote our own or nonparties’ products or services, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a purchase, service experience, or other transactions.

• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target audience preferences, you can opt out by sending us an email stating your request to [email protected]. For this opt-out to function, you must have your browser set to accept all browser cookies.

We do not control nonparties’ collection or use of your information to serve interest-based advertising. But these nonparties may provide you with ways to choose not to have your information collected or used in this way. If you wish to opt out of third-party interest-based advertising, please visit https://thenai.org/ and https://optout.aboutads.info/ for details on how to do so.

You can opt out of Google Analytics for Displaying Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page at https://adssettings.google.com/. Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser, which is available at https://tools.google.com/dlpage/gaoptout. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on Google’s privacy practices, please visit https://policies.google.com/privacy.

Residents of certain jurisdictions, including California, Nevada, Colorado, Connecticut, Virginia, Utah, European Economic Area, and United Kingdom might have additional personal information rights and choices. Please see Your State Privacy Rights and Your EEA/UK Privacy Rights for more information.

Accessing and Correcting Your Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. You have the right to request access to and to correct the personal information that we hold about you.

You can access, review, and change your personal information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of (if allowed by the law of your jurisdiction) your personal information, you may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. In some circumstances, we cannot delete your personal information except by also deleting your user account. We will not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal information that we hold about you or make your requested changes. Law might allow or require us to refuse to provide you with access to some or all the personal information that we hold about you, or we might have destroyed, erased, or made your personal information anonymous under our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you delete your User Contributions from the Website, copies of your User Contributions might remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

Residents of certain jurisdictions, including California, Nevada, Colorado, Connecticut, Virginia, Utah, European Economic Area, and United Kingdom might have additional personal information rights and choices. Please see Your State Privacy Rights and Your EEA/UK Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws might provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, visit https://privr.com/privacy/#ccpa-privacy. California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to nonparties for their direct marketing purposes. To make that request, please send an email to [email protected].

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.

• Access and delete certain personal information.

• Data portability.

• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose.

• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights, please send an email to [email protected]. To appeal a decision regarding a consumer rights request, please contact us at [email protected].

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Your EEA/UK Privacy Rights

If you live in the EEA or the UK, the following terms apply to you.

Legal Basis for Processing

We may process your personal data because you have given us permission to do so (e.g., by sending data through our Website’s contact, signup forms or by using the service), because the processing is in our legitimate interests and it is not overridden by your rights, or because we need to process your personal data to perform a contract with you or comply with the law.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws concerning your personal data. Your rights may include the following:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we might not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will let you know and keep you updated.

Data Retention

Except as otherwise permitted or required by law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use that anonymous and de-identified information for any legitimate business purpose without further notice to you or your consent.

Withdrawing Your Consent

Where you have given your consent to the collection, use, and transfer of your personal information, you might have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, you may contact us at [email protected]. Please note that if you withdraw your consent, we might not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like live video chat. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information through the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

This Privacy Policy for California Residents supplements the information contained in Skyline Media LLC’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.

• Deidentified or aggregated consumer information.

• Information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; and

• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, our Website has collected the following categories of personal information from consumers within the last 12 months:

Our Website obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.

• Indirectly from you. For example, from observing your actions on our Website.

• From third parties. For example, from our business partners.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment. We may also save your information to facilitate new orders.

• To provide, support, personalize, and develop our Website, products, and services.

• To create, maintain, customize, and secure your account with us.

• To process your requests, purchases, transactions, and payments and prevent transactional fraud.

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information or as otherwise stated in the CCPA.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding 12 months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding 12 months, Company has not sold personal information.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (“right to know”). Once we receive your request and confirm your identity (see Exercising Your Right to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• 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, two separate lists disclosing:

  • sales, identifying the personal information categories that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (“right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers 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, fulfill the terms of a written warranty or product recall conducted under federal law, or otherwise 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 impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

• Emailing us at [email protected].

• Visiting https://privr.com/contact/.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• 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 the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within 10-business days. If you do not receive confirmation within the 10-day timeframe, please contact us.

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

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

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• 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 you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code § 1798.83) allows users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make that request, please contact us.

Changes to Our Privacy Policy

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

Contact Information

If you have any questions or comments about this notice, the ways in which Skyline Media LLC collects and uses your information described here and in the Privacy Policy, your choices and rights regarding that use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: https://privr.com/contact/

Email: [email protected]

If you need to access this Policy in an alternative format due to having a disability, please contact us.