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Privacy Policy

ADESSO NETWORK PRIVACY POLICY
This privacy policy (“Privacy Policy”) describes the policies and procedures of ADESSO NETWORK LLC (“we,” “us,” “our”) regarding the collection, use, and disclosure of Users’ information when using the Service, and sets forth Users’ privacy rights and how the law protects Users. By using the Service, Users agree to the collection and use of information in accordance with this Privacy Policy.
1.
Interpretation and Definitions
As used in this Privacy Policy, all capitalized terms below are defined as follows, and such definitions have the same meaning regardless of whether they appear in the singular or plural:
a.
“Account” means a unique account created for Users to access the Service or parts of the Service.
b.
“Business” means, for the purpose of the CCPA (California Consumer Privacy Act), Adesso Network LLC as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected, and that alone, or jointly with others, determines the purposes and means of the processing of Consumers’ personal information. For the purpose of the GDPR, we are the Data Controller.
c.
“Consumer” means, for the purpose of the CCPA (California Consumer Privacy Act), a natural person who is a California resident. A resident, as defined in the law, includes (A) every natural person who is in the USA for other than a temporary or transitory purpose, and (B) every natural person who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
d.
“Cookies” means small files that are placed on Users’ Devices by a website, that contain the details of Users’ browsing history on that website among its many uses.
e.
“Country” means the United States of America (USA).
f.
“Data Controller” means, for the purposes of the GDPR (General Data Protection Regulation), Adesso Network LLC as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
g.
“Data Processor” means, for the purposes of the GDPR (General Data Protection Regulation), any natural or legal person, public authority, agency, or other body which processes data on behalf of the Data Controller.
h.
“Data Subject” means, for the purposes of the GDPR (General Data Protection Regulation), any living individual whose Personal Data is collected, held, or processed by an organization.
i.
“Device” means any device that can access the Service such as a computer, cellular phone, digital tablet, or other similar device.
j.
“Do Not Track (DNT)” means the concept promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
k.
“Personal Data” means any information that relates to an identified or identifiable natural person. For the purposes of the GDPR, Personal Data means any information relating to Users such as a name, an identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with Users.
l.
“Sale” means, for the purpose of the CCPA (California Consumer Privacy Act), selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
m.
“Service” means the Adesso Network-branded family of websites featuring curated third-party entertainment and discipleship for the Christian audience.
n.
“Service Provider” means any natural or legal person who processes the data on our behalf. It refers to third-party companies or individuals employed by us to facilitate the Service, to provide the Service on our behalf, to perform services related to the Service, or to assist us in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
o.
“Usage Data” means data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
p.
“Users” means the natural person accessing or using the Service, or the legal entity on behalf of which such natural person is accessing or using the Service, as applicable. Under the GDPR (General Data Protection Regulation), Users can be referred to as the Data Subject.
q.
“Website” means any website within the Service.
2.
Collecting and Using Users’ Personal Data
a
Types of Data Collected.
i.
Personal Data. While using The Service, we may ask Users to provide us with certain personally identifiable information that can be used to contact or identify Users. Personally identifiable information may include, but is not limited to, (A) email addresses, and (B) Usage Data.
ii.
Usage Data. Usage Data is collected automatically when using the Service. Usage Data may include information such as Users’ Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the Service that Users visit, the time and date of a User’s visit, the time spent on those pages, unique device identifiers, and other diagnostic data. When Users access the Service by or through a Device, we may collect certain information automatically, including, but not limited to, the type of Device uses, the Device’s unique ID, the IP address of the Device, the operating system, the type of Internet browser, unique device identifiers, and other diagnostic data. We may also collect information that a browser sends whenever Users access the Service.
iii.
Tracking Technologies and Cookies. We use Cookies and similar tracking technologies to track activity on the Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the Service. The technologies we use may include:
A.
Browser Cookies. Users can instruct their browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if Users do not accept Cookies, Users may not be able to use some parts of the Service. Unless Users have adjusted their browser settings to refuse Cookies, the Service may use Cookies.
B.
Flash Cookies. Certain features of the Service may use local stored objects (or Flash Cookies) to collect and store information about Users’ preferences or Users’ activity on the Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how Users can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at: https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
C.
Web Beacons. Certain sections of the Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, 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 a certain section and verifying system and server integrity).
D.
Persistent or Session Cookies. Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on a User’s Device when the User goes offline, while Session Cookies are deleted as soon as a User closes his/her web browser. We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type
Session Cookies
Administered by
ss

