1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal
information that you provide to us.
We collect personal information that you voluntarily provide
to us when you register, express an interest in obtaining information
about us or our products and Services, when you participate in activities on
the Services, or otherwise when you contact us.
Personal Information Provided by You. The
personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and the products
and features you use. The personal information we collect may include the
following:
Name
Company
Email
Address
Sensitive Information. We do not process
sensitive information. When necessary, with your consent or as otherwise
permitted by applicable law, we process the following categories of sensitive
information:
Name
Company
Email
Address
Payment Data. We may collect data necessary to
process your payment if you make purchases, such as your payment instrument
number (such as a credit card number), and the security code associated with
your payment instrument. All payment data is stored by Company Name.
Social Media Login Data. We may provide you with
the option to register with us using your existing social media account
details, like your Facebook, Twitter, or other social media account. If you
choose to register in this way, we will collect the information described in
the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.
Application Data. If you use our application(s),
we also may collect the following information if you choose to provide us with
access or permission:
Geolocation
Information. We may request access or permission to track
location-based information from your mobile device, either continuously or
while you are using our mobile application(s), to provide certain
location-based services. If you wish to change our access or permissions,
you may do so in your device’s settings.
Mobile
Device Access. We may request access or permission to certain
features from your mobile device, including your mobile device’s
bluetooth, calendar, camera, own, and other features. If you wish to
change our access or permissions, you may do so in your device’s settings.
Mobile
Device Data. We automatically collect device information (such as
your mobile device ID, model, and manufacturer), operating system, version
information and system configuration information, device and application
identification numbers, browser type and version, hardware model Internet
service provider and/or mobile carrier, and Internet Protocol (IP) address
(or proxy server). If you are using our application(s), we may also
collect information about the phone network associated with your mobile
device, your mobile device’s operating system or platform, the type of
mobile device you use, your mobile device’s unique device ID, and
information about the features of our application(s) you accessed.
Push
Notifications. We may request to send you push notifications
regarding your account or certain features of the application(s). If you
wish to opt out from receiving these types of communications, you may turn
them off in your device’s settings.
This information is primarily needed to maintain the
security and operation of our application(s), for troubleshooting, and for our
internal analytics and reporting purposes.
All personal information that you provide to us must be
true, complete, and accurate, and you must notify us of any changes to such
personal information.
Information automatically collected
In Short: Some information — such as
your Internet Protocol (IP) address and/or browser and device characteristics —
is collected automatically when you visit our Services.
We automatically collect certain information when you visit,
use, or navigate the Services. This information does not reveal your specific
identity (like your name or contact information) but may include device and
usage information, such as your IP address, browser and device characteristics,
operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other
technical information. This information is primarily needed to maintain the
security and operation of our Services, and for our internal analytics and
reporting purposes.
Like many businesses, we also collect information through
cookies and similar technologies.
The information we collect includes:
Log
and Usage Data. Log and usage data is service-related,
diagnostic, usage, and performance information our servers automatically
collect when you access or use our Services and which we record in log
files. Depending on how you interact with us, this log data may include
your IP address, device information, browser type, and settings and
information about your activity in the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches, and
other actions you take such as which features you use), device event
information (such as system activity, error reports (sometimes called
“crash dumps”), and hardware settings).
Device
Data. We collect device data such as information about your
computer, phone, tablet, or other device you use to access the Services.
Depending on the device used, this device data may include information
such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model, Internet
service provider and/or mobile carrier, operating system, and system
configuration information.
Location
Data. We collect location data such as information about your
device’s location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device you
use to access the Services. For example, we may use GPS and other
technologies to collect geolocation data that tells us your current
location (based on your IP address). You can opt out of allowing us to
collect this information either by refusing access to the information or
by disabling your Location setting on your device. However, if you choose
to opt out, you may not be able to use certain aspects of the Services.
Information collected from other sources
In Short: We may collect limited data
from public databases, marketing partners, social media platforms, and other
outside sources.
