Global Privacy Policy - Fileverse

  1. About this Privacy Policy
    1. Fileverse Limited (Fileverse, we, us or our ) has implemented this Privacy Policy to provide information about what kinds of Personal Data we may collect or hold, how we collect, hold, use and disclose that Personal Data, choices you have regarding our use of that Personal Data, and your ability to access or correct that Personal Data. If you wish to make any inquiries regarding this Privacy Policy, you should contact us in any of the ways specified in paragraph 15.
    2. From time to time, Fileverse may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your Personal Data by us and by those related entities. A reference in this Privacy Policy to Fileverse, we, us or our is also a reference to those related entities.
  2. Personal Data
    1. "Personal Data" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable from the data or from the data and other information to which the organization has or is likely to have access.
  3. User Content and our services
    1. Our services offer a straightforward and personalised solution for storing your files, documents, photos, comments, messages, and anything else you upload or share via our services (User Content). Unless otherwise specified in this privacy policy, Personal Data includes User Content. Our services enable you to collaborate with others and work seamlessly across various devices and platforms.
    2. Our services offer two options, users can:
      1. create an account with us to access the full range of services, or
      2. use our services without an account, which will grant you access to our services in a limited way.
    3. Upon creation of an account via Privy.io, We will seek that you connect your crypto wallet or social media account to streamline account setup and for verification purposes. In the event that you lose access to an account or otherwise request Information about an account, we may request verification we deem necessary before restoring access to or providing information about such account.
    4. For users with an account, to facilitate your User Content, we store, process, and transmit User Content, along with related information. This related information includes your profile details, which enhance collaboration and sharing capabilities, as well as data such as file size, upload time, collaborators, and usage activity.
  4. What Personal Data do we collect and hold?
    1. The types of Personal Data we may collect about an individual will depend upon the nature of our interaction with them. Paragraph 3.2 describes the two types of users we have.
    2. Personal Data that we collect may include (but is not limited to) the following:
      1. users with an account: your full name; date of birth; contact details; business or company details (if you sign up to our use your services on behalf of your business); third party accounts you chose to link to your Fileverse account; and the further information set out in paragraphs 3, 3.5 and 6
      2. users without an account: we do not see your User Content and only collect the information set out in paragraph 3.5 and 6
      3. our investors and shareholders: identification information and information about your shareholding, to identify our investors and shareholders and to administer their investment in Fileverse
      4. our suppliers, potential suppliers, and their representatives: generally information to assess your business (such as its key personnel); and business contact information (names, roles, contact details) to communicate with you, arrange and administer your provision of services to us
      5. our employees past and present, including job applications: occupation and employment details including employment status and any previous work experience; information in connection with your employment with us (which may include health information); and information from or in connection with your resume or job application if you apply for a position with us (including information from referees and to verify your qualifications, work and academic history), and
      6. any person who comes into contact with Fileverse or our technologies: information about your contact with us; photographs and/or images from camera footage such as CCTV cameras in our premises; information from social media accounts and profiles, and other publicly available sources; and the information set out in paragraph 5.
  5. How and when do we collect Personal Data?
    1. We collect your Personal Data to allow us to conduct our business functions, to provide and market our services and for the specified purposes set out in paragraph 6. In some circumstances the collection of Personal Data may be required by law.
    2. We may collect your Personal Data in the course of providing you with goods or services, or:
      1. when you use services
      2. when you provide us, or you offer or apply to supply us, with goods or services
      3. when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card)
      4. when you request information about us, our services
      5. when you provide feedback to us
      6. when you visit or fill in a form on our Website (see paragraph 5)
      7. when you register for or use an account on our Website
      8. when you visit premises from which we operate
      9. when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations
      10. when you submit a job application to us,
      11. when you otherwise contact us by telephone, fax, email, social media, post or in person, or
      12. where we are otherwise required or authorised by law to do so.
    3. Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect personal information directly from the relevant individual where reasonable and practicable.
    4. We may also collect Personal Data about you from third parties and other sources such as:
      1. third party accounts that you link to your Fileverse account
      2. your nominated representatives (eg spouse accountant, power of attorney, brokers and other professional advisors)
      3. publicly available sources of information, or
      4. related entities, companies and businesses of Fileverse,
      but we will only collect your Personal Data in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.
    5. If the Personal Data we collect includes sensitive information, including health information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent or this type of information is uploaded by you as User Content.
    6. Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.
    7. If you choose not to provide your Personal Data to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Data we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.
  6. Information collected via our Website and applications
    1. Personal information may be collected by us and by our third party service providers who assist us in operating our website at https://docs.fileverse.io, including its subdomains and any other website we operate from time to time (collectively the Website).
    2. We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website or using our applications, including but not limited to the methods set out in this paragraph 5.