These Cookies are essential to provide Users with services available through the Service and to enable Users to use some of its features. They help to authenticate Users and prevent fraudulent use of User accounts. Without these Cookies, the services that Users have asked for cannot be provided, and we only use these Cookies to provide Users with those services.

Cookies Policy / Notice Acceptance Cookies

Type
Persistent Cookies
Administered by
us

These Cookies identify if Users have accepted the use of Cookies on the Service.

Functionality Cookies

Type
Persistent Cookies
Administered by
us

These Cookies allow us to remember choices Users make when Users use the Service, such as remembering Users’ login details or language preferences. The purpose of these Cookies is to provide Users with a more personal experience and to avoid Users having to re-enter Users’ preferences every time Users use the Service.

Tracking and Performance Cookies

Type
Persistent Cookies
Administered by
third parties

These Cookies are used to track information about traffic to the Service and how Users use the Service. The information gathered via these Cookies may directly or indirectly identify Users as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the Device Users use to access the Service. We may also use these Cookies to test new pages, features, or new functionality of the Service to see how Users react to them.

Targeting and Advertising Cookies

Type
Persistent Cookies
Administered by
third parties

These Cookies track Users’ browsing habits to enable us to show advertising which is more likely to be of interest to Users. These Cookies use information about Users’ browsing history to group Users who have similar interests. Based on that information, and with our permission, third-party advertisers can place Cookies to enable them to show advertisements which we think will be relevant to Users’ interests while Users are on third party websites.