In order to enhance our ability to provide relevant
marketing, offers, and services to you and update our records, we may obtain
information about you from other sources, such as public databases, joint
marketing partners, affiliate programs, data providers, social media platforms,
and from other third parties. This information includes mailing addresses, job
titles, email addresses, phone numbers, intent data (or user behavior data),
Internet Protocol (IP) addresses, social media profiles, social media URLs, and
custom profiles, for purposes of targeted advertising and event promotion. If
you interact with us on a social media platform using your social media account
(e.g., Facebook or Twitter), we receive personal information about you such as
your name, email address, and gender. Any personal information that we collect
from your social media account depends on your social media account’s privacy
settings.
Information collected when you use our Facebook
application(s). We by default access your Facebook basic
account information, including your name, email, gender, birthday, current
city, and profile picture URL, as well as other information that you choose to
make public. We may also request access to other permissions related to your
account, such as friends, check-ins, and likes, and you may choose to grant or
deny us access to each individual permission. For more information regarding
Facebook permissions, refer to the Facebook Permissions Reference page.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information
to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your
information for other purposes with your consent.
We process your personal information for a variety of
reasons, depending on how you interact with our Services, including:
To
facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and
log in to your account, as well as keep your account in working order.
To
deliver and facilitate delivery of services to the user. We may
process your information to provide you with the requested service.
To
respond to user inquiries/offer support to users. We may process
your information to respond to your inquiries and solve any potential
issues you might have with the requested service.
To
send administrative information to you. We may process your
information to send you details about our products and services, changes
to our terms and policies, and other similar information.
To
fulfill and manage your orders. We may process your information
to fulfill and manage your orders, payments, returns, and exchanges made
through the Services.
To
enable user-to-user communications. We may process your
information if you choose to use any of our offerings that allow for
communication with another user.
To
request feedback. We may process your information when necessary
to request feedback and to contact you about your use of our Services.
To
send you marketing and promotional communications. We may process
the personal information you send to us for our marketing purposes, if
this is in accordance with your marketing preferences. You can opt out of
our marketing emails at any time. For more information, see “WHAT ARE
YOUR PRIVACY RIGHTS?” below).
To
deliver targeted advertising to you. We may process your
information to develop and display personalized content and advertising
tailored to your interests, location, and more.
To
protect our Services. We may process your information as part of
our efforts to keep our Services safe and secure, including fraud
monitoring and prevention.
To
identify usage trends. We may process information about how you
use our Services to better understand how they are being used so we can
improve them.
To
determine the effectiveness of our marketing and promotional campaigns. We
may process your information to better understand how to provide marketing
and promotional campaigns that are most relevant to you.
To
save or protect an individual’s vital interest. We may process
your information when necessary to save or protect an individual’s vital
interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your
personal information when we believe it is necessary and we have a valid legal
reason (i.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or
fulfill our contractual obligations, to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU or UK, this section
applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR
require us to explain the valid legal bases we rely on in order to process your
personal information. As such, we may rely on the following legal bases to
process your personal information:
Consent. We
may process your information if you have given us permission (i.e.,
consent) to use your personal information for a specific purpose. You can
withdraw your consent at any time.
Performance
of a Contract. We may process your personal information when we
believe it is necessary to fulfill our contractual obligations to you,
including providing our Services or at your request prior to entering into
a contract with you.
Legitimate
Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and
those interests do not outweigh your interests and fundamental rights and
freedoms. For example, we may process your personal information for some
of the purposes described in order to:
Send
users information about special offers and discounts on our products and
services
Develop
and display personalized and relevant advertising content for our users
Analyze
how our services are used so we can improve them to engage and retain
users
Support
our marketing activities
Diagnose
problems and/or prevent fraudulent activities
Understand
how our users use our products and services so we can improve user
experience
Legal
Obligations. We may process your information where we believe it
is necessary for compliance with our legal obligations, such as to
cooperate with a law enforcement body or regulatory agency, exercise or
defend our legal rights, or disclose your information as evidence in
litigation in which we are involved.
Vital
Interests. We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a
third party, such as situations involving potential threats to the safety
of any person.
