This Privacy Policy details our principles and procedures regarding the collection, use, and disclosure of your information when using the Service. It also informs you about your privacy rights and legal protections.

We use your personal data to improve and provide the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The capitalized terms within this document hold specific meanings, as defined under the following circumstances. These defined interpretations keep consistent whether the terms are 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 Harmoni, 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 Heypex Digital 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

Throughout your use of our service, we may ask you to provide certain personally identifiable information, which can be used to communicate with or identify you. This personally identifiable information may include, but is not limited to:

• Email address

• Usage Data

Usage Data

Usage data is automatically collected as you interact with the service. This information includes your device's Internet Protocol address (e.g., IP address), browser type, browser version, specific pages visited on our service, date and time of your visit, duration of your stay on those pages, unique device identifiers, and other diagnostic data.

If you access the service via a mobile device, certain details are gathered automatically, such as the type of mobile device you use, its unique ID, IP address, operating system, mobile Internet browser type, unique device identifiers, and additional diagnostic data.

Moreover, information sent by your browser during visits, whether from a standard browser or a mobile device, may also be received by us.

Information Collected while Using the Application

While using Our Application and aiming to offer specific features, We may gather the following information with Your explicit consent:

• Images and other details from your Device's camera and photo library

We use this data to provide features within our service and improve and customize it based on user preferences. This information may be uploaded to the company's servers and/or a service provider's server, or it may be stored solely on your device.

You have the option to enable or disable access to this information at any time through your device settings.

Use of Your Personal Data

The Company may utilize Personal Data for the subsequent objectives:

• Service Maintenance: To deliver and uphold our Service, including monitoring Service usage.

• For the performance of a contract: The development, compliance and undertaking of the agreement for the acquisition of goods, articles or services." You have accquired or of any other contract with Us through the Service.

• To contact You: To contact You by email, 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 updates, exclusive deals, and general details regarding other products, services, and events similar to those you've already bought or inquired about, unless you've chosen not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• To deliver targeted advertising to You: We might utilize your information to create and showcase content and advertisements personalized to your interests and/or location. We may also collaborate with third-party vendors for this purpose and assess the effectiveness of such content.

• 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 might utilize your information for various purposes, including data analysis, recognizing usage patterns, assessing the success of our promotional efforts, and enhancing our Service, products, services, marketing, and your overall experience.

We may divulge Your personal information in the following scenarios:

• With Service Providers: We might disclose your personal information to service providers for purposes such as monitoring and analyzing service usage, displaying ads to support and sustain our service, promoting on third-party websites after you've visited our service, facilitating payment processing, and contacting you.

• With Affiliates: We might share Your information with Our affiliates. In such cases, we will enforce compliance with this Privacy Policy by these affiliates. Affiliates encompass Our parent company and any subsidiaries, joint venture partners, or companies under common control with Us.

• With business partners: We might disclose your information to our business partners to provide you with specific products, services, or promotions.

• With Other Users: When You share personal information or engage in public interactions with other users, this information may be viewable by all users and could be distributed publicly.

• With Your Consent: We may disclose Your personal information for any other purpose if We have obtained Your consent.

Retention of Your Personal Data

The company will retain your personal data only for the time necessary to achieve the purposes outlined in this privacy policy. We will keep and use your personal data to the extent required to comply with legal requirements (for example, if we need to retain 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 analytical purposes. Usage data is typically kept for a shorter duration, unless this data contributes to enhancing security or improving the functionality of our service, or when legal obligations require the extended retention of this data.

Transfer of Your Personal Data

Your data, including personal information, undergoes processing at our operational offices and other locations where involved parties are situated. This may involve transmission and storage on computers located outside your state, province, country, or any other jurisdiction, where data protection laws may differ.

Your acceptance of this Privacy Policy and provision of information implies your consent to such transfers. The company is committed to ensuring secure and compliant handling of your data, implementing necessary measures.

No transfer of your personal data will occur to any organization or country without sufficient controls, including data security and privacy safeguards.

Delete Your Personal Data

You have the right to request the deletion of your Personal Data collected by us or seek assistance in this process.

