Our privacy policy

TechnicalRequirements

Browsers

WorkAdventure requires a recent browser. It is compatible with the latest versions of:

• Google Chrome
• Firefox
• Safari
• Microsoft Edge
• Mobile browsers (tested with Chrome on Android, Safari on iOS)

WorkAdventure is not compatible with:

• Internet Explorer (and probably never will be compatible with it)

Network

WorkAdventure requires access to the domain name “workadventu.re” as well as to all subdomains.

Connections are secured using HTTPS.

The domain name “play.workadventu.re” is used for the real-time aspect (user position sharing, etc…). A web-socket connection is established on this domain (“wss” protocol, on port 443).

Video, audio and chat connections (in the conversation “bubbles”) are provided in WebRTC. The connection between browsers will be attempted in “peer-to-peer” mode using the ICE protocol. That is, browsers will attempt to connect to each other without going through an intermediary server. They will attempt connections in IPv4, IPv6, UDP, TCP, etc. If no live solution works, they will try to go through a relay server (called TURN server).

TURN server:

• Port: 443
• Domain: coturn.workadventure.fr

During meetings in a meeting room, the video streams pass through a “Jitsi” server which centralizes the stream and redistributes it to the participants.

Technical Requirements

Architecture

Front Server: This server serves the static files of WorkAdventure (HTML, JS, images, etc.)

Pusher: These servers receive websocket connections from browsers and transmit them to “API” servers. Pusher servers have the role of “dispatcher”. They are developed in NodeJS. Pusher servers do not store anything.

API: API servers host the “rooms” in which users move. They centralize the position of each player. The data is only stored in RAM. API servers do not perform any physical storage.

Map Storage: stores the WAM files that contains all the parts of a map that can be edited using WorkAdventure inline editor.

Admin: The admin server provides the graphical interface to account administrators: room management, management of members authorized to enter its rooms, etc. It is the only component to perform data storage (see the “privacy” chapter for the nature of the data stored).

Maps: the maps are hosted on a separate web server. You may be in control of this web server (and browsers will connect to your server to download these maps). The maps are stored in JSON format and are generally accompanied by image files (the tiles, often in PNG) or sound (MP3) if you want to add a musical atmosphere. The server must allow CORS requests from the domain name play.workadventu.re so that the browser can connect to the web server (see https://workadventu.re/map-building/hosting) If desired, the maps can contain “iFrame” that will open when a user hovers over an area of the map. The iFrame URL is stored in the card and cannot be changed (a user cannot trigger the opening of an iFrame for another user). Some sites may refuse to open inside an iFrame (see on this subject https://workadventu.re/map-building/special-zones)

Meeting rooms: The meeting rooms are provided by a cluster of Jitsi Meet servers: https://meet.jit.si/

TURN servers: If it is impossible to establish a peer-to-peer connection, the audio / video / chat streams are redirected via a TURN server. This server does not store anything, it just acts as a relay.

Good development practices

WorkAdventure is developed in “open-core”.

The “front”, “pusher”, “API” and “map-storage” bricks are available on GitHub: https://github.com/workadventure/workadventure. They are visible to everyone and regularly reviewed by the community.

A continuous integration and deployment process ensures the quality of each “pull request”.

All components of WorkAdventure are subject to internal security audits on a regular basis.

Hosting

The following components are hosted by OVH in the “Gravelines” data center:

• Admin
• Front
• Pusher
• API
• Map-storage
• JITSI Cluster

The data of the “Admin” component is stored at OVH.

The following components are hosted by AWS in the “Ireland” data center:

• TURN Servers
• WAM files stored by the Map-storage in AWS S3 

WorkAdventure acts as a “browser” of maps. Those maps can be hosted on the WorkAdventure servers OR on any web-server that you own.

If you choose to host the maps yourself

The maps can be hosted on any web server. Therefore, WorkAdventure cannot be held responsible for the content of a map. Moreover, WorkAdventure cannot be held liable for the unavailability of a web server hosting a map.

Technical and organizational measures to guarantee the protection of personal data processed

Authentication to WorkAdventure

• Authentication in the WorkAdventure administration panel is secured by a login / password pair.
• Passwords are hashed in the database using the Bcrypt algorithm with a salt.
• A minimum password complexity is ensured.
• Alternatively, WorkAdventure users are able to connect using an OpenID connect identity provider (Google, LinkedIn, GitHub or any OpenID connect identity provider configured by the administrator). 
• WorkAdventure also supports Web3 wallet authentication via MetaMask.