In legal terms, we are generally the “data controller” under
European data protection laws of the personal information described in this
privacy notice, since we determine the means and/or purposes of the data
processing we perform. This privacy notice does not apply to the personal
information we process as a “data processor” on behalf of our customers. In
those situations, the customer that we provide services to and with whom we
have entered into a data processing agreement is the “data controller” responsible
for your personal information, and we merely process your information on their
behalf in accordance with your instructions. If you want to know more about our
customers’ privacy practices, you should read their privacy policies and direct
any questions you have to them.
If you are located in Canada, this section applies
to you.
We may process your information if you have given us
specific permission (i.e., express consent) to use your personal information
for a specific purpose, or in situations where your permission can be inferred
(i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under
applicable law to process your information without your consent, including, for
example:
If
collection is clearly in the interests of an individual and consent cannot
be obtained in a timely way
For
investigations and fraud detection and prevention
For
business transactions provided certain conditions are met
If it
is contained in a witness statement and the collection is necessary to
assess, process, or settle an insurance claim
For
identifying injured, ill, or deceased persons and communicating with next
of kin
If we
have reasonable grounds to believe an individual has been, is, or may be
victim of financial abuse
If it
is reasonable to expect collection and use with consent would compromise
the availability or the accuracy of the information and the collection is
reasonable for purposes related to investigating a breach of an agreement
or a contravention of the laws of Canada or a province
If
disclosure is required to comply with a subpoena, warrant, court order, or
rules of the court relating to the production of records
If it
was produced by an individual in the course of their employment, business,
or profession and the collection is consistent with the purposes for which
the information was produced
If the
collection is solely for journalistic, artistic, or literary purposes
If the
information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in
specific situations described in this section and/or with the following
categories of third parties.
Vendors, Consultants, and Other Third-Party Service
Providers. We may share your data with third-party vendors, service
providers, contractors, or agents (“third parties”) who perform services
for us or on our behalf and require access to such information to do that work.
We have contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do anything
with your personal information unless we have instructed them to do it. They
will also not share your personal information with any organization apart from
us. They also commit to protect the data they hold on our behalf and to retain
it for the period we instruct. The categories of third parties we may share
personal information with are as follows:
Ad
Networks
Affiliate
Marketing Programs
Cloud
Computing Services
Communication
& Collaboration Tools
Data
Analytics Services
Data
Storage Service Providers
Finance
& Accounting Tools
Government
Entities
Order
Fulfillment Service Providers
Payment
Processors
Performance
Monitoring Tools
Product
Engineering & Design Tools
Retargeting
Platforms
Sales
& Marketing Tools
Social
Networks
Testing
Tools
User
Account Registration & Authentication Services
Website
Hosting Service Providers
We also may need to share your personal information in the
following situations:
Business
Transfers. We may share or transfer your information in
connection with, or during negotiations of, any merger, sale of company
assets, financing, or acquisition of all or a portion of our business to
another company.
When
we use Google Maps Platform APIs. We may share your information
with certain Google Maps Platform APIs (e.g., Google Maps API, Places
API). To find out more about Google’s Privacy Policy, please refer to
this link.
We use certain Google Maps Platform APIs to retrieve certain information
when you make location-specific requests.
Affiliates. We
may share your information with our affiliates, in which case we will
require those affiliates to honor this privacy notice. Affiliates include
our parent company and any subsidiaries, joint venture partners, or other
companies that we control or that are under common control with us.
Business
Partners. We may share your information with our business
partners to offer you certain products, services, or promotions.
Other
Users. When you share personal information (for example, by
posting comments, contributions, or other content to the Services) or
otherwise interact with public areas of the Services, such personal
information may be viewed by all users and may be publicly made available
outside the Services in perpetuity. If you interact with other users of
our Services and register for our Services through a social network (such
as Facebook), your contacts on the social network will see your name,
profile photo, and descriptions of your activity. Similarly, other users
will be able to view descriptions of your activity, communicate with you
within our Services, and view your profile.
Offer
Wall. Our application(s) may display a third-party hosted “offer
wall.” Such an offer wall allows third-party advertisers to offer virtual
currency, gifts, or other items to users in return for the acceptance and
completion of an advertisement offer. Such an offer wall may appear in our
application(s) and be displayed to you based on certain data, such as your
geographic area or demographic information. When you click on an offer
wall, you will be brought to an external website belonging to other persons
and will leave our application(s). A unique identifier, such as your user
ID, will be shared with the offer wall provider in order to prevent fraud
and properly credit your account with the relevant reward.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for
the safety of any information that you share with third parties that we may
link to or who advertise on our Services, but are not affiliated with, our
Services.
