This Privacy Policy outlines our practices and guidelines concerning the gathering, utilization, and sharing of your information when you engage with the Service. It also informs you about your privacy rights and the legal safeguards in place to protect your privacy.

We utilize your personal data to offer and enhance the Service. When you utilize the Service, you signify your consent to the collection and utilization of information as delineated in this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with initial capitalization have meanings defined based on the following conditions. These definitions maintain their meaning whether presented in singular or plural form.

Definitions

For the purposes of this Privacy Policy:

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to Wellbeing, the software program provided by the Company.

• Business, for the purpose of CCPA/CPRA, 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.

• CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Appify Limited.
  For the purpose of the GDPR, the Company is the Data Controller.

• Consumer, for the purpose of the CCPA/CPRA, 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.

• 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 cellphone or a digital tablet.

• GDPR refers to EU General Data Protection Regulation.

• 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/CPRA, 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.

• Service refers to the Application.

• 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.

• 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).

• 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, 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

When utilizing our service, we might request you to furnish us with specific personally identifiable details that can be utilized to get in touch with you or recognize you. This may encompass, but is not not confined to:

• Email address

• Usage Data

Usage Data

Usage Data is automatically gathered during your use of the Service.

This data may encompass details such as your device's Internet Protocol (IP) address, browser type, browser version, the specific pages you visit on our Service, the date and time of your visits, the duration of your visits on those pages, unique device identifiers, and additional diagnostic information.

When you access the Service via a mobile device, we may also automatically collect specific information, including, but not limited to, the type of mobile device you utilize, your mobile device's unique ID, your mobile device's IP address, your mobile operating system, the type of mobile internet browser you use, as well as unique device identifiers and other diagnostic data.

Furthermore, we may collect information that your browser sends when you visit our Service or when you access it through a mobile device.

Information Collected while Using the Application

When using our application and in order to deliver the features it offers, we may gather, with your prior consent:

• Pictures and other information from your Device's camera and photo library

We utilize this data for the purpose of enhancing and tailoring our service to provide its features. This information can be either uploaded to the company's servers and/or a service provider's server or stored locally on your device.

You have the flexibility to enable or disable access to this information at any time via your device's settings.

Use of Your Personal Data

The company might utilize Personal Data for the subsequent purposes:

• To provide and sustain our Service, which includes monitoring service usage.

• For contract performance: To develop, comply with, and execute any contract with us via the Service.

• To communicate with you: This includes using email or other equivalent electronic communication methods, such as push notifications through a mobile application, to provide updates or informative messages related to the Service's functions, products, or contracted services, including security updates when necessary or reasonable.

• To furnish you with news, special offers, and general information regarding other goods, services, and events that we offer, which are similar to those you have previously purchased or inquired about, unless you have opted not to receive such information.

• To manage your requests: Addressing and handling your inquiries and requests.

• For targeted advertising: Utilizing your information to create and display tailored content and advertisements (working with third-party vendors, when applicable) based on your interests and/or location, and assessing their effectiveness.

• For business transactions: Assessing or executing mergers, divestitures, restructurings, reorganizations, dissolutions, or other sales or transfers of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar process, where Personal Data held by us about our Service users is among the assets transferred.

• For other purposes: This may include data analysis, identifying usage trends, and evaluating and enhancing our Service, products, services, and your overall experience.

We may share Your personal information in the following situations:

• In collaboration with Service Providers: We might divulge your personal information to Service Providers for purposes such as monitoring and analyzing the usage of our Service, displaying advertisements to support and maintain our Service, delivering ads on third-party websites after you've visited our Service, facilitating payment processing, and reaching out to you.

• For business transitions: Your personal information may be shared or transferred in connection with, or during negotiations for, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another entity.

• With Affiliates: We may share your information with our affiliates, and in such instances, we will require these affiliates to adhere to this Privacy Policy. Our affiliates encompass our parent company, any subsidiaries, joint venture partners, or other companies under our control or sharing common control with us.

• With business partners: Your information may be shared with our business partners to provide you with specific products, services, or promotional offerings.