Authentication to IT systems / servers

• Authentication to servers is done using individual usernames and passwords when possible, or personal private keys.

Application security

• All communication is secured using secure protocols.
• Web connections are secured using HTTPS + HSTS.
• Peer to peer connections established via WebRTC are secured with the DTLS protocol.
• WorkAdventure Ops are connecting to servers using connections secured via SSH / SSL.
• All default vendor passwords have been changed.
• All unnecessary default vendor accounts have been removed.
• WorkAdventure has been developed in respect of the guidelines provided by OWASP.
• WorkAdventure relies on frameworks that provide a natural protection against the most common security vulnerabilities:
  • In the admin panel, VueJS and Blade template provide a protection against XSS attacks.
  • In virtual places, SvelteJS provides a protection against XSS attacks.
  • In the admin panel, access to the database is managed by the Eloquent ORM which secures requests against SQL injection.
  • Access control is handled by Laravel Gates and Policies.
• Every new-comer receives a one day security training.
• Any code submitted to WorkAdventure is reviewed by at least one peer during a « pull request » review.
• Continuous integration tools are in place to help automate code reviews:
  • In particular, static analysis of the code is performed (using Typescript type checker and ESLint) and unit tests are ran on every Git push.
  • Vulnerable dependencies are automatically flagged by Dependabot.
• Test, staging and production environments are segregated. They run on a different cluster of servers.
• All administration tasks are performed using secure protocols (SSH and SSL)

Servers security

• At the OS layer: Our virtual machines are installing security patches automatically on a daily basis.
• Our Kubernetes cluster is managed by OVH which provides automatic patching.
• Third party dependency vulnerabilities are tracked using Dependabot. Patches are tested within a business week and applied to the next version of WorkAdventure. We can apply a patch within a business day in the case of Severe vulnerabilities.

Physical security

Our servers are hosted in third party data-centers (OVH AND AWS).

Admittance:

For OVH data centers:

• Access to all OVHcloud premises is strictly monitored. Data center boundaries are secured with barbed wire fencing to prevent intrusions or hazards. Video surveillance and motion detection systems are in continuous operation. Physical activity in the data centers and outside the buildings is also monitored and recorded on secure servers. A surveillance team is on site 24/7/365.

  Strict security procedures have been put in place to control and monitor access to the OVHcloud premises. Every staff member receives an RFID name badge, which is also used to restrict their access. Employee access rights are reassessed regularly, according to their remit. To access the premises, employees must hand in their badge for verification before passing through the security doors.

  The data centers have an even higher level of protection, and only authorized personnel can gain entry.

  Source: https://us.ovhcloud.com/about/company/security

For AWS data centers:

• Employee Data Center Access

  AWS provides physical data center access only to approved employees. All employees who need data center access must first apply for access and provide a valid business justification. These requests are granted based on the principle of least privilege, where requests must specify to which layer of the data center the individual needs access, and are time-bound. Requests are reviewed and approved by authorized personnel, and access is revoked after the requested time expires. Once granted admittance, individuals are restricted to areas specified in their permissions.

• Third-Party Data Center Access

  Third-party access is requested by approved AWS employees, who must apply for third-party access and provide a valid business justification. These requests are granted based on the principle of least privilege, where requests must specify to which layer of the data center the individual needs access, and are time-bound. These requests are approved by authorized personnel, and access is revoked after request time expires. Once granted admittance, individuals are restricted to areas specified in their permissions. Anyone granted visitor badge access must present identification when arriving on site and are signed in and escorted by authorized staff.

  Source: https://aws.amazon.com/compliance/data-center/controls/

WorkAdventure Privacy Policy

Product specific policies

WorkAdventure « core application »

The WorkAdventure « core application » is the video-game like application you use daily to speak to your fellow colleagues/friends.

• We do NOT store or view any user video/audio: when users are talking inside « communication bubbles », the stream is directly established peer-to-peer. If possible, it will not go through WorkAdventure servers at all.
• If a peer-to-peer connection cannot be established (because of network limitations for one or both users), the video/audio stream is relayed via a « TURN relay server ». This server only acts as a relay and does not store the stream.
• We do NOT store chat messages shared inside bubbles. These messages are also shared directly on a peer-to-peer connection if possible.
• Meeting rooms are managed by Jitsi, which is a privacy oriented conference solution. The privacy policy of Jitsi applies for meeting rooms.
• We do not require users to provide personal information to use the service. Anyone can create a room without authenticating in the service and invite users in this room. The users will not need to authenticate.
• We provide additional services to users who are authenticated.
• We store anonymous metrics, like the number of users connected to WorkAdventure, the number of users in a given room or the number of chats happening. Those metrics allow us to size the servers correctly to ensure an optimal user experience.

