Privacy Notice

Last updated: July 24, 2024

Welcome

‍Security and privacy are at the heart of what we do. Accordingly, we think it is important to be transparent about what personal data we collect, how we use it, with whom we share it, and how we store it. This Privacy Notice describes how we process and handle data provided to us in connection with your use of certain of our products, services, apps, and websites that link to this notice (we refer to these collectively as our “services”).

This notice uses the term “personal data” to refer to information that is related to an identified or identifiable natural person and is protected as personal data under applicable data protection laws.

Who are we

This notice covers Super Unlimited Inc., VPN Super Inc., Free VPN Pte. Ltd, and Mobile Jump Pte. Ltd's data collection and processing practices with respect to any virtual private network (VPN) applications offered by each of them, including VPN - Super Unlimited Proxy.

In this notice, “we,” “us,” and “our” refer to the particular company from the list above that provides you with the services and is responsible for handling your data in accordance with this notice. For mobile apps, you can identify which company this is by looking at which company is listed as offering the app on the download page for that app or reviewing its terms of service.

Age Restrictions‍

Our services are not intended for and may not be used by minors. In this context, minors are individuals under the age of 16 (or such lower age as may be applicable in a jurisdiction). We do not knowingly collect personal data from minors. If we discover that we have collected personal data from a minor, we may close their account and delete associated data without notice.

Key Assurances about VPN - Super Unlimited Proxy

• VPN - Super Unlimited Proxy does not record your VPN browsing activities in any way that can be associated with you. When you use a VPN connection, we do not store any information that identifies what you browse, view, or do online via that VPN connection. The exception is when you choose to communicate with us (such as via chat or email) over a VPN connection and choose to identify yourself to us.
• Data over our VPN connections is encrypted and we do not inspect or record the contents of what you are browsing, viewing, or doing through them (unless you are using the VPN connection to communicate with us).
• Since we do not collect your VPN browsing activities, even if we were compelled to share user activity data, there would be nothing to give.
• Free versions of our VPN products are supported by personalized ads, but these ads are not personalized based on any of your VPN browsing activity, nor do we share any such activity with our advertising partners. Personalization is conducted by our advertising partners, who collect personal data such as your user-resettable advertising identifier (e.g. AAID or IDFA) and combine it with the information they have to show you ads that they believe are more relevant to you. Google allows you to disable your advertising identifier via Google account settings. You can disable the Apple advertising identifier via Apple device settings.
• Paid versions of our VPN products do not contain ads, and therefore do not send information to these advertising partners.

1. What information do we collect about you?

This section describes the various types of information we collect from and about you. We may collect the types of information described below.

Information you provide to us

• Account information. Our services generally do not require you to create an account to use them. If you decide to create an account, we may collect information such as your name, username, email address, and password.
• Transactional information. If you purchase services from us, you will need to provide payment information to make your purchase. We use industry-standard payment processor services to handle payment information. Such services are subject to separate terms and privacy policies. We also collect information about what you are purchasing, such as billing address, subscription types, currency, purchase dates, and amounts.
• Customer support information. If you contact us for support, we collect information from you to help diagnose and resolve the issue. This information may include your contact information (e.g. e-mail address), payment information, and information about your use of the services.
• Other submissions. We collect information you submit when you respond to surveys we send, provide feedback, participate in promotions, apply for a job, or otherwise communicate with us.

‍Information collected automatically when using our services

• IP address. We may collect your IP address when you use our services and also derive your approximate location based on your IP address. See section 2 to understand what we use your IP address and derived location for. However, we do not store your IP address.
• User interaction data. We collect information about how you interact with our websites, applications, and advertisements that we may publish. For example, we may track what user interface elements are clicked on.
• Device information. We and our ad networks collect information from and about the device you use to access our services. We may collect device model, device settings, operating system, network information, and application version numbers. Our ad networks only collect this information for free users.
• Device hash. We may generate a unique hash for each device that uses our services. The device hash is randomly generated and you can re-install the app to get a new device ID. Device hashes are not linked to VPN browsing activity or user identities.
• Advertising identifiers. Our ad networks may collect your device identifier for marketing and analytics purposes. Google allows you to disable your advertising identifier via Google account settings. You can disable the Apple advertising identifier via Apple device settings.
• VPN application information. We do not store your VPN browsing activity (e.g. websites you browse or apps accessed through a VPN connection). However, we may collect diagnostic information as referenced above. We also collect anonymized application usage data such as speed, latency, connection success, login success, feature usage, error reports, and troubleshooting reports.