• With other users: If you share personal information or interact in public areas with other users, please be aware that such information may be accessible to all users and could be distributed publicly beyond our platform.

• With your consent: We may reveal your personal information for other purposes with your explicit consent.

Retention of Your Personal Data

The company will maintain your Personal Data solely for the duration necessary to fulfill the objectives outlined in this Privacy Policy. We will preserve and utilize your Personal Data to the extent required to adhere to our legal obligations, such as retaining your data to comply with applicable laws, resolve disputes, and enforce our legal agreements and policies.

Additionally, the company will retain Usage Data for internal analysis purposes. Typically, Usage Data is stored for a shorter duration, unless it is utilized to enhance security, improve the functionality of our service, or is legally mandated to be retained for extended periods.

Transfer of Your Personal Data

Your data, including Personal Data, is processed at the Company's operational offices and at other locations where the parties involved in processing are situated. This means that such information may be transmitted to and stored on computers situated outside your state, province, country, or another governmental jurisdiction, where data protection laws may vary from those in your jurisdiction.

Your consent to this Privacy Policy, coupled with the submission of this information, signifies your acceptance of this data transfer. The Company will undertake all reasonably required measures to ensure the secure treatment of your data in accordance with this Privacy Policy. No transfer of your Personal Data will be executed to an organization or country unless sufficient controls, including data security and the protection of your personal information, are in place.

Delete Your Personal Data

You possess the authority to erase or request our assistance in deleting the Personal Data that has been gathered about you. Within our Service, there may be features that empower you to remove particular information about yourself.

At any time, you retain the option to modify, amend, or eliminate your information by accessing the settings section, which enables you to manage your personal details. You also have the option to reach out to us for requests related to accessing, rectifying, or deleting any personal information you have furnished to us.

Please be aware that there may be instances where we are obligated to retain certain information due to legal obligations or lawful justifications.

Disclosure of Your Personal Data

Business Transactions

In the event that the Company partakes in a merger, acquisition, or asset transaction, your Personal Data might be transferred. Rest assured, we will notify you prior to the transfer of your Personal Data, and it will subsequently be governed by a distinct Privacy Policy, if applicable.

Law enforcement

In specific situations, the Company may find itself compelled to reveal your Personal Data as mandated by the law or in response to valid requests from public authorities, such as a court or government agency.

Other legal requirements

The Company may divulge your Personal Data in a sincere belief that such measures are essential to:

• Adhere to a legal requirement.

• Safeguard and uphold the rights or assets of the Company.

• Prevent or investigate potential misconduct associated with the Service.

• Safeguard the personal safety of Service users or the general public.

• Shield against legal liabilities.

Security of Your Personal Data

The security of your Personal Data is a paramount concern for us. However, please be mindful that no method of data transmission over the Internet or electronic storage is entirely impervious to breaches. While we make diligent efforts to employ commercially accepted measures to safeguard your Personal Data, we cannot assure its complete security.

Detailed Information on the Processing of Your Personal Data

The Service Providers we engage with may have access to your Personal Data. These third-party providers collect, store, utilize, process, and transfer data related to your interactions on our Service in accordance with their respective Privacy Policies.

Analytics

We may employ third-party service providers to oversee and assess the utilization of our Service.

• Google Analytics
  Google Analytics is a web analytics service provided by Google, designed to track and report website traffic. Google leverages the data it collects to observe and oversee the utilization of our Service, and this information may be shared with other Google services. Google might utilize the gathered data to tailor and personalize advertisements within its advertising network.
  You have the option to disable specific Google Analytics features by adjusting your mobile device settings, including your device's advertising preferences, or by adhering to the guidelines outlined in Google's Privacy Policy: https://policies.google.com/privacy
  For more comprehensive insights into Google's privacy practices, please refer to the Google Privacy & Terms web page: https://policies.google.com/privacy

• Firebase
  Firebase is an analytics service offered by Google Inc.