b
Use of Users’ Personal Data.
i.
to provide and maintain the Service, including to monitor the usage of the Service;
ii.
to manage registrations as Users of the Service. The Personal Data Users provide may give Users access to different functionalities of the Service that are available to Users as a registered User;
iii.
for the development, compliance, and undertaking of a contract for the products, items, or services Users have purchased or of any other contract with us through the Service;
iv.
to contact Users by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation;
v.
to provide Users with news, special offers, and general information about other goods, services, and events which we or our partner affiliates offer that may be similar to those that Users have already purchased or inquired about unless Users have opted not to receive such information;
vi.
to attend and manage Users’ requests to us;
vii.
to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about Users is among the assets transferred; and
viii.
we may use Users’ information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Service and Users’ experience.
c.
Sharing of Users’ Personal Data. We may share Users’ personal information in the following situations:
i.
we may share Users’ personal information with Service Providers to monitor and analyze the use of the Service, to show advertisements to Users, to help support and maintain the Service, or to contact Users;
ii.
we may share or transfer Users’ personal information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company;
iii.
we may share Users’ information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with us;
iv.
we may share Users’ information with our business partners to offer Users certain products, services, or promotions;
v.
when Users share personal information or otherwise interact in the public areas of the Service with other Users, such information may be viewed by all Users and may be publicly distributed outside the Service; and
vi.
we may disclose Users’ personal information for any other purpose with Users’ consent.
d.
Retention of Users’ Personal Data. We will retain Users’ Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Users’ Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Users’ data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.
e.
Transfer of Users’ Personal Data. Users’ information, including Personal Data, is processed at our operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Users’ state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of the Users’ jurisdiction. Users’ consent to this Privacy Policy, as evidenced by use of the Service, represents Users’ agreement to any such transfers. We take all commercially reasonable steps to ensure that Users’ data is treated securely and in accordance with this Privacy Policy and no transfer of Users’ Personal Data will take place, to an organization or a country unless there are adequate controls in place, including the security of Users’ data and other personal information.
f.
Disclosure of Users’ Personal Data. We may disclose User’s Personal Data in the following situations:
i.
if we are involved in a merger, acquisition, or asset sale, Users’ Personal Data may be transferred. We will provide notice before Users’ Personal Data is transferred and becomes subject to a different Privacy Policy;
ii.
if we are required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency); or
iii.
if we believe in good faith that such action is necessary to comply with a legal obligation; protect and defend our rights or property; prevent or investigate possible wrongdoing in connection with the Service; protect the personal safety of Users of the Service or the public; or protect against legal liability.
g.
Security of Users’ Personal Data. The security of Users’ Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Users’ Personal Data, we cannot guarantee its absolute security.
3.
Detailed Information on the Processing of Users’ Personal Data
The Service Providers we use may have access to Users’ Personal Data. These third-party vendors collect, store, use, process, and transfer information about Users’ activity on the Service in accordance with their privacy policies.
a.
Analytics. We may use Service Providers to monitor and analyze the use of the Service, including:
i.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Users can opt-out of having Users’ activity on the Service made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at: https://policies.google.com/privacy
b.
Advertising. We may use Service Providers to show advertisements to Users to help support and maintain the Service, including:
i.
Google AdSense & DoubleClick Cookies
Google, as a third-party vendor, uses Cookies to serve ads on the Service. Google’s use of the DoubleClick Cookie enables it and its partners to serve ads to our Users based on their visit to the Service or other websites on the Internet.
Users may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page at: http://www.google.com/ads/preferences/
ii.
Amazon
Their privacy policy can be viewed at: https://www.amazon.com/gp/help/customer/display.html?nodeId=468496&ref_=footer_privacy
c.
Email Marketing We may use Users’ Personal Data to contact Users with newsletters, marketing or promotional materials, and other information that may be of interest to Users. Users may opt-out of receiving any or all of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. We may use email marketing Service Providers to manage and send emails to Users, including:
i.
Mailchimp
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their privacy policy at: https://mailchimp.com/legal/privacy/
d.
API Services We use various Service Providers to provide API services in the operation of the Service, including:
i.
YouTube’s API Services
By using the Service, you agree to be bound by Google’s Privacy Policy, located at: http://www.google.com/policies/privacy Users can revoke our access to their Personal Data via the Google security settings page, located at: https://security.google.com/settings/security/permissions
4.
GDPR Privacy
a.
Legal Basis for Processing Personal Data under GDPR. We may process Personal Data under the following conditions:
i.
Users have given their consent for processing Personal Data for one or more specific purposes.