The Services, may link to third-party websites, online
services, or mobile applications and/or contain advertisements from third
parties that are not affiliated with us and which may link to other websites,
services, or applications. Accordingly, we do not make any guarantee regarding
any such third parties, and we will not be liable for any loss or damage caused
by the use of such third-party websites, services, or applications. The
inclusion of a link towards a third-party website, service, or application does
not imply an endorsement by us. We cannot guarantee the safety and privacy of
data you provide to any third parties. Any data collected by third parties is
not covered by this privacy notice. We are not responsible for the content or
privacy and security practices and policies of any third parties, including
other websites, services, or applications that may be linked to or from the
Services. You should review the policies of such third parties and contact them
directly to respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other
tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like
web beacons and pixels) to access or store information. 7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or
log in to our services using a social media account, we may have access to
certain information about you.
Our Services offer you the ability to register and log in
using your third-party social media account details (like your Facebook or
Twitter logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile information
we receive may vary depending on the social media provider concerned, but will
often include your name, email address, friends list, and profile picture, as
well as other information you choose to make public on such a social media
platform. If you log in using Facebook, we may also request access to other
permissions related to your account, such as your friends, check-ins, and
likes, and you may choose to grant or deny us access to each individual
permission.
We will use the information we receive only for the purposes
that are described in this privacy notice or that are otherwise made clear to
you on the relevant Services. Please note that we do not control, and are not
responsible for, other uses of your personal information by your third-party
social media provider. We recommend that you review their privacy notice to
understand how they collect, use and share your personal information, and how
you can set your privacy preferences on their sites and apps.
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and
process your information in countries other than your own.
Our servers are located in various locations. If you are
accessing our Services, please be aware that your information may be
transferred to, stored, and processed by us in our facilities and by those
third parties with whom we may share your personal information.
If you are a resident in the European Economic Area (EEA) or
United Kingdom (UK), then these countries may not necessarily have data
protection laws or other similar laws as comprehensive as those in your
country. However, we will take all necessary measures to protect your personal
information in accordance with this privacy notice and applicable law.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for
as long as necessary to fulfill the purposes outlined in this privacy notice
unless otherwise required by law.
We will only keep your personal information for as long as
it is necessary for the purposes set out in this privacy notice, unless a
longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than the period of
time in which users have an account with us.
When we have no ongoing legitimate business need to process
your personal information, we will either delete or anonymize such information,
or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
possible.
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your
personal information through a system of organizational and technical security
measures.
We have implemented appropriate and reasonable technical and
organizational security measures designed to protect the security of any
personal information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our best to
protect your personal information, transmission of personal information to and
from our Services is at your own risk. You should only access the Services
within a secure environment.
11. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect
data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children
under 18 years of age. By using the Services, you represent that you are at
least 18 or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we will
deactivate the account and take reasonable measures to promptly delete such
data from our records. If you become aware of any data we may have collected
from children under age 18, please contact us at safety@sotaris.com 12. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the
European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights
that allow you greater access to and control over your personal information.
You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have
certain rights under applicable data protection laws. These may include the
right (i) to request access and obtain a copy of your personal information,
(ii) to request rectification or erasure (iii) to restrict the processing of
your personal information and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to the processing
of your personal information. You can make such a request by contacting us by
using the contact details provided in the section “HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?” below.
We will consider and act upon any request in accordance with
applicable data protection laws.
If you are located in the EEA or UK and you believe we are
unlawfully processing your personal information, you also have the right to
complain to your local data protection supervisory authority. You can find
their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
If you are located in Switzerland, the contact details for
the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are
relying on your consent to process your personal information, which may be
express and/or implied consent depending on the applicable law, you have the
right to withdraw your consent at any time. You can withdraw your consent at
any time by contacting us by using the contact details provided in the section
“HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your
preferences.