You have the choice to deactivate specific Firebase features by adjusting your mobile device settings, including your device's advertising preferences, or by following the guidelines set out in Google's Privacy Policy. https://policies.google.com/privacy
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245
For additional details regarding the kind of data collected by Firebase, kindly refer to the "How Google uses data when you use our partners' sites or apps" webpage: https://policies.google.com/technologies/partner-sites

Advertising

We may use Service Providers to show advertisements to You to help support and maintain Our Service.

• Google AdSense & DoubleClick Cookie As a third-party vendor, Google utilizes cookies to display advertisements on our Service. Google's employment of the DoubleClick cookie empowers both Google and its associates to present ads to our users that are related to their visits on our Service or other websites across the Internet. To abstain from the use of the DoubleClick Cookie for interest-based advertising, you can access the Google Ads Settings webpage. http://www.google.com/ads/preferences/

• AdMob by Google AdMob by Google is provided by Google Inc. You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: https://policies.google.com/technologies/partner-sites or visit the Privacy Policy of Google: https://policies.google.com/privacy

• AppLovin AppLovin is provided by the AppLovin Corporation. If you'd like to opt-out from AppLovin service, please visit the AppLovin Opt-out page: https://www.applovin.com/optout If you'd like to learn more about AppLovin, please visit the Privacy Policy page of AppLovin: https://www.applovin.com/privacy

Payments

In situations where we offer paid products and/or services through the Service, we may employ third-party services for payment processing, such as payment processors.

Please note that we neither retain nor gather your payment card details. Instead, this information is directly shared with our third-party payment processors, whose handling of your personal information is regulated by their respective Privacy Policies. These payment processors adhere to the standards established by PCI-DSS, as overseen by the PCI Security Standards Council, a collaborative initiative involving prominent brands like Visa, Mastercard, American Express, and Discover. The PCI-DSS requirements are instrumental in ensuring the secure management of payment information.

Apple Store In-App Payments Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

Behavioral Remarketing

The company employs remarketing services to display ads to you once you've interacted with or visited our service. We, along with our third-party partners, utilize cookies and other tracking technologies to identify your device and gain insights into your usage of our service. This helps us enhance our service to align with your preferences and provide you with ads that are more tailored to your interests.

These third-party partners gather, store, analyze, and share information about your activities on our service in compliance with their privacy policies. This is done to enable us to:

• Assess and evaluate the flow of visitors and their browsing behavior on our service

• Display promotions for our products and/or services to you on external websites or applications

• Evaluate and analyze the effectiveness of our advertising campaigns

Certain third-party providers may utilize non-cookie technologies that could remain unaffected by browser settings designed to block cookies. Your web browser might not offer the capability to block these technologies. To opt out of the collection and utilization of data for the purpose of receiving interest-based advertising, you can make use of the following third-party tools:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You have the option to disable all personalized advertising by activating privacy features on your mobile device, such as enabling "Limit Ad Tracking" on iOS or opting out of "Ads Personalization" on Android. For detailed instructions, consult the Help system of your mobile device.

We may share certain information, like hashed email addresses (when available) or other online identifiers gathered through our service, with these third-party vendors. This sharing enables our third-party partners to identify and deliver advertisements to you across various devices and web browsers. To learn more about the technologies employed by these third-party vendors and their ability to deliver ads across multiple devices, please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

• Google Ads (AdWords) The Google Ads (AdWords) remarketing service is offered by Google Inc. If you wish to opt out of Google Analytics for Display Advertising and tailor your Google Display Network ads, you can do so by accessing the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

  • Facebook The Facebook remarketing service is provided by Facebook Inc. For comprehensive information about interest-based advertising from Facebook, please visit the following page: https://www.facebook.com/help/516147308587266. If you wish to opt out of Facebook's interest-based ads, you can follow the instructions provided by Facebook here: https://www.facebook.com/help/568137493302217. Facebook follows the Self-Regulatory Principles for Online Behavioral Advertising as outlined by the Digital Advertising Alliance. You also have the option to opt out of Facebook and other participating companies through the Digital Advertising Alliance in the USA at http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada at http://youradchoices.ca/, or the European Interactive Digital Advertising Alliance in Europe at http://www.youronlinechoices.eu/. Additionally, you can manage your opt-out preferences using your mobile device settings. For more details regarding Facebook's privacy practices, please refer to Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have granted your explicit permission for the processing of Personal Data for one or more specified purposes.

