PRIVACY POLICY:

ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS

Effective date: 5/26/2023

ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS

Under the California Consumer Privacy Act (“CCPA”), as amended by the Consumer Privacy Rights Act (“CPRA”), we are required to provide specific disclosures about how we use and disclose personal information (“California Personal Information”) about you (“consumers” in this section).  

CALIFORNIA PERSONAL INFORMATION  

Depending on your online and offline interactions with us, we may collect and process the following categories of California Personal Information:

  • Identifiers: including contact details such as email address, name or telephone number;

  • Customer Records: electronic customer records containing California Personal Information, such as telephone number;

  • Internet or Other Electronic Network Activity Information: including your interactions with our website or App; 

  • Inferences: drawn from the information collected; and

  • Geolocators: including general location information with App user consent. 

Certain California Personal Information that we collect about you may be considered “Sensitive Personal Information” within the meaning of California Privacy Law. We only use and disclose Sensitive Personal Information as necessary in connection with the performance of Services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by California Privacy Law.

SOURCES

We may collect the categories of California Personal Information identified in the sub-section above directly from you, automatically as you use our website, App or Services, and from third parties such as data analytics providers, social media networks, and distributors and intermediaries. 

 PURPOSES OF USE 

We use California Personal Information for the following business and commercial purposes:

BUSINESS PURPOSES

Negotiate, conclude, and perform contracts with vendors;

Manage our accounts and records;

Operate our website or Services, including through the use of analytics software;

Communicate with individuals that are, or who represent, customers, vendors, or web users related to transactions;

Protect our rights and interests;

Ensure the security of our website, App and other assets;

Legal and regulatory compliance and internal control evaluations and audits (including where conducted by our internal and external audit service providers);

Obtain legal advice, including for legal proceedings and litigation and also in connection with the sale, purchase or merger of a business;

To provide the products, information and services you request; 

For security, credit or fraud prevention purposes; 

To provide you with effective customer service; 

To provide you with a personalized experience when you use our Services;  

To contact you with information and notices related to your use of our Services; 

COMMERCIAL PURPOSES

Advertising, marketing, and public relations (including direct marketing);

Market research and competitor analysis;

To display personalized advertising when you visit our website, App or a third party website; 

To contact you with special offers, such as new products, contests and other information we believe will be of interest to you;

To better understand your needs and interests; and

To improve our marketing efforts.

DISCLOSURE OF CALIFORNIA PERSONAL INFORMATION

We may disclose the categories of California Personal Information described above, for the business purposes described above, to:

  • Third-party service providers and contractors that perform data processing activities on our behalf, subject to appropriate privacy and security obligations;

  • Government and other authorities as required by law; 

  • Potential purchasers and other parties in connection with the sale, purchase, or merger of a business; and

  • Others to the extent necessary to comply with applicable law and as otherwise permitted under California Privacy Law.

 We may disclose Identifiers and Internet or Other Electronic Network Activity Information for the commercial purposes described above to: 

  • Third-party service providers; and

  • Social media and advertising networks. 

YOUR CALIFORNIA PRIVACY RIGHTS

Subject to certain exceptions detailed in California Privacy Law, as a California resident, you have the right to request: (i) deletion of your California Personal Information (subject to our right to retain your California Personal Information in order to prevent you from creating a new user account or otherwise accessing the Services in the event you violated the Terms of Service); (ii) correction of inaccurate California Personal Information; (iii) the right to know/ access the categories of California Personal Information that we collect about you, including the specific pieces of California Personal Information; (iv) the categories of California Personal Information disclosed for a business purpose; and (v) information about the categories of California Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the California Personal Information was shared.  

In addition, California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

DO-NOT-SELL OR SHARE MY PERSONAL INFORMATION

In addition to the above-stated rights, California residents have the right to opt-out of the selling or sharing of their California Personal Information, as such terms are defined under California Privacy Law.  To exercise this right, please contact us at support@thronelabs.co.  

We will not discriminate against you by offering you different products, or by providing you with a different level or quality of products, based solely upon your exercising your rights under applicable law.   

Finally, we do not “sell” or “share” California Personal Information about consumers that we know are younger than 16 years old without opt-in consent.

EXERCISING YOUR RIGHTS   

If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the California Personal Information collected or shared with third parties, please contact us at support@thronelabs.co.   When submitting your request, please include the specific nature of your request, referencing "Your California Privacy Rights," as well as your first and last name, email address, and zip code or mailing address.  We may apply any exceptions or other conditions available under law when responding to access, correction, deletion, or other requests. We will generally fulfill requests for access, correction, and deletion within 45 days of receiving a valid verified request. We may extend the response time by another 45 days by notifying the individual of the time extension. 

AUTHORIZED AGENTS

To the extent that you elect to designate an authorized agent to make a request on your behalf, the authorized agent must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of the agent’s identity; a valid, designated power of attorney as defined under the California Probate Code, and certificate of registration as an agent before the California Secretary of State.  If you are an agent submitting the request on behalf of a California consumer, please contact us at support@thronelabs.co.

DATA RETENTION

We keep your California Personal Information for as long as needed or permitted according to the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) for the duration of a contract with you; (iii) as required by a legal obligation to which we are subject to; or (iv) as advisable considering our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).   We may remove California Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we may delete California Personal Information from our database at any time and without providing any reason.

SHINE THE LIGHT

Separately, under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us their Personal Information are entitled to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant sharing in the prior calendar year (so, requests submitted in 2023 would be applicable to relevant disclosures (if any) in 2022). If you are a California resident and would like to make such a request, please contact us at support@thronelabs.co, using the subject line "Request for California Privacy Information." In your request, please attest to the fact that you are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address from which you submitted your request. Please note that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.