Our Service may provide you with the option to delete specific information related to you directly within the Service.

You can update, modify, or delete your information at any time by visiting the settings section, which allows you to manage your personal information. Additionally, you can contact us to request access to, correction of, or deletion of any personal information you have shared with us.

It's important to note, however, that in cases where we are legally obligated or have a lawful basis to do so, we may need to retain certain information.

Disclosure of Your Personal Data

Business Transactions

If the Company engages in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will notify you before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

In certain circumstances, the Company may need to disclose your Personal Data as required by law or in response to valid requests from public authorities, such as a court or government agency.

Other legal requirements

The Company may reveal Your Personal Data with a genuine belief that such action is indispensable to:

• Abide by a legal obligation

• Safeguard and uphold the rights or property of the Company

• Prevent or probe potential misconduct associated with the Service

• Ensure the personal safety of Service Users or the public

• Mitigate legal liability

Security of Your Personal Data

Ensuring the security of your Personal Data is a top priority for us. However, it's essential to recognize that no method of transmission over the Internet or electronic storage can be guaranteed to be 100% secure. While we employ commercially acceptable means to secure your Personal Data, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The third-party service providers we work with may have access to your Personal Data. These providers collect, store, use, process, and transmit information regarding your activities on our Service in accordance with their respective Privacy Policies.

Analytics

We may enlist third-party service providers to manage and evaluate the use of our Service.

Google Analytics: Google Analytics is a web analytics service provided by Google, which tracks and generates reports on website traffic. Google utilizes the collected data to monitor and analyze the use of our Service, and this information is also shared with other Google services. You have the option to opt-out of specific Google Analytics features via your mobile device settings, or by following the directions outlined in Google's Privacy Policy: https://policies.google.com/privacy

• For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Firebase

Firebase: Firebase is an analytics service provided by Google Inc.

You can choose to opt-out of specific Firebase features via your mobile device settings, or by following the instructions provided by Google in their 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 more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage: https://policies.google.com/technologies/partner-sites

Advertising

We might employ Service Providers to display ads to you, aiding in the support and maintenance of Our Service.

• Google AdSense & DoubleClick Cookie

Google, as a third-party vendor, uses cookies for displaying ads on our Service. The DoubleClick cookie, employed by Google and its partners, enables them to show ads to our users based on their visits to our Service or other websites on the Internet.

You have the option to refuse the use of the DoubleClick Cookie for interest-based advertising by accessing the Google Ads Settings web page: http://www.google.com/ads/preferences/

• AdMob by Google

AdMob by Google is offered by Google Inc.

You can choose not to use the AdMob by Google service by following the instructions provided by Google: https://support.google.com/ads/answer/2662922?hl=en

For additional details on how Google utilizes the gathered information, please refer to 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 offered by the AppLovin Corporation.

If you wish to decline the AppLovin service, please go to the AppLovin Opt-out page: https://www.applovin.com/optout

If you want to get more information about AppLovin, please check out the Privacy Policy page on AppLovin's website: https://www.applovin.com/privacy

Payments

We may provide paid products and/or services through the Service, using third-party services for payment processing (e.g., payment processors).

We do not store or collect your payment card details. Your payment information is directly submitted to our third-party payment processors, and their utilization of your personal information is subject to their Privacy Policy. These processors adhere to PCI-DSS standards set by the PCI Security Standards Council, ensuring secure handling of payment information.

Apple Store In-App Payments

You can review their Privacy Policy at: https://www.apple.com/legal/privacy/en-ww/

Behavioral Remarketing

The Company utilizes remarketing services to show you ads after you've visited our Service. We and our third-party vendors use cookies and non-cookie technologies to identify your device, understand your Service usage, and improve our Service based on your interests. This enables us to deliver ads that are more likely to align with your preferences.

Information about your activity on our Service, collected, stored, used, processed, and transmitted by these third-party vendors, adheres to their Privacy Policies. This information is employed to:

• Assess and analyze traffic and browsing patterns on our Service

• Display ads for our products and/or services on third-party websites or apps

• Evaluate and analyze the effectiveness of our advertising campaigns

Certain third-party vendors may utilize non-cookie technologies unaffected by browser settings blocking cookies. Your browser settings may not block such technologies. To opt out of information collection for interest-based advertising, you can use 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 can choose to disable personalized advertising by activating privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). Refer to your mobile device's Help system for specific instructions.