However, please note that this will not affect the
lawfulness of the processing before its withdrawal, nor when applicable law
allows, will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional
communications: You can unsubscribe from our marketing and
promotional communications at any time by clicking on the unsubscribe link in
the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages
that we send, or by contacting us using the details provided in the
section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then
be removed from the marketing lists — however, we may still communicate with
you, for example to send you service-related messages that are necessary for
the administration and use of your account, to respond to service requests, or
for other non-marketing purposes.
Account Information
If you would at any time like to review or change the
information in your account or terminate your account, you can:
Log in
to your account settings and update your user account.
Contact
us using the contact information provided.
Upon your request to terminate your account, we will
deactivate or delete your account and information from our active databases.
However, we may retain some information in our files to prevent fraud,
troubleshoot problems, assist with any investigations, enforce our legal terms
and/or comply with applicable legal requirements.
Cookies and similar technologies: Most
Web browsers are set to accept cookies by default. If you prefer, you can
usually choose to set your browser to remove cookies and to reject cookies. If
you choose to remove cookies or reject cookies, this could affect certain
features or services of our Services. To opt out of interest-based advertising
by advertisers on our Services visit http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights,
you may email us at safety@sotaris.com
13. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and
mobile applications include a Do-Not-Track (“DNT”) feature or setting you can
activate to signal your privacy preference not to have data about your online
browsing activities monitored and collected. At this stage no uniform
technology standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals or any
other mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we must follow in the future,
we will inform you about that practice in a revised version of this privacy
notice.
14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident
of California, you are granted specific rights regarding access to your
personal information.
California Civil Code Section 1798.83, also known as the
“Shine The Light” law, permits our users who are California residents to
request and obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a request,
please submit your request in writing to us using the contact information
provided below.
If you are under 18 years of age, reside in California, and
have a registered account with Services, you have the right to request removal
of unwanted data that you publicly post on the Services. To request removal of
such data, please contact us using the contact information provided below and
include the email address associated with your account and a statement that you
reside in California. We will make sure the data is not publicly displayed on
the Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for
other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside
the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must
adhere to certain rights and obligations regarding your personal information.
How do we use and share your personal information?
SOTARIS LLP collects and shares your personal
information through:
Targeting
cookies/Marketing cookies
Social
media cookies
Beacons/Pixels/Tags
Social
media plugins: We use social media features, such as a “Like” button,
and widgets, such as a “Share” button in our Services. Such features may
process your Internet Protocol (IP) address and track which page you are
visiting on our website. We may place a cookie to enable the feature to
work correctly. If you are logged in on a certain social media platform
and you interact with a widget or button belonging to that social media
platform, this information may be recorded to your profile of such social
media platform. To avoid this, you should log out from that social media
platform before accessing or using the Services. Social media features and
widgets may be hosted by a third party or hosted directly on our Services.
Your interactions with these features are governed by the privacy notices
of the companies that provide them. By clicking on one of these buttons,
you agree to the use of this plugin and consequently the transfer of
personal information to the corresponding social media service. We have no
control over the essence and extent of these transmitted data or their
additional processing.
You can opt out from the selling or sharing of your personal
information by disabling cookies in Cookie Preference Settings and clicking on
the Do Not Sell or Share My Personal Information link on our homepage.
You may contact us by email us at safety@sotaris.com , or by referring to
the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right
to opt out we may deny a request if the authorized agent does not submit proof
that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service
providers pursuant to a written contract between us and each service provider.
Each service provider is a for-profit entity that processes the information on
our behalf, following the same strict privacy protection obligations mandated
by the CCPA.
We may use your personal information for our own business
purposes, such as for undertaking internal research for technological
development and demonstration. This is not considered to be “selling” of your
personal information.
SOTARIS, LLP has not sold or shared any personal information
to third parties for a business or commercial purpose in the preceding twelve
(12) months.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information.
If you ask us to delete your personal information, we will respect your request
and delete your personal information, subject to certain exceptions provided by
law, such as (but not limited to) the exercise by another consumer of his or
her right to free speech, our compliance requirements resulting from a legal
obligation, or any processing that may be required to protect against illegal
activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether
we collect and use your personal information
the
categories of personal information that we collect
the
purposes for which the collected personal information is used
whether
we sell or share personal information to third parties
the
categories of personal information that we sold, shared, or disclosed for
a business purpose
the
categories of third parties to whom the personal information was sold,
shared, or disclosed for a business purpose
the
business or commercial purpose for collecting, sharing, or selling
personal information and
the
specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to
provide or delete consumer information that is de-identified in response to a
consumer request or to re-identify individual data to verify a consumer
request.