ii.
Provision of Personal Data is necessary for the performance of an agreement with Users and/or for any contractual obligations thereof.
iii.
Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
iv.
Processing Personal Data is necessary in order to protect the vital interests of Users or other natural persons.
v.
Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of our official authority.
vi.
Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us.
b.
Users’ Rights under the GDPR. We undertake to respect the confidentiality of Users’ Personal Data and to guarantee Users can exercise their rights. Users have the right under this Privacy Policy, and by law if Users are within the European Union (EU), to:
i.
to access, update, or delete the information we have on Users. Whenever made possible, Users can access, update, or request deletion of their Personal Data directly within their account settings section. If Users are unable to perform these actions, please contact us at [email protected] for assistance. Users are also entitled to receive a copy of the Personal Data we hold about them;
ii.
to have any incomplete or inaccurate information we hold about them corrected;
iii.
to object to processing of Users’ Personal Data where we are relying on a legitimate interest as the legal basis for our processing and there is something about their particular situation which makes them want to object to our processing of Users’ Personal Data on this ground. Users also have the right to object where we are processing their Personal Data for direct marketing purposes;
iv.
to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it;
v.
to provide to Users, or to a third-party Users have chosen, their Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which Users initially provided consent for us to use or where we used the information to perform a contract with Users; and
vi.
to withdraw their consent on using Users’ Personal Data. If Users withdraw Users’ consent, we may not be able to provide Users with access to certain specific functionalities of the Service.
c.
Exercising of Users’ GDPR Data Protection Rights. Users may exercise their rights of access, rectification, cancellation, and opposition by contacting us at [email protected]. Please note that we may ask Users to verify their identity before responding to such requests. If Users make a request, we will try our best to respond to Users as soon as possible. Users have the right to complain to a Data Protection Authority about our collection and use of Users’ Personal Data. For more information, if Users are in the European Economic Area (EEA), please contact Users’ local data protection authority in the EEA.
5.
CCPA Privacy
This privacy notice section for California residents supplements the information contained in our Privacy Policy and applies solely to Users who reside in the State of California, USA.
a.
Categories of Personal Information Collected. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months. Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if Users provided such personal information directly to us.
i.
Category A: Identifiers.Examples: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers. Collected: Yes.
ii.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Examples: a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: Yes.
iii.
Category C: Protected classification characteristics under California or federal law.Examples: age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No.
iv.
Category D: Commercial information.Examples: records and history of products or services purchased or considered. Collected: No.
v.
Category E: Biometric information.Examples: genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No.
vi.
Category F: Internet or other similar network activity. Examples: interaction with the Service or advertisements. Collected: Yes.
vii.
Category G: Geolocation data.Examples: approximate physical location. Collected: No.
viii.
Category H: Sensory data.Examples: audio, electronic, visual, thermal, olfactory, or similar information. Collected: No.
ix.
Category I: Professional or employment-related information.Examples: current or past job history or performance evaluations. Collected: No.
x.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Examples: education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No.
xi.
Category K: Inferences drawn from other personal information.Examples: profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No.
b.
Exclusions from Personal Information. Under CCPA, personal information does not include:
i.
publicly available information from government records;
ii.
deidentified or aggregated consumer information; and
iii.
information excluded from the CCPA’s scope, such as:
A.
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) or clinical trial data, and
B.
Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
c.
Sources of Personal Information. We obtain the categories of personal information listed above from the following categories of sources:
i.
directly from Users, including from any forms Users complete on the Service and preferences Users express or provide through the Service;
ii.
indirectly from Users, including by observing Users’ activity on the Service;
iii.
automatically from Users, including through Cookies we or the Service Providers set on Users’ Devices as Users navigate through the Service; and
iv.
from Service Providers, including from third-party vendors who monitor and analyze the use of the Service, third-party vendors who provide advertising on the Service, or other third-party vendors that we use to provide the Service to Users.
d.
Use of Personal Information for Business Purposes or Commercial Purposes. We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
i.
to operate the Service and provide the Service to Users;
ii.
to provide Users with support and to respond to Users’ inquiries, including to investigate and address Users’ concerns and monitor and improve the Service;
iii.
to fulfill or meet the reason Users provided the information – for example, if Users share their contact information to ask a question about the Service, we will use that personal information to respond to their inquiry;
iv.