We may share information, including hashed email addresses (if available) or other online identifiers collected on our Service, with these third-party vendors. This allows them to recognize you and display ads across various devices and browsers. For more detailed information about the technologies and cross-device capabilities of these vendors, please review the Privacy Policy of each respective vendor.

The third-party vendors we utilize are:

• Google Ads (AdWords)

The Google Ads (AdWords) remarketing service is furnished by Google Inc.

To opt-out of Google Analytics for Display Advertising and customize Google Display Network ads, visit the Google Ads Settings page:http://www.google.com/settings/ads

• Google suggests installing the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptoutfor your web browser. This add-on enables visitors to prevent the collection and use of their data by Google Analytics.

For further details on Google's privacy practices, please refer to the Google Privacy & Terms web page: https://policies.google.com/privacy

• Facebook

The Facebook remarketing service is provided by Facebook Inc.

Learn more about interest-based advertising from Facebook: https://www.facebook.com/help/516147308587266

To opt-out of Facebook's interest-based ads, follow these instructions: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising by the Digital Advertising Alliance. You can also opt-out via the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/, or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/. Mobile device settings also allow opt-out.

For further information on Facebook's privacy practices, refer to Facebook's Data Policy: https://www.facebook.com/privacy/explanation

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may deal with Personal Data based on the following circumstances:

• Consent: You have provided Your consent for the processing of Personal Data for one or more specific purposes.

• Performance of a Contract: The disclosure of Personal Data is essential for the performance of an agreement with You and/or for any pre-contractual obligations.

• Legal Obligations: Processing Personal Data is imperative to comply with a legal obligation to which the Company is subject.

• Vital Interests: Processing Personal Data is essential to safeguard Your vital interests or those of another natural person.

• Public Interests: Processing Personal Data is linked to a task 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 all instances, the Company is ready to offer clarification on the specific legal basis applicable to the processing. This includes confirming whether the provision of Personal Data is a statutory or contractual requirement or a necessity to enter into a contract.

Your Rights under the GDPR

The Company is committed to upholding the confidentiality of Your Personal Data and ensuring that You can exercise Your rights.

As per this Privacy Policy, and in compliance with EU law, You have the following rights:

• Request access to Your Personal Data. The right to access, update, or delete the information we have on you is available to you. Whenever feasible, 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 for assistance. This also allows 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 have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data. This right applies when we rely on legitimate interests as the legal basis for processing, and there is something about your specific situation that prompts you to object to our processing of your Personal Data on this ground. You also have the right to object when we process your personal data for direct marketing purposes.

Exercising of Your GDPR Data Protection Rights

To exercise your rights of access, rectification, erasure, and objection, please contact us. Please note that we may request verification of your identity before addressing such requests. We aim to respond promptly to your inquiries upon receiving them.

Moreover, you have the right to lodge a complaint with a Data Protection Authority concerning our collection and use of your Personal Data. For more information, particularly if you are in the European Economic Area (EEA), we suggest reaching out to your local data protection authority within the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This section of the privacy notice is dedicated to residents of California and supplements the information provided in Our Privacy Policy. It applies solely to all visitors, users, and other individuals residing in the State of California.

Categories of Personal Information Collected

We collect information that may be associated, either directly or indirectly, with a particular Consumer or Device. The following list includes categories of personal information that we may collect or have collected from California residents in the last twelve (12) months.

Please note that the categories and examples provided below align with the definitions set forth in the CCPA/CPRA. This does not imply that every instance of personal information within a category has been collected by us. It signifies our genuine belief, to the best of our knowledge, that some information within the relevant category could potentially have been collected. For example, specific categories of personal information would only be acquired if you directly provided such information 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: Information that directly or indirectly identifies a person, including but not limited to 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 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: Documentation and background of items or services bought or under consideration.

• Collected: Yes.

Category E: Internet or other similar network activity.