• Performance of a contract: Providing Personal Data is essential for fulfilling an agreement with you and/or meeting any pre-contractual obligations associated with it.

• Legal obligations: The processing of Personal Data is required to adhere to a legal obligation to which the Company is bound.

• Vital interests: Processing Personal Data is indispensable for safeguarding your critical interests or those of another individual.

• Public interests: Processing Personal Data is associated with a task carried out in the public interest or as part of the exercise of official authority delegated to the Company.

• Legitimate interests: Processing Personal Data is deemed necessary to serve the legitimate interests pursued by the Company.

In all situations, the Company is more than willing to provide clarification regarding the precise legal foundation that governs the processing, especially concerning whether the furnishing of Personal Data is a mandatory statutory or contractual obligation or a necessity for entering into an agreement.

Your Rights under the GDPR

The Company commits to maintaining the confidentiality of your Personal Data and ensuring that you can assert your rights.

You possess the entitlement, as stipulated in this Privacy Policy and by legal regulations if you are located within the EU, to:

• Request access to your Personal Data: You have the right to inquire about the Personal Data we have pertaining to you. You can typically access, modify, or request the deletion of your Personal Data directly within your account settings. If you encounter difficulties with these actions, please contact us for assistance. This process also allows you to receive a copy of the Personal Data we possess about you.

• Request correction of your Personal Data: You possess the right to rectify any incomplete or inaccurate information we have on record about you.

• Object to the processing of your Personal Data: This right applies when we rely on legitimate interests as the legal basis for processing, and there are specific reasons related to your situation that lead you to object to our processing of your Personal Data. You also have the right to object when we process your Personal Data for direct marketing purposes.

• Request the erasure of your Personal Data: You can ask us to delete or remove your Personal Data when there is no valid reason for us to continue processing it.

• Request the transfer of your Personal Data: We will provide your Personal Data to you or a third party of your choice in a structured, commonly used, machine-readable format. Please note that this right is applicable to automated information for which you initially provided consent for us to use or for situations where we used the information to execute a contract with you.

• Withdraw your consent: You retain the right to revoke your consent for the use of your Personal Data. Be aware that if you withdraw your consent, it may affect our ability to provide you with access to specific functionalities of the service.

Exercising of Your GDPR Data Protection Rights

You can exercise your rights related to access, rectification, deletion, and objection by getting in touch with us. It's important to note that we may request you to verify your identity before addressing such requests. When you make a request, we will make our best effort to respond to you promptly.

You also retain the right to file a complaint with a Data Protection Authority regarding our gathering and utilization of your Personal Data. For further details, particularly if you are situated in the European Economic Area (EEA), please reach out to your local data protection authority within the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This California residents' privacy notice complements the details provided in our Privacy Policy and is specifically relevant to individuals who live in the State of California, including all visitors, users, and others.

Categories of Personal Information Collected

We gather data that can be used to identify, associate with, describe, reference, or be reasonably linked, either directly or indirectly, to a specific Consumer or Device. Here is a breakdown of the categories of personal information that we may collect or have collected from California residents in the past twelve (12) months.

Please be aware that the categories and examples listed below are based on the definitions in the CCPA/CPRA. This does not imply that every example of personal information within a category has been collected by us. It reflects our sincere belief, to the best of our knowledge, that some information from these specific categories may have been collected. For instance, particular categories of personal information would only be gathered if you provided such 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, driver's license number, passport number, or other similar identifiers.
  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. 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 or advertisement.
  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.

• Category L: Sensitive personal information.
  Examples: Account login and password information, geolocation data.
  Collected: Yes.

According to CCPA/CPRA regulations, personal information does not encompass:

• Publicly available information found in government records.