Right to Non-Discrimination for the Exercise of a
Consumer’s Privacy Rights
We will not discriminate against you if you exercise your
privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal
Information
We do not process consumer’s sensitive personal information.
If the business collects any of the following:
social
security information, drivers’ licenses, state ID cards, passport numbers
account
login information
credit
card numbers, financial account information, or credentials allowing
access to such accounts
precise
geolocation
racial
or ethnic origin, religious or philosophical beliefs, union membership
the
contents of email and text, unless the business is the intended recipient
of the communication
genetic
data, biometric data, and health data
data
concerning sexual orientation and sex life
you have the right to direct that business to limit its use
of your sensitive personal information to that use which is necessary to
perform the Services.
Once a business receives your request, they are no longer
allowed to use or disclose your sensitive personal information for any other
purpose unless you provide consent for the use or disclosure of sensitive
personal information for additional purposes.
Please note that sensitive personal Information that is
collected or processed without the purpose of inferring characteristics about a
consumer is not covered by this right, as well as the publicly available
information.
To exercise your right to limit use and disclosure of
sensitive personal Information, please email us at safety@sotaris.com
Verification process
Upon receiving your request, we will need to verify your
identity to determine you are the same person about whom we have the
information in our system. These verification efforts require us to ask you to
provide information so that we can match it with information you have
previously provided us. For instance, depending on the type of request you
submit, we may ask you to provide certain information so that we can match the
information you provide with the information we already have on file, or we may
contact you through a communication method (e.g., phone or email) that you have
previously provided to us. We may also use other verification methods as the
circumstances dictate.
We will only use personal information provided in your
request to verify your identity or authority to make the request. To the extent
possible, we will avoid requesting additional information from you for the
purposes of verification. However, if we cannot verify your identity from the
information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for
security or fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other privacy rights
You
may object to the processing of your personal information.
You
may request correction of your personal data if it is incorrect or no
longer relevant, or ask to restrict the processing of the information.
You
can designate an authorized agent to make a request under the CCPA on your
behalf. We may deny a request from an authorized agent that does not
submit proof that they have been validly authorized to act on your behalf
in accordance with the CCPA.
You
may request to opt out from future selling or sharing of your personal
information to third parties. Upon receiving an opt-out request, we will
act upon the request as soon as feasibly possible, but no later than fifteen
(15) days from the date of the request submission.
To exercise these rights, you can contact us by email or by
referring to the contact details at the bottom of this document. If you have a
complaint about how we handle your data, we would like to hear from you.
Financial Incentives
“Financial incentive” means a program, benefit, or other
offering, including payments to consumers as compensation, for the disclosure,
deletion, sharing, or sale of personal information.
The law permits financial incentives or a price or service
difference if it is reasonably related to the value of the consumer’s data. A
business must be able to explain how the financial incentive or price or
service difference is reasonably related to the value of the consumer’s data.
The explanation must include:
a
good-faith estimate of the value of the consumer’s data that forms the
basis for offering the financial incentive or price or service difference
and
a
description of the method the business used to calculate the value of the
consumer’s data.
We may decide to offer a financial incentive (e.g., price or
service difference) in exchange for the retention, sale or sharing of a
consumer’s personal information.
If we decide to offer a financial incentive, we will notify
you of such financial incentive and explain the price difference, as well as
material terms of the financial incentive or price of service difference,
including the categories of personal information that are implicated by the
financial incentive or price or service difference.
15. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this
notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The
updated version will be indicated by an updated “Revised” date and the updated
version will be effective as soon as it is accessible. If we make material
changes to this privacy notice, we may notify you either by prominently posting
a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be informed of how we
are protecting your information.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
contact us at safety@sotaris.com 17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country, you may have
the right to request access to the personal information we collect from you,
change that information, or delete it in some circumstances.