      Google Analytics
    3. We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.
    4. If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.

      Click Stream Data
    5. When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. This information is used for statistical, reporting and website administration, maintenance and improvement purposes.

      Cookies
    6. Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.
    7. Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.
    8. Cookies may also be used for other purposes on our Website.
    9. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
    10. If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

      Web Beacons
    11. Web beacons are images that originate from a third party site to track visitor activities. We use web beacons to track the visiting patterns of individuals accessing our Website.

      Third party content
    12. Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. This also includes where you chose to link a third party account to your Fileverse account. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Data.
  7. How do we use your Personal Data?
    1. We use the Personal Data we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our services for the benefit of our customers.
    2. We may collect, hold and use your personal information:
      1. to identify and communicate with you
      2. assist you get into your account, if you have lost access
      3. facilitate access to your User Content
      4. to enable us to provide you with requested information or services
      5. to otherwise assist you by providing information and support
      6. to help us to manage and enhance products or services we provide to you
      7. to help us to manage and enhance goods and services we procure from our suppliers and subcontractors
      8. to personalise and customise your experiences on our Website
      9. to manage and administer any account you may hold with us
      10. to promote and market our services to you
      11. to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners
      12. to conduct research for the purposes of improving existing services or creating new services
      13. to help us research the needs of our customers to enable us to market our products and services with a better understanding of your needs and the needs of customers generally
      14. to protect you and us from fraud
      15. to provide for the safety and security of workers and onsite visitors
      16. to help us manage our business operations
      17. for business support purposes including maintenance, backup and audit
      18. to process any job application submitted by you
      19. to respond to any queries or complaints you may have, or
      20. to comply with our statutory and legal obligations.
    3. As part of our services, you have to option to engage in peer-to-peer (P2P) networks. Please be aware that while using P2P networks, certain information may be shared with other users in the network, including your IP address. We do not collect or monitor the content transmitted through P2P networks, but we advise you to be mindful of the information you share, as it may be visible to other users and outside of our direct control.
    4. We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.
    5. We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.
    6. You consent to us using your Personal Data in the above ways and as set out in this Privacy Policy.
    7. We may otherwise collect, use or disclose your Personal Data where the collection, use or disclosure is:
      1. in accordance with this Privacy Policy or any agreement you enter into with us, or
      2. required or authorised by law, including without limitation the Singapore Personal Data Protection Act 2012.
  8. When do we disclose your Personal Data?
    1. Fileverse may disclose, or provide access to, your Personal Data to third parties in connection with the purposes described in paragraph 6.
    2. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Data to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).
    3. Unless where authorised or required by law or to facilitate our services to you, e.g. to our data storage providers, Fileverse will not disclose your User Content to third parties.
    4. We may also disclose your Personal Data to:
      1. any of Fileverse's internal divisions, business units or departments
      2. your nominated representatives
      3. other organisations or individuals who assist us in providing services to you (including the third party accounts you link to our services when we need to assist you get into your account, if you have lost access)
      4. professional service providers and advisors who perform functions on our behalf, such as lawyers
      5. medical providers including medical and rehabilitation practitioners for assessing insurance claims
      6. representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)