Examples: Interaction with our Service.

• Collected: Yes.

Category F: Geolocation data.

Examples: Approximate physical location.

• Collected: No.

Category G: Sensory data.

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

• Collected: No.

Category H: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

• Collected: No.

Category I: 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: Records pertaining to a student's education directly managed by an educational institution or a party acting on its behalf. This includes grades, transcripts, class lists, student schedules, identification codes, financial information, or disciplinary records.

• Collected: No.

Category J: Inferences drawn from other personal information.

Examples: A profile that reflects an individual's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• Collected: No.

Category K: Sensitive personal information.

Examples: Account login and password information, geolocation data.

• Collected: Yes.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA/CPRA'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 acquire the categories of personal information mentioned above from the following categories of sources:

• Directly from You. This includes information from forms you complete on our Service, preferences you express or provide through our Service, or purchases you make on our Service.

• Indirectly from You. This involves information obtained by observing your activity on our Service.

• Automatically from You. For instance, through cookies set on your device by us or our Service Providers as you navigate through our Service.

• From Service Providers. This includes data acquired from third-party vendors we employ to monitor and analyze the usage of our Service, provide advertising, deliver targeted advertising, process payments, or furnish other services to you.

Use of Personal Information

We may utilize or reveal the personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may encompass the following instances:

• 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 satisfy the purpose for which You provided the information. For instance, if You share your contact information to inquire 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.

Disclosure of Personal Information

We might have utilized or shared, and within the past twelve (12) months potentially utilized or shared, the subsequent 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 outlined categories adhere to the definitions provided by the CCPA/CPRA. This does not confirm the disclosure of every instance within a category of personal information. It reflects our sincere belief, to the best of our knowledge, that certain information within the relevant category could potentially have been disclosed.

When disclosing personal information for a business or commercial purpose, we establish a contract defining the purpose and requiring the recipient to maintain the confidentiality of that personal information. Furthermore, they are obligated not to use it for any purpose other than fulfilling the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers

• Payment processing services

Sale of Personal Information

In compliance with the CCPA/CPRA, "sell" and "sale" encompass various activities such as selling, renting, releasing, disclosing, disseminating, making available, transferring, or communicating a Consumer's personal information to a third party for valuable consideration. This indicates that we may have received some form of benefit in return for sharing personal information, although not necessarily a monetary benefit.

It's crucial to clarify that we do not engage in the traditional sale of personal information. However, we do permit Service Providers to use your personal information for the business purposes outlined in our Privacy Policy, including activities like advertising, marketing, and analytics. These activities may be considered a sale under the CCPA/CPRA.

Sale of Personal Information of Minors Under 16 Years of Age

We do not intentionally gather personal information from minors under the age of 16 through our Service, although certain third-party websites we link to may do so. These third-party websites operate under their own terms of use and privacy policies. We strongly encourage parents and legal guardians to supervise their children's online activities and educate them about not providing information on other websites without proper permission.

The personal information of consumers under 16 years of age is not intentionally sold unless explicit authorization (the "right to opt-in") is obtained from the consumer aged between 13 and 16, or from the parent or guardian of a consumer under 13 years of age. Consumers who authorize the sale of personal information have the option to opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) can submit a request to us by reaching out.

If you believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient details to facilitate the deletion of that information.

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 be notified 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 CCPA/CPRA, 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 purposes 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 say no to the sale or sharing of Personal Data (opt-out). You can direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Us.

• The right to correct Personal Data.You possess the right to correct or rectify any inaccurate personal information about you that we have collected. Upon receiving and confirming your request, we will make commercially reasonable efforts to correct your personal information (and direct our service providers to do the same), unless an exception applies.

• The right to limit use and disclosure of sensitive Personal Data. You retain the right to request limitations on the use or disclosure of specific sensitive personal information we have collected about you, unless an exception applies. To submit such a request, please refer to the "Limit the Use or Disclosure of My Sensitive Personal Information" section or get in touch with us.