to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
v.
as described to Users when collecting Users’ personal information or as otherwise set forth in the CCPA;
vi.
for internal administrative and auditing purposes; and
vii.
to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.
e.
Disclosure of Personal Information for Business Purposes or Commercial Purposes. We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
i.
Category A: Identifiers;
ii.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); and
iii.
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of such category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When we disclose personal information for a business purpose or a commercial purpose, we enter into a contract that describes the purpose and requires the recipient to both keep such personal information confidential and to not use it for any purpose except performing the contract.
f.
Sale of Personal Information. As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of such category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
i.
Category A: Identifiers;
ii.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); and
iii.
Category F: Internet or other similar network activity
h.
Sale of Personal Information of Minors Under 18 Years of Age. We do not sell the personal information of Consumers we actually know are less than 18 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is less than 18 years of age, or the parent or guardian of a Consumer less than 18 years of age.
Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, Users (or Users’ authorized representative) may submit a request to us by contacting us at [email protected].
If Users have reason to believe that a child under the age of 18 has provided us with personal information, please contact us at [email protected] with sufficient detail to enable us to delete such information.
i.
Users’ Rights under the CCPA. The CCPA provides California residents with specific rights regarding their personal information. If Users are a resident of California, Users have the following rights:
i.
to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used;
ii.
to request that we disclose information to Users about our collection, use, sale, disclosure for business purposes, and sharing of personal information. Once We receive and confirm Users’ request, we will disclose to Users:
A.
the categories of personal information we collected about Users;
B.
the categories of sources for the personal information we collected about Users;
C.
our business or commercial purpose for collecting or selling that personal information;
D.
the categories of third parties with whom we share that personal information;
E.
the specific pieces of personal information we collected about Users; and
F.
if we sold Users’ personal information or disclosed Users’ personal information for a business purpose, we will disclose to Users the categories of personal information categories sold, and the categories of personal information categories disclosed.
iii.
to direct us to not sell Users’ personal information. To submit an opt-out request please contact us at [email protected];
iv.
to request the deletion of Users’ Personal Data, subject to certain exceptions. Once We receive and confirm Users’ request, we will delete (and direct Service Providers to delete) Users’ personal information from our records, unless an exception applies. We may deny Users’ deletion request if retaining the information is necessary for us or the Service Providers to:
A.
complete the transaction for which we collected the personal information, provide a good or service that Users requested, take actions reasonably anticipated within the context of our ongoing business relationship with Users, or otherwise perform our contract with Users;
B.
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
C.
debug products to identify and repair errors that impair existing intended functionality;
D.
exercise free speech, ensure the right of another User to exercise their free speech rights, or exercise another right provided for by law;
E.
comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
F.
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 Users previously provided informed consent;
G.
enable solely internal uses that are reasonably aligned with consumer expectations based on Users’ relationships with us;
H.
comply with a legal obligation; or
I.
make other internal and lawful uses of such information that are compatible with the context in which Users provided it.
v.
to not be discriminated against for exercising any of Users’ consumer’s rights, including by:
A.
denying goods or services to Users;
B.
charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties;
C.
providing a different level or quality of goods or services to Users; or
D.
suggesting that Users will receive a different price or rate for goods or services or a different level or quality of goods or services.
j.
Exercising Users’ CCPA Data Protection Rights. In order to exercise any of Users’ rights under the CCPA, and if Users are a California resident, Users can contact us at [email protected]. Only Users, or a person registered with the California Secretary of State that Users authorize to act on Users’ behalf, may make a verifiable request related to Users’ personal information.
A User’s request to us must (i) provide sufficient information that allows us to reasonably verify Users are the person about whom we collected personal information or an authorized representative, and (ii) describe the User’s request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to Users’ request or provide Users with the required information if we cannot (i) verify the User’s identity or authority to make the request, and (ii) confirm that the personal information relates to the User. We will disclose and deliver the required information free of charge within 45 days of receiving a User’s verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, we will select a format to provide the User’s personal information that is readily useable and should allow the User to transmit the information from one entity to another entity without hindrance.
k.