• Deidentified or aggregated consumer data.

• Information exempted from CCPA/CPRA's scope, such as:

  • Health or medical data governed 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 protected by specific privacy laws relevant to certain sectors, including the Fair Credit Reporting Act (FCRA), 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 source the categories of personal information mentioned above from the following categories of origins:

• Directly from You: This includes information acquired from the forms you complete on our Service, preferences you convey or provide through our Service, or data gathered from your transactions on our Service.

• Indirectly from You: We may obtain information by observing your activities on our Service.

• Automatically from You: This pertains to data collected through cookies, which are either set by us or our Service Providers, on your Device as you navigate through our Service.

• From Service Providers: We may also receive information from third-party vendors who help us in monitoring and analyzing the usage of our Service, delivering advertising on our Service, providing targeted advertising to you, handling payment processing, or offering other services that enable us to provide the Service to you.

Use of Personal Information

We may utilize or reveal the personal information we gather for "business purposes" or "commercial purposes," as characterized by the CCPA/CPRA. This may encompass the following instances:

• To operate our Service and delivering our services to you.

• To provide customer support and addressing your inquiries, including investigating and resolving your concerns and enhancing our Service.

• To fulfill the purpose for which you provided the information. For instance, if you share your contact details to inquire about our Service, we will use that personal information to respond to your query. If you provide personal information to make a purchase, we will use it to process your payment and facilitate delivery.

• To comply with law enforcement requests and meeting the requirements of applicable laws, court orders, or government regulations.

• To carry out activities that were disclosed to you when collecting your personal information or as otherwise outlined in the CCPA/CPRA.

• For internal administrative and audit purposes.

• To detect and safeguard against security incidents and preventing malicious, deceptive, fraudulent, or unlawful activities, including, when necessary, taking legal action against those responsible for such activities.

• Other isolated uses.

It's important to note that the examples mentioned above are illustrative and not intended to be exhaustive. For comprehensive details on how we use this information, please refer to the "Use of Your Personal Data" section.

In the event that we decide to collect additional categories of personal information or employ the personal information we have gathered for substantially different, unrelated, or incompatible purposes, we will revise and update this Privacy Policy.

Disclosure of Personal Information

We may have utilized or disclosed, and may continue to utilize or disclose within the previous twelve (12) months, the subsequent categories of personal information for business or commercial reasons:

• 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

It's important to clarify that the aforementioned categories are those defined by the CCPA/CPRA. This doesn't imply that every example within a category has been disclosed, but rather signifies our sincere belief, to the best of our knowledge, that some information from the relevant category may have been or may be disclosed.

When we share personal information for a business or commercial purpose, we establish a contractual agreement that delineates the purpose and mandates the recipient to maintain the confidentiality of that personal information while refraining from using it for any other purpose except for fulfilling the terms of the contract.

Share of Personal Information

We may have shared, and may continue to share within the past twelve (12) months, your personal information falling within the categories mentioned above with the subsequent categories of third parties:

• Service providers

• Payment processors

• Our affiliated entities

• Our business collaborators

• Third-party vendors to whom you or your authorized representatives permit us to disclose your personal information in connection with the products or services we offer to you

Sale of Personal Information

As per the CCPA/CPRA definitions, "sell" and "sale" encompass activities like selling, renting, releasing, disclosing, distributing, providing, transferring, or otherwise communicating a consumer's personal information to a third party in exchange for valuable consideration. This means that we may have received some form of benefit, not necessarily limited to monetary gain, in exchange for sharing personal information.

It's important to note that we do not engage in selling personal information in the conventional sense. However, we do permit service providers to utilize your personal information for the business purposes outlined in our Privacy Policy, which can include activities like advertising, marketing, and analytics. These actions may be regarded as a sale under the CCPA/CPRA.