• The right to delete Personal Data. You possess the right to request the deletion of your Personal Data under specific circumstances, subject to certain exceptions. Upon receipt and confirmation of your request, we will proceed to delete (and instruct our Service Providers to delete) your personal information from our records, unless an exception applies. We reserve the right to deny your deletion request if retaining the information is deemed 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/CPRA Data Protection Rights

For detailed guidance on opting out and limiting the use of sensitive personal 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.

If you are a California resident and desire to exercise your rights pursuant to the CCPA/CPRA, you can reach out to us at:

• By email: feedback@heypexdigital.com

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

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf can 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 to allow 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.

• Confirm that the personal information relates to you.

We will furnish the necessary information at no cost within 45 days of receiving your verifiable request. In circumstances where an extension is reasonably necessary, we may extend the time period by an additional 45 days, with prior notice. The information disclosed will pertain solely to the 12-month period preceding the receipt of the verifiable request.

Regarding data portability requests, we will choose a format for presenting your personal information that is easily usable and facilitates the transmission of information from one entity to another without impediment.

Do Not Sell My Personal Information

As per the CCPA/CPRA, "sell" and "sale" encompass selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer's personal information by the business to a third party for valuable consideration. This implies that we may have received some form of benefit, not necessarily monetary, in return for sharing personal information.

We do not engage in the sale of personal information as commonly understood. However, we permit Service Providers to utilize your personal information for the business purposes described in Our Privacy Policy, which may include activities such as advertising, marketing, and analytics. These activities may be considered a sale under CCPA/CPRA.

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

The Service Providers we collaborate with, such as our analytics or advertising partners, may employ technology on the Service that falls under the CCPA/CPRA's definition of selling personal information. If you want to opt out of the use of your personal information for interest-based advertising purposes and these potential sales under CCPA/CPRA, you can do so by following the instructions below.

Please be aware that any opt-out is specific to the browser you use, and you may need to opt out on every browser you use.

Website

If applicable, navigate to the "Privacy Preferences," "Update Privacy Preferences," or "Do Not Sell My Personal Information" buttons on the Service to review Your privacy settings and opt out of cookies and other technologies we may use. Remember to perform this action for each browser You use to access the Service.

Additionally, to avoid receiving personalized ads from our Service Providers, follow the instructions provided 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

The opt-out process will set a unique cookie on Your computer specific to the browser You use for opting out. If You switch browsers or delete cookies from Your browser, You will need to opt out again.

Mobile Devices

Your mobile device may provide options to opt out of using information about the apps You use for targeted ads:

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

• "Limit Ad Tracking" on iOS devices

You can also prevent the collection of location information from Your mobile device by adjusting preferences.

Limit the Use or Disclosure of My Sensitive Personal Information

As a California resident, you hold the right to limit the use and disclosure of your sensitive personal information to what is reasonably expected for the performance of services or provision of goods as anticipated by an average consumer seeking such services or goods.

We exclusively collect, use, and disclose sensitive personal information as required for the provision of the Service. For additional insights into how we handle your personal information, kindly consult the "Use of Your Personal Data" section or contact us for further clarification.

Children's Privacy

Our Service is not designed for individuals under the age of 13, and we do not deliberately collect personally identifiable information from anyone in this age group. If you are a parent or guardian and become aware that your child has provided us with Personal Data, please get in touch with us. Should we learn that we have inadvertently obtained Personal Data from an individual under the age of 13 without parental consent verification, we will take prompt measures to remove that information from our servers.

In cases where consent is required as a legal basis for processing your information, and your country mandates parental consent, we may seek approval from your parent before collecting and using that information.

Links to Other Websites

Our Service may contain links to websites operated by third parties. Clicking on a third-party link will redirect you to that specific site. We strongly advise reviewing the Privacy Policy of each site you visit.

We do not have 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 periodically update Our Privacy Policy. We will inform You of any changes by posting the revised Privacy Policy on this page.

We may additionally inform You through email or provide a conspicuous notice on Our Service before the changes become effective, and we will update the "Last updated" date at the top of this Privacy Policy.

We suggest reviewing this Privacy Policy regularly for any revisions. Modifications to this Privacy Policy become effective upon being posted on this page.

Contact Us

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

• By email: feedback@heypexdigital.com

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