      7. debt collecting agencies
      8. banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers, and
      9. Government, regulatory authorities and other organisations as required or authorised by law (such as Centrelink or the Police).
    5. We may also disclose your Personal Data to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
    6. As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Data. In such transactions, Personal Data may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Data to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.
  9. Overseas disclosures
    1. Some of your Personal Data may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:
      1. our offices or related entities are overseas
      2. we outsource certain activities overseas
      3. transactions, information, services or products have an overseas connection, or
      4. our computer systems including IT servers are located overseas.
    2. You consent to the collection, use, storage, and processing of your Personal Data in locations around the world – including those outside your country.
    3. In particular, your Personal Data may be disclosed to third parties in Australia, Singapore, the EU and the US and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy.
  10. Other uses and disclosures
    1. We may collect, use and disclose your Personal Data for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Data.
  11. Marketing
    1. You consent to us using your Personal Data for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.
    2. If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:
      1. clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us
      2. logging into your account on the Website and editing your communication preferences, or
      3. contacting us using the contact details specified in paragraph 15.
  12. Storage and security of Personal Data held by us
    1. We aim to keep your Personal Data secure. Any Personal Data that is collected via our Website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.
    2. If we find that we no longer require or have no further need for your Personal Data we may de-identify it or remove it from our systems and destroy all record of it.
    3. We utilise data storage providers to store User Content, as well as caching servers. Caching servers temporarily store your User Content to reduce load times and ensure faster access to frequently requested User Content. These servers do not collect or store any Personal Data about you except for the Personal Data included in your User Content. Any cached data is typically deleted or refreshed after a set period to ensure you are receiving the most up-to-date User Content.
  13. You can access, update and delete your Personal Data
    1. You have control over your User Content and can access, amend or delete it at any time via logging in to your account.
    2. Outside of your User Content, your rights in relation to the Personal Data that we hold to facilitate our services to you include:
      1. you are generally entitled to access Personal Data that we hold about you. If you request access to your Personal Data, in ordinary circumstances we will give you full access to your Personal Data. Depending on the nature of the request, Fileverse may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Data, we will provide you with reasons for the refusal where we are required by law to give those reasons.
      2. we take all reasonable steps to ensure that any Personal Data we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.
      please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Data is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information. It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.
  14. How do we deal with complaints about privacy?
    1. If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact us in any of the ways specified in paragraph 15 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.
    2. It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.
    3. We will notify you of the outcome of our investigation.
  15. Updates to this Privacy Policy
    1. We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Data held by us will be governed by our most recent Privacy Policy, posted on our Website at: https://docs.fileverse.io/privacy-policy where the Privacy Policy will be located. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.
  16. What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Data or this Privacy Policy
    1. If you:
      1. have a query or concern about this Privacy Policy or our Personal Data handling processes
      2. wish to make a complaint in relation to a breach of your privacy
      3. would like to access your Personal Data held by us
      4. would like to update or correct your Personal Data held by us, or
      5. would like to opt out of direct marketing,
      please contact us at hello@fileverse.io.