We may have sold, and may continue to sell, within the previous twelve (12) months, the subsequent categories of personal information:

• 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

It's essential to clarify that the categories mentioned above are those defined by the CCPA/CPRA. This doesn't imply that every example within a category was indeed sold, but rather signifies our sincere belief, to the best of our knowledge, that some information from the relevant category may have been exchanged for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

We make every effort to avoid knowingly gathering personal information from individuals under the age of 16 through our Service. However, it's important to note that certain third-party websites we link to might collect such information. These third-party websites operate under their own terms of use and privacy policies. We strongly advise parents and legal guardians to supervise their children's online activities and instruct them not to share information on other websites without appropriate permission.

The personal information of individuals under 16 that we are aware of is not sold unless we have obtained explicit authorization (referred to as the "right to opt-in") from either the individual aged between 13 and 16 or from the parent or guardian of an individual under 13. Individuals who opt-in to the sale of personal information can opt-out at any time from future sales. To exercise the right to opt-out, You (or Your authorized representative) can contact us to submit a request.

If you suspect that a child under the age of 13 (or 16) has provided us with personal information, please get in touch with us and provide sufficient detail to allow us to remove that information from our records.

Your Rights under the CCPA/CPRA

The CCPA/CPRA 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 receive information about which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

• The right to know/access: Under the CCPA/CPRA, you can request that we provide you with details about our collection, use, sale, disclosure for business purposes, and sharing of personal information. Once we receive and verify your request, we will provide you with:

  • The types of personal information we have gathered regarding you

  • The origins of the personal information we have acquired about you

  • Our objectives for collecting or selling that personal information for business or commercial purposes

  • The categories of third parties with whom we have shared your personal information

  • The precise personal information we have collected about you

  • In the event that we sold or disclosed your personal information for a business purpose, we will provide you with:

    • The kinds of personal information categories that have been sold

    • The types of personal information categories that have been disclosed

• The right to refuse the sale or sharing of Personal Data (opt-out): You have the authority to instruct us not to sell your personal information. To submit an opt-out request, please refer to the "Do Not Sell My Personal Information" section or get in touch with us.

• The right to rectify Personal Data: You hold the right to amend or rectify any inaccurate personal information about you that we have collected. Upon receiving and verifying your request, we will make commercially reasonable efforts to correct your personal information, and we will also instruct our Service Providers to do the same, unless an exception applies.

• The right to restrict the use and disclosure of sensitive Personal Data: You can request to limit the use or disclosure of certain sensitive personal information that we have gathered about you, unless an exception applies. To submit such a request, please consult the "Limit the Use or Disclosure of My Sensitive Personal Information" section or reach out to us.

• The right to erase Personal Data: You have the prerogative to seek the deletion of your Personal Data under specific conditions, subject to certain exceptions. Upon receipt and verification of your request, we will expunge your personal information from our records and direct our Service Providers to do the same, unless an exception applies. We may decline your deletion request if retaining the information is essential for us or our Service Providers to:

  • To complete the transaction for which we initially gathered the personal information, provide a product or service that you have requested, undertake actions reasonably expected within the scope of our ongoing business relationship with you, or otherwise fulfill our contractual obligations to you.

  • To identify and address security incidents, safeguard against malicious, deceptive, fraudulent, or illegal activities, and, if necessary, take legal action against those responsible for such actions.

  • To diagnose and rectify issues with our products that hinder their intended functionality.

  • To uphold freedom of speech, ensure another consumer's right to exercise their free speech, or exercise other rights mandated by law.

  • To adhere to the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • To participate in public or peer-reviewed scientific, historical, or statistical research that serves the public interest and aligns with all relevant ethical and privacy regulations. This applies when the deletion of information may render such research infeasible or significantly impair its accomplishment, provided you have previously given informed consent.

  • To enable strictly internal uses that align with consumer expectations based on your relationship with us.

  • To fulfill legal obligations.

  • To undertake other internal and lawful uses of the information that are compatible with the context in which you provided it.

• The right to be free from discrimination: You possess the right to be shielded from any form of discrimination for exercising your consumer's rights, which includes:

  • Refusing to provide goods or services to you.

  • Imposing varied prices or rates for goods or services, encompassing the utilization of discounts or other advantages, or imposing penalties.