Do Not Sell Users’ Personal Information. Users have the right to opt-out of the sale of their personal information. Once we receive and confirm a verifiable consumer request from a User, we will stop selling that User’s personal information. To exercise your right as a User to opt-out, please contact us at [email protected].
The Service Providers we partner with (for example, our analytics and advertising partners) may use technology on the Service that sells personal information as defined by the CCPA. If Users wish to opt out of the use of their personal information for interest-based advertising purposes and these potential sales as defined under the CCPA, Users may do so by following the instructions below. Please note that any opt out is specific to the browser the User uses. Users may need to opt out on every browser that the User uses.
l.
Website. Users can opt out of receiving ads that are personalized as served by the Service Providers by following our instructions presented on the Service.
i.
The NAI’s opt-out platform at: http://www.networkadvertising.org/choices/
ii.
The EDAA’s opt-out platform at: https://www.youronlinechoices.com/
iii.
The DAA’s opt-out platform at: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a Cookie on the User’s computer that is unique to the browser the User uses to opt out. If the User changes browsers or deletes the Cookies saved by the User’s browser, then the User will need to opt out again.
m.
Mobile Devices. A User’s mobile device may provide the ability to opt out of the use of information about the apps the User uses in order to serve ads that are targeted to the User’s interests:
i.
“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices, and
ii.
“Limit Ad Tracking” on iOS devices
Users can also stop the collection of location information from Users’ mobile Devices by changing the preferences on Users’ mobile devices.
6.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
The Service does not respond to Do Not Track signals. However, some third-party websites do keep track of Users’ browsing activities. If Users are visiting such websites, Users can set their preferences in their web browser to inform websites that they do not want to be tracked. Users can enable or disable DNT by visiting the preferences or settings page of their web browser.
7.
Children’s Privacy
a.
Children Under the Age of 13. The Service contains content appropriate for children under the age of 13. As a parent, Users should know that through the Service, children under the age of 13 may participate in activities that involve the collection or use of personal information. We use reasonable efforts to ensure that before we collect any personal information from a child, the child’s parent receives notice of and consents to our personal information practices.
We also may limit how we collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means we will be unable to provide certain functionality of the Service to these Users. If we need to rely on consent as a legal basis for processing Users’ information and Users’ country requires consent from a parent, we may require Users’ parent’s consent before we collect and use that information.
We may ask a User to verify the User’s date of birth before collecting any personal information from them. If the User is under the age of 13, the Service will be either blocked or redirected to a parental consent process.
b.
Information Collected from Children Under the Age of 13. We may collect and store persistent identifiers such as Cookies or IP addresses from children without parental consent for the purpose of supporting the internal operation of the Service. We may collect and store other personal information about children if this information is submitted by a child with prior parent consent or by the parent or guardian of the child. We may collect and store the following types of personal information about a child when submitted by a child with prior parental consent or by the parent or guardian of the child: first and/or last name; date of birth; gender; grade level; email address; telephone number; parent’s or guardian’s name; and parent’s or guardian’s email address.
For further details on the information we might collect, Users can refer to the “Types of Data Collected” section of this Privacy Policy. We follow our standard Privacy Policy for the disclosure of personal information collected from and about children.
c.
Parental Access. A parent who has already given us permission to collect and use their child’s personal information can, at any time: review, correct, or delete the child’s personal information, and discontinue further collection or use of the child’s personal information. To make such a request, Users can write to us at [email protected].
8.
Users’ California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If Users would like to request more information under the California Shine the Light law, and if Users are a California resident, Users can contact us at [email protected].
9.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if Users are a California resident, Users can contact us at [email protected], and include the email address associated with Users’ account. Be aware that a User’s request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
10.
Links to other Websites
The Service contains links to other websites that are not a part of the Adesso Network and are not operated or controlled by us. If Users click on a third-party link, Users will be directed to that third party’s site. We strongly advise Users to review the privacy policy of every site Users visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
11.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will notify Users of any changes by posting the new Privacy Policy on this page. We will also update the “Last updated” date at the bottom of this Privacy Policy. Users are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
12.
Definitive Version
If this Privacy Policy is translated into any language other than English, you acknowledge and agree such translation is an accommodation for convenience only, and in the event of any dispute arising out of or relating to this Privacy Policy, the English version shall govern and control.
13.
Contact Us
If Users have any questions about our Privacy Policy, Users can contact us at [email protected]
    Last updated: December 19, 2022