• Information from cookies and similar technologies. We may receive information from cookies and similar technologies. You can read more about these in our cookie policy in Section 5. 

Information provided to us by third parties

• Referrals. If you are invited to use our service, the person who invited you may submit your personal data, such as your email address or other contact information.
• Third Party Accounts. Some services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you do so, that third party may send us some information about you that they have. You may be able to control what information they send us via your privacy settings for that third party account.
• Threat Information. We may receive information from reputable members of the security industry who provide information to help us to provide, develop, test, and improve our services (for example, lists of malicious URLs, spam blacklists, phone number blacklists, and sample malware). Some of this information may contain personal data on an incidental basis.

2. What do we use the information for?

• To provide, maintain, troubleshoot, and support our services. We use your information since it is required to fulfill our contractual obligations to you, such as providing you access when you have an active subscription, using IP address information to connect you to the best VPN server, using usage information to troubleshoot a problem you report with our services, and ensuring the proper functioning of our services.
• For billing and payment purposes. We use your account and transactional information to perform billing administration activities and process payments, which are required to fulfill our contractual obligations.
• To communicate with users and prospective users. We use your information to communicate with you, which includes responding to your support and other requests, and sending you information and updates about our services. We may do this to fulfill our contract with you, because you consented to the communication, or because we have a legitimate interest in providing you with information about our services. You can opt out of marketing communications at any time.
• To improve our services. To continue to improve our services, we use your information to understand how users interact with our services. For example, we analyze usage, device, and diagnostic information to understand usage trends and user engagement with our services. This allows us to increase servers where demand has increased. We may use device and threat information to conduct spam, threat, and other research to improve our threat detection capabilities. We review customer feedback to understand what we could be doing better.
• To develop new services. We have a legitimate interest in using your information to plan for and develop new services. For example, we may use customer support requests and user feedback to understand what new services users may want.
• To market and advertise our services. We may use your information to provide, measure, personalize, and enhance our advertising and marketing based on our legitimate interest in offering you services that may be of interest. For example, we may use information such as who or what business referred you to our services to understand how effective our advertising is; we may use information to administer promotional activities such as sweepstakes and referral programs. We do not collect your VPN browsing activity or use it for these (or any other) purposes.
• To prevent harm or liability. We may use information for security purposes (such as to investigate security issues or to monitor and prevent fraud) and to prevent abuse. We may do this to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or liability to us and our users. For example, we may use account, usage, and device information to determine whether an entity is engaging in abusive or unauthorized activity in connection with our services.
• For legal compliance. We internally use your information as required by applicable law, legal process, or regulation. For example, we may use your billing address to ensure we comply with embargoes and sanctions. To learn about our practices regarding sharing your information with third parties for legal compliance purposes, see Section 3 below. We use your information to enforce our legal rights and resolve disputes. We use your information to determine local taxes.
• IP addresses. We know that IP addresses can be regarded by users as sensitive information.
  • While collection of your IP address is required from a technical perspective to enable the use of our services, IP addresses are neither stored nor used beyond the period that they are required for such use (i.e. the duration of a VPN session). We do not associate IP addresses with any VPN browsing activity.
  • We also use IP addresses to approximate your location by calculating an imprecise latitude and longitude. Once we have ascertained your location, we discard the IP address. We use your approximate location to provide you with better service (e.g. to connect you to the nearest and fastest VPN server) and more relevant personalized advertising if you are a free user who has not opted out of such advertising.

Note that we may use and disclose aggregated data and data that is de-identified such that it no longer reveals the identity of an individual user for regulatory compliance, research, and analysis, our own or third party marketing and advertising activities, and other legitimate business purposes.

3. With whom do we disclose your personal information?

We may disclose your information in the following circumstances:

• In accordance with your instructions or consent. For example, some services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you choose to do so, we will collect your email address and name from the third party account provider. The third party account provider may collect registration and sign in information.
• Affiliates and third party service providers. To help us provide some aspects of our services, we work with our affiliates and trusted third parties. To protect your data, we enter into appropriate confidentiality and data processing terms with these third parties, review their security practices, and limit information sharing to the scope of what they are helping us with. Examples of activities that third parties help us with include:
  • processing customer payments
  • providing analytics about our services
  • providing sales and customer support
  • maintaining the infrastructure required to provide our services
  • delivering our marketing and advertising content
  • serving advertising content

• To a new owner. If ownership or control of all or part of our services, assets, or business changes, we may transfer your information to the new owner.
• To comply with legal processes and the law. For our VPN products, we protect your privacy by ensuring that we do not log or record online activities that you conduct over a VPN connection in any way that can be tied back to you, meaning that we do not have any data to share with law enforcement and government agencies who make requests for information about what you were doing through a VPN connection. Subject to the foregoing, we may disclose your information related to your account such as your email address if we are required to do so by applicable law; to comply with our legal obligations; to comply with legal processes; and to respond to valid law enforcement requests relating to a criminal investigation, or alleged or suspected illegal activity that may expose us, you, or any of our other users to legal liability. If we disclose your information for these purposes, we limit the information disclosed to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.
• To enforce our rights and prevent fraud and abuse. We may disclose limited amounts of your information to enforce and administer our agreements with customers and users, and to respond to claims asserted against us. We may also disclose your information to protect against fraud and abuse against us, our affiliates, users, and others.

4. Use of Advertising Services With Free VPN Products

For users of our free VPN products, we may serve ads through the use of third party advertising services. As previously noted, we do not collect VPN browsing information or share VPN browsing information with advertising service providers. However, as with any online advertising service, the entities will have access to the information associated with ad delivery such as which website or app the ad was delivered to, and certain device-specific information.

To display ads in our apps, we may use third party software development kits (SDKs), which consist of software code provided by a third party that is embedded in our apps. These SDKs may collect the following information from your device or use:

• Device or mobile advertising identifiers (controlled by your mobile operating system)
• IP address, which may reveal your approximate geographic location as determined by your carrier or ISP. However, when using the VPN service, this may replace your actual location with an alternative geographic location.

• Device-specific information such as make, model, OS version, language, time zone, and other information.
• The name of the app or website serving the ad.

As some ads may be personalized based on your mobile advertising identifier or IP address, you may see an AdChoices icon on an ad. You can click this icon to learn more about the ad network that provided the ad, its privacy policy, and your choices regarding opting out from any personalized advertising. If you opt out from personalized advertising, you may still see non-personalized ads. While we request you not to use ad blockers to prevent the display of ads because that is how we support our free services, our services can continue functioning if you do use ad blockers.

Advertising services we use to provide ads with our free VPN products may include:

In addition, you may opt out of interest-based mobile advertising by utilizing the Digital Advertising Alliance (DAA) AppChoices app.

5. Tracking Technologies & Cookies

About Tracking Technologies

We use various technologies in our services to help us collect information which may include tracking links and pixel tags/page tags/web beacons. These are small, hidden images and blocks of code placed in web pages, ads, and our emails that allow us to determine if you perform a specific action. When you access a page, ad, or email, or click a link, these items let us know that you have accessed that page, opened an email, or clicked a link. For convenience, we refer to these as “tracking technologies,” although they are not always used to track individuals and the information collected is in a non-identifiable form that does not reference any personal data.

SDKs

SDKs or software development kits are software code provided by our advertising network or other business partners that let our software interact with the services those partners provide. For example, in certain of our mobile apps, we may use an SDK to enable our app to serve ads from an advertising network. Sometimes these interactions will involve that business partner collecting, using, and tracking some information from the device on which the software is run.  See above regarding the type of information that is collected and used for advertising purposes.

Cookies

Cookies are small portions of text that are stored on the device you use to access our services. Cookies enable us (or third parties that we allow to set cookies on your device) to recognize repeat users. Cookies may expire after a period of time, depending on what they are used for. We use cookies:

• To provide our services. Some cookies are essential for the proper operation of our services. For example, cookies allow us to authenticate who you are and whether you’re authorized to access a resource.
• To store your preferences. Cookies can store your preferences, such as language preferences or whether to pre-fill your username on sign in forms. We may also use them to optimize the content that we show to you.
• For analytics. Cookies are used to inform us how users interact with our services so we can, as a legitimate interest, improve how they work (such as what screens or webpages you access, and whether our advertising is effective).
• For security. Cookies can enable us and our payment processors to detect certain kinds of fraud.
• For advertising-related purposes. We advertise our services online with the help of third parties who show ads and marketing about us on sites around the internet.

Third Parties

We may allow our business partners to place certain tracking technologies in our services. These partners use these technologies for the following purposes:

• To provide our services. Some business partners who help us to provide our services may use these technologies to support those efforts.
• For Analytics. To help us understand how you use our services.
• For Marketing. To help us market and advertise our services to you, including on third party websites. Cookies are used in connection with this to measure the performance of our advertising, attribute actions you take with our ads with actions you take on our services, deliver ad retargeting (serving ads based on your past interactions with our services), and target ads at similar audiences.
• To Serve Ads. Ad networks may use these technologies to display ads which they think will be more relevant to you. For more information, please see the “Displaying Advertisements” section above.

Your Choices

• Our Cookies: Most web browsers and some mobile devices give you the ability to manage your cookie preferences, including deleting cookies and blocking cookies from being set on those browsers or devices. Visit the “help” section of your mobile device to understand what controls it gives you over cookies. Note that deleting or blocking certain cookies could adversely impact the proper operation of our services.
• Third Party Advertising Cookies: For information on how to opt out of personalized or interest-based advertising, you can visit the following pages:some text
  • Network Advertising Initiative opt out page
  • Digital Advertising Alliance opt out page
  • Your Online Choices (for Australian residents)
  • Your Online Choices (for EU residents)
• Google Ads. To opt out from Google ad personalization, visit the Google Ads Settings page. These opt out mechanisms are not provided by us and we are not responsible for the availability or operation of them. Note that after opting out of personalized advertising you may still see non-personalized ads.
• Google Analytics. We use Google Analytics to help us understand how users use our services. Google makes available a Google Analytics Opt Out Browser Add-On if you do not want to participate in Google Analytics.

6. Security

We employ a range of administrative, organizational, technical, and physical safeguards designed to protect your data against unauthorized access, loss, or modification. Access to your account and other information is restricted to our team members who require such access to perform their job functions. While our controls are strong, no data security measures can guarantee 100% protection.

7. International Data Transfers

We may transfer your personal data to countries other than the one in which you reside. We do this to facilitate our operations, and transferees include our group companies, service providers, and partners. Laws in other countries may be different to those that apply where you reside. For example, personal data collected within Switzerland, United Kingdom or the European Economic Area (EEA) may be transferred and processed outside Switzerland, United Kingdom or the EEA for purposes described in this policy. 

However, we put in place appropriate safeguards that help to ensure that such data receives an adequate level of protection. You may contact us if you would like more information about such safeguards.

8. Data Retention

We generally retain your personal data for as long as is needed to provide the services to you, or for as long as you have an account with us. We may also retain personal data if required by law, or for our legitimate interests, such as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data may be stored in backup systems as a security measure to protect against data loss. 

We do not store or retain data about your VPN browsing activity.

9. Marketing Communications and Third Party Web Site Links

Marketing Communications. If you receive marketing emails from us, you may unsubscribe at any time by following the instructions contained within the email. Note that you may continue to receive transaction-related emails regarding services you have requested. Using the unsubscribe link will not halt those communications.

Push Notifications. If you opt in to receive push notifications, we will send you push notifications. If you no longer wish to receive these types of communications, you may turn them off through your device settings.

Third Party Links. The services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this notice, this notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy policies.

10. Your Rights

Depending on your location of residence, you may have certain legal rights in relation to your personal data that we maintain. Subject to exceptions and limitations provided by applicable law, these may include the right to:

• access and receive a copy of your personal data;
• correct your personal data;
• restrict the processing of your personal data;
• object at any time to the processing of your personal data;
• have your personal data erased;
• data portability;
• withdraw any consent you previously gave to the processing of your data (such as opting out to marketing communications);
• lodge a complaint with a data protection authority;
• request that we provide you with the categories of personal data we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal data; and the categories of third parties with whom we disclose personal data. This information may also be provided in this Privacy Policy.

Please note your rights and choices vary depending upon your location, and some information may be exempt from certain requests under applicable law.

You may be able to exercise some of these rights by using the settings and tools provided in our services. For example, you may be able to update your user account details via the relevant account settings screen of our apps. You may also be able to opt out from receiving marketing communications from us by clicking an “opt out” or “unsubscribe” link in such communications.

Otherwise, if you wish to exercise any of these rights, you may contact us using the details in the “Contact Us” section. As permitted by law, we may ask you to verify your identity before taking further action on your request.

If you want to delete your account, you may do so at any time by contacting us at the email provided in the “Contact Us” section. Please note we may retain some personal information for certain legal, security, and business needs. For example, we’ll retain information about any purchases you may have made through the services, and about when you accepted our terms of service.

11. Privacy Notice Updates

We may update this Privacy Notice from time to time in accordance with this section for reasons such as changes in laws, industry standards, and business practices. We will post updates to this page and update the “Last updated” date above. If we make updates that materially alter your privacy rights, we will also make reasonable efforts to provide you with advance notice, such as via email or through the services. If you disagree with such an update to this policy, you may stop using the services and cancel your services account. If you do not cancel your account before the date the update becomes effective, your continued use of our services will be subject to the updated Privacy Notice.

12. Contact Us

We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you have any questions or complaints about our privacy practices, you can contact us using the following details:

Super Unlimited Inc.

541 Jefferson Ave

Ste 100

Redwood City 

CA 94063, USA

Email: privacy@superunlimited.com

If you are a resident of the European Economic Area, Switzerland, or the United Kingdom and wish to exercise your rights under Section 10 (Your Rights), you may contact DataRep, which is Super Unlimited’s Data Protection Representative in the European Union, Switzerland, and the United Kingdom. DataRep can be contacted using the following details:

Web form: https://www.datarep.com/data-request

• Email: datarequest@datarep.com (you must also quote “Super Unlimited Inc.” in the subject line)
• Mail (Ireland/EU/EEA): DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
• Mail (Switzerland): DataRep, Leutschenbachstrasse 95, Zurich, 8050, Switzerland
• Mail (UK): DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
• Mailing addresses for other EU countries are available upon request to privacy@superunlimited.com

Region-specific disclosured

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions, or states. Please refer below for disclosures that may be applicable to you:

R1. Additional privacy information for residents of Colorado, Connecticut, Utah, Nevada, and Virginia

In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information:

R2.1. Do Not Track Signals

• Right of Access: You may have the right to obtain
  • some text;
  • copy of the personal information we hold about you;
  • information about the categories of recipients with whom we may share your personal information;
  • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  • confirmation of whether, and where, we are processing your personal information.
• Right of Portability: You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
• Right to Rectification or Correction: You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
• Right to Deletion or Erasure: You may have the right, in some circumstances, to require us to delete erase your personal information.
• Right to Restriction: You may have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
• Right to Opt-Out: You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or to “sell” or “share” your personal information with third parties in certain contexts.
• Right to Withdraw Consent: If you have provided consent for the processing of your personal information, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
• Right to Appeal: In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.

Nevada rights

Under Nevada law, certain Nevada consumers may opt out of the sale of information about you. We do not sell your data in accordance with Nevada Senate Bill 220. However, if you are a Nevada resident you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the details in the “Contact Us” section. Please note, if needed, we may take reasonable steps to verify your identity and the authenticity of the request.

R2. Your California Privacy Rights

This Section applies solely to California residents.

We currently do not respond to “Do Not Track” signals sent by browsers or mobile apps due to a lack of standardization regarding how that signal should be interpreted.

R2.2. California “Shine the Light” disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes.

R2.3. Third Party Disclosure Requests

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their “personal information” (if any) as defined under California Civil Code 1798.83 for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. See the “Contact Us” section for where to send such requests. Note that we do not share personal information with third parties for their own direct marketing purposes without your prior consent.

R2.4. Opt-Out From Sale

You may have the right to opt out of the “sale” of your personal information as defined by the California Consumer Privacy Act (CCPA). The CCPA broadly defines “sale” such that it may include allowing third parties to receive certain information, e.g. cookies, to deliver personalized advertising on our services.