  • Offering goods or services at a different level or quality 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/CPRA Data Protection Rights

For additional details on how to opt out and restrict the use of sensitive information collected, please refer to the "Do Not Sell My Personal Information" section and the "Limit the Use or Disclosure of My Sensitive Personal Information" section.

Furthermore, if you are a California resident and wish to exercise any of your rights under the CCPA/CPRA, you can reach out to us at:

• By email: feedback@appifylimited.com

• By visiting this page on our website: www.appifylimited.com

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 reasonably 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 usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As per the CCPA/CPRA definitions, "sell" and "sale" encompass various actions, including selling, renting, disclosing, or transferring a Consumer's personal information by the Business to a third party in exchange for valuable consideration. This consideration might not only be monetary but could include other benefits.

We don't engage in the traditional understanding of selling personal information. However, we do permit Service Providers to utilize Your personal information for the business purposes outlined in Our Privacy Policy. These purposes encompass activities such as advertising, marketing, and analytics, which might be considered a sale under CCPA/CPRA.

You retain the right to opt-out of the sale of Your personal information. Upon receiving and verifying a consumer request from You, we will cease the sale of Your personal information. To exercise Your right to opt-out, please reach out to Us.

Our partnered Service Providers, such as analytics or advertising partners, may use technology on the Service that falls within the definition of selling personal information as per CCPA/CPRA law. Should you wish to opt out of the utilization of Your personal information for interest-based advertising purposes and these potential sales under CCPA/CPRA law, you can do so by following the instructions below.

Kindly note that any opt-out pertains to the specific browser You use. It might be necessary to opt out on each browser You utilize.

Website

If available, click on the "Privacy Preferences," "Update Privacy Preferences," or "Do Not Sell My Personal Information" options provided on the Service to review and manage Your privacy preferences, including opting out of cookies and other technologies that We might employ. It's important to remember that You'll need to opt out on each browser used to access the Service.

Furthermore, You have the option to opt out of receiving personalized ads served by our Service Providers by following the instructions detailed on the Service.

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Opting out will set a unique cookie on Your computer, specific to the browser You used for the opt-out. Should You switch browsers or clear the cookies saved by Your browser, You'll need to opt out once more.

Mobile Devices

Your mobile device might provide You with the option to refuse the utilization of data regarding the applications You use to deliver personalized advertisements based on Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If you reside in California, You possess the right to restrict the utilization and disclosure of Your sensitive personal information to only that which is essential for carrying out the services or providing the goods that an average consumer would reasonably expect when requesting such services or goods.

We gather, use, and disclose sensitive personal information in manners essential to deliver the Service. For further details on how Your personal information is utilized, please refer to the "Use of Your Personal Data" section or get in touch with us.

Children's Privacy

Our Service is not intended for individuals under the age of 13. We do not intentionally gather personally identifiable information from anyone under 13 years old. If You are a parent or guardian and become aware that Your child has provided Us with Personal Data, please contact Us. Should We discover that Personal Data has been collected from an individual under the age of 13 without verified parental consent, We take steps to delete that information from Our servers.

In situations where we need to rely on consent as a lawful basis for processing Your information, and if Your country mandates parental consent, we may require consent from Your parent before collecting and using that information.

Links to Other Websites

Our Service may include links to websites not operated by Us. Clicking on a third-party link will redirect You to that third party's site. We highly recommend reviewing the Privacy Policy of each site You visit.

We lack control over and do not take responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

Periodically, we may revise Our Privacy Policy. Any alterations will be communicated by posting the updated Privacy Policy on this page.

We will notify You in advance of these changes via email and/or a noticeable announcement on Our Service before the modifications take effect. Additionally, we'll update the "Last updated" date at the top of this Privacy Policy.

It is recommended that You periodically review this Privacy Policy for any modifications. Changes to this Privacy Policy take effect when posted on this page.

Contact Us

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

• By email: feedback@appifylimited.com

• By visiting this page on our website: www.appifylimited.com