This Privacy Policy outlines Our guidelines and practices concerning the gathering, utilization, and disclosure of Your information while utilizing the Service, and informs You about Your privacy rights and legal protections.

We utilize Your Personal data to enhance and deliver the Service. By utilizing the Service, You consent to the collection and utilization of information in compliance 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 remain 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 Health Planner, 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 Goldwright Media 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

During Your use of Our Service, We may request that You furnish certain personally identifiable information which can be used to communicate with or recognize You. This personally identifiable information may encompass, but is not confined to:

• Email address

• Usage Data

Usage Data

Usage Data is automatically collected during the use of the Service. This data may encompass details such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the specific pages of our Service that You visit, the date and time of Your visit, the duration spent on those pages, unique device identifiers, and other diagnostic data.

If You access the Service through a mobile device, certain information may be gathered automatically, including, but not limited to, the mobile device type You utilize, Your mobile device's unique ID, Your mobile device's IP address, Your mobile operating system, the variety of mobile Internet browser You employ, unique device identifiers, and other diagnostic data.

Additionally, we may receive information that Your browser dispatches whenever You visit our Service, whether through a standard browser or a mobile device.

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 utilize this data to deliver features within Our Service and enhance and tailor Our Service according to user preferences. The information may either be uploaded to the Company's servers and/or a Service Provider's server, or it might be stored solely on Your device.

You have the option to activate or deactivate 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 uphold Your Personal Data solely for the duration necessary to fulfill the objectives outlined in this Privacy Policy. We will maintain and utilize Your Personal Data to the extent obligatory to adhere to legal requirements (for instance, if we must retain Your data to conform to relevant laws), resolve disputes, and enforce our legal agreements and policies.

Additionally, the Company will preserve Usage Data for internal analytical purposes. Usage Data is typically retained for a shorter duration, except when this data contributes to enhancing security or improving the functionality of Our Service, or when legal obligations necessitate the prolonged retention of this data.

Transfer of Your Personal Data

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

Your consent to this Privacy Policy, followed by Your provision of such information, signifies Your agreement to this transfer.

The Company will take all reasonably necessary measures to ensure that Your data is handled securely and in accordance with this Privacy Policy. No transfer of Your Personal Data will occur to any organization or country unless adequate controls are in place, including the security of Your data and other personal information.

Delete Your Personal Data

You possess the right to request the deletion of the Personal Data collected about You or seek assistance from Us in this process.

Our Service may offer You the option to delete specific information pertaining to You directly within the Service.

At any time, You have the ability to update, modify, or delete Your information by visiting the settings section, which allows You to manage Your personal information. Additionally, You can reach out to Us to request access to, correct, or erase any personal information that You have shared with Us.

It's important to note, however, that in instances 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

In the event of the Company's engagement 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 distinct Privacy Policy.

Law enforcement

In specific situations, the Company might necessitate disclosing Your Personal Data as mandated by law or in response to valid requests from public authorities (e.g., 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

The safeguarding of Your Personal Data is a priority for Us. However, it's important to note that no method of transmission over the Internet or electronic storage can be guaranteed to be 100% secure. Although We make every effort to utilize commercially acceptable means to secure Your Personal Data, We cannot assure its absolute 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 service providers collect, store, use, process, and transmit information regarding Your activities on Our Service in alignment with their respective Privacy Policies.

Analytics

We might