WorkAdventure « administration panel »

The WorkAdventure « administration panel » is the place where you can create / manage rooms, members, …

• In order to access the administrator panel, you need to provide your email, name and organization name.
• Your email is used as a login, to retrieve your password -should you forget it-, and, rarely, to send news about the WorkAdventure service or legal changes. You can opt-out of the newsletter anytime. Your email is not shared with third parties.
• Your organization name is used to customize the URL to your rooms. All URLs for your rooms will start with /@/[organization slug].
• From the administration panel, an administrator can add/manage/upload a list of « members ».
• Members data can contain names, email addresses of members, position, biography… This data is not verified by WorkAdventure. Members email is not used by WorkAdventure and no mail will be sent to the members by us unless they request it (for instance, for resetting a password). It will not be shared with third parties.
• The organization administrator is responsible for the privacy of the members he/she manages. In particular, he/she must ensure the members granted a proper authorization for their data to be hosted on WorkAdventure servers.

Moderation

• The organization administrator can take steps to moderate his/her rooms. This includes banning users, for instance if some users are behaving badly and repeatedly violating a code of conduct.
• Users can be banned:
• By ID (if they are logged)
• By IP: if an administrator decides to ban a user by IP, the IP address of the banned user will be stored indefinitely in our database to enforce this ban.

Collection of information using tracking tools

• We use an analytics solution to analyze user behaviours on our website and in the WorkAdventure « core application ». This analysis is done to understand how WorkAdventure is used and to improve the user experience.
• Analytics data is stored on WorkAdventure servers and is not shared with any third party.
• Personal Data processed: Cookies; Usage Data.
• Place of processing: France

General Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
• Company (referred to as either « the Company », « We », « Us » or « Our » in this Agreement) refers to Workadventu.re SAS, 56 rue de Londres, 75008 PARIS.
• For the purpose of the GDPR, the Company is the Data Controller.
• Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: France.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Personal Data is any information that relates to an identified or identifiable individual.
• For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to WorkAdventure, accessible from https://workadventu.re.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Usage Data

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be « Persistent » or « Session » Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

  Type: Session Cookies

  Administered by: Us

  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Us

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

• Tracking and Performance Cookies

  Type: Persistent Cookies

  Administered by: Third-Parties

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

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Analytics

We do not use third-party Service providers to monitor and analyze the use of our Service.

In particular, we do not use Google Analytics.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

• MailJet

  Their Privacy Policy can be viewed at https://www.mailjet.com/security-privacy/

• Pipedrive

  Their Privacy Policy can be viewed at https://www.pipedrive.com/en/privacy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Stripe

  Their Privacy Policy can be viewed at https://stripe.com/us/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please 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.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

• Category A: Identifiers.

  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.

  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

  Examples: A name, address, telephone number, credit card number, debit card number. Some personal information included in this category may overlap with other categories.

  Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.

  Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

  Collected: No.

• Category D: Commercial information.

  Examples: Records and history of products or services purchased or considered.

  Collected: Yes.

• Category E: Biometric information.

  Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

  Collected: No.

• Category F: Internet or other similar network activity.

  Examples: Interaction with our Service.

  Collected: Yes.

• Category G: Geolocation data.

  Examples: Approximate physical location.

  Collected: No.

• Category H: Sensory data.

  Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

  Collected: No.

• Category I: Professional or employment-related information.

  Examples: Current or past job history or performance evaluations.

  Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

  Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

  Collected: No.

• Category K: Inferences drawn from other personal information.

  Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  Collected: No.

Under CCPA, personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
• Indirectly from You. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for « business purposes » or « commercial purposes » (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the « Use of Your Personal Data » section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, « sell » and « sale » mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal Iinformation, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We do not sell or plan to sell in the future any Personal Information.

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of Consumers We actually know are less than 16 years of age.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
  • The categories of personal information We collected about You
  • The categories of sources for the personal information We collected about You
  • Our business or commercial purpose for collecting or selling that personal information
  • The categories of third parties with whom We share that personal information
  • The specific pieces of personal information We collected about You
  • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
    • The categories of personal information categories sold
    • The categories of personal information categories disclosed
• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

• By email: [email protected]

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the « Last updated » date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: [email protected]