We do not “sell” (as defined by the CCPA) your personal information except in the context of certain versions of our products that are supported by personalized advertising. Advertising, including personalized advertising, enables us to provide certain of our products for free, to provide offers relevant to you, and, because we believe it’s important that everyone has the opportunity, regardless of their situation, to have secure and private access to the internet. Personalized advertising enables ads to be shown that are more relevant to you.

R2.5. Sale of Personal Information

As is common practice among companies that operate online, in the last 12 months, we have allowed certain third-party providers to collect information about consumers directly through our website and other online services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. As a result of this practice, in the last 12 months, we have sold (per the CCPA’s broad definition) the following categories of personal information to these third-party providers, subject to each consumer’s settings and their right to opt-out:

• Identifiers, such as IP address.
• Commercial Information, such as service information, including services of interest or orders made in connection with our services.
• Internet/Network Information, such as log data (including operating system and browser type) and analytics data (including usage and activity on our website and online services). Note this excludes VPN browsing activity data.
• Geolocation Data, such as general geographic location based on IP address.
• Since our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16, we do not sell personal information of consumers we know to be under the age of 16.

Categories of Personal Information Collected and with Whom we Share It

To opt out of our use of your information for such purposes, visit: Do Not Sell My Personal Information. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

R2.5. Additional Rights

California law may permit you to request that we:

• provide you the categories of personal information we have collected or disclosed about you in the last twelve months, the categories of sources of such information, the business or commercial purpose for collecting or selling your personal information, and the categories of third parties with whom we shared personal information. This information is provided in this Notice;
• provide access to, or a copy, of certain information we hold about you;
• delete certain information we have about you.

You may also have the right to receive information about the financial incentives that we offer to you (if any), and the right to not be discriminated against (as provided for in the CCPA) for exercising certain of your rights.

Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the services to you and for compliance with applicable law.

When you exercise certain rights, we may take reasonable steps to authenticate your identity before fulfilling your request (such as verifying your email address or payment instrument). If you ask us to delete certain information, you may no longer be able to access or use our services.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with a signed, written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us using the details in the “Contact Us” section.

R2.6. Summary of How we Handle your Personal Information

The California Consumer Privacy Act (CCPA) requires that we make certain disclosures to California residents, including the categories of personal information we collect, the purposes for which we use that information, the categories of sources of personal information, and the categories of third parties with whom we share personal information. This section lays out this information in the manner specified by the CCPA, but it does not differ in substance from the information in the rest of this policy.

Sources of Personal Information

All the categories of personal information we collect come from the following categories of sources:

• You (either via voluntary submission or automatic collection, such as when you use our services)
• Third parties (such as service providers, other users or marketing partners who may refer you to our services)

• Identifiers (such as name, account username, email address)
• Commercial information (such as transaction data)
• Financial and transactional data (such as credit card or other payment instrument details)
• Internet or other network or device activity (such as app usage and interactions with our services)
• Unique device ID 
• Geolocation information (e.g., your city and state based on IP address)
• Demographics and statistical information (such as age and gender)
• Customer service information (e.g. support requests)
• Survey responses and other research information
• Other information that identifies or can be reasonably associated with you

Categories of Third Parties with Whom we Share Your Personal Information.

The categories of personal information collected, as described above, may be shared with the following categories of third parties:

• Our corporate affiliates which are companies under our common control or a party that may acquire us or our assets.
• Third party service providers that perform services on our behalf (e.g. payment processors, analytics providers)
• Third party ad networks (e.g. Google)
• Third parties for legal purposes (e.g. in response to legal process)
• Others with your consent or at your direction

Categories of Business & Commercial Purposes for Which We Use Your Personal Information.

The categories of personal information collected, as described above, are used for the following categories of purposes:

• To provide, maintain, troubleshoot, and support our services.
• For billing and payment purposes.
• To communicate with users and prospective users.
• To improve our services.
• To develop new services.
• To market and advertise our services and to advertise the services of others.
• To prevent harm or liability.
• For legal compliance.

More information about these categories, including examples of use cases, is available in Sections 1, 2, and 3.