  17. This Privacy Policy was last updated on 27 November 2024.
  1. Appendix 1 - Additional Information and Rights for Individuals Located in the EU or the UK
    Under the GDPR individuals located in the EU or the UK have certain additional rights which apply to their Personal Data. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix sets out the additional rights we give to individuals located in the EU and the UK, including how we process Personal Data lawfully, transparently and fairly. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.
    1. Additional Rights
      This Appendix applies to the Personal Data set out in the Privacy Policy above. This includes any sensitive information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.
    2. Our commitment to you
      Your Personal Data will:

      • be processed lawfully, fairly and in a transparent manner by us;
      • only be collected for the specific purposes we have identified in paragraph 7 and Personal Data will not be further processed in a manner that is incompatible with the purposes we have identified
      • be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the Personal Data is processed
      • be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your Personal Data)
      • be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the Personal Data was collected, and
      • be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.
    3. How we process Personal Data
      We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

      • where we need to perform the contract we are about to enter into or have entered into with you
      • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, and
      • where we need to comply with a legal obligation.

      Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message.

      You have the right to withdraw consent to marketing at any time by contacting us or by clicking on the unsubscribe link in each marketing email you receive from us.

      We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

      If you refuse to provide us with certain Personal Data or if you provide us with incomplete or inaccurate information required for the performance of the contract or for compliance with a legal obligation, please be aware that we may not be able to provide or deliver to you all or parts of the service that you require.

      We only collect Special Categories of Personal Data where you have given your explicit consent, it is necessary to protect your vital interests or those of other people or where you have deliberately made it public.

      See above in the main section of this Privacy Policy at paragraph 7 to find out more about the types of lawful basis that we will rely on to process your Personal Data.
    4. Data Transfers
      We may transfer your personal data to third parties located outside of the European Economic Area and the United Kingdom. We will provide appropriate safeguards for such transfers.

      When transferring personal data out of the European Economic Area or the United Kingdom, we will use either the "Standard Contractual Clauses" as approved by the European Commission or the United Kingdom Government (as applicable) or any other contractual agreement approved by the competent authorities as a basis for the transfer.

      Where these contractual agreements are not sufficient to ensure an adequate level of data protection at the recipient, we will implement supplemental safeguards.

      Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the European Economic Area and/or the United Kingdom.
    5. Data Retention
      You have control over your User Content and delete it at any time.

      Outside of your User Content, we will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

      To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes through other means and the applicable legal requirements.

      In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

      In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
    6. Your legal rights
      You have control over your User Content and can access, amend, delete your User Content at any time. Outside of your User Content and under certain circumstances, you have rights under data protection laws in relation to your Personal Data:

      You have the right to:
      • request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it
      • request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
      • request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
      • object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
      • request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
        • if you want us to establish the data's accuracy
        • where our use of the data is unlawful but you do not want us to erase it
        • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, and
        • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it,
      • request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you, and
      • withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

      If you wish to exercise any of the rights set out above, please contact us using the details at paragraph 16 in the Privacy Policy.

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

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

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

      You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
  2. Appendix 2 - Additional Rights for Individuals Located in the US
    The California Consumer Privacy Rights Act provides California residents with specific rights regarding their Personal Data. This Appendix sets out additional rights granted to residents of California.
    1. Sale or Share of Your Personal Data
      We do not “sell” or “share” your Personal Data, as the term is defined in the California Privacy Rights Act.
    2. Data Retention
      You have control over your User Content and can delete it at any time.

      Outside of our User Content, we will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

      To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes through other means and the applicable legal requirements.

      In some circumstances you can ask us to delete your data: see below in this Appendix for further information.

      In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
    3. Your Right to Access, Delete, and Correct

      You have control over your User Content and can access, amend, delete your User Content at any time. Outside of your User Content and under certain circumstances, you have rights in relation to your Personal Data.

      You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and validate your request, we will include a list of your Personal Data that may have been disclosed and the categories of third parties the information may have been disclosed to.

      You may request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request. We may deny your deletion request if retaining the information is proper and necessary or if an exception allowing us to retain the information applies.

      You may also request that we correct any of your Personal Data that has become outdated or needs correction for any reason.

      If your request is approved, we will delete, correct, or deidentify the relevant information and will direct our service providers to take similar action.

      Exercising Your Rights to Know, Delete or Correct

      California residents may exercise their rights to know, delete or correct as described above by using the contact details at paragraph 16 in the Privacy Policy. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data.

      You may only submit a request to know twice within a 12-month period. We endeavor to substantively respond to a Verifiable Consumer Request within forty-five (45) days of its receipt, unless we require an extension. If we reasonably require an extension we will inform you of the reason and extension period.

      Non-Discrimination

      We will not discriminate against you for exercising any of your data subject rights.

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

      California’s Shine the Light Law

      California Civil Code Section 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of the information you provide through the Services to third parties for their direct marketing purposes. To make such a request, by using the contact details at paragraph 16 in the Privacy Policy.

      Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one Shine the Light request per consumer each year, and we are not required to respond to requests made by means other than through the e-mail address or mailing address provided in this Policy.

      Participation in Financial Incentive Programs

      We will notify you in the event we offer any financial incentive for the use of your Personal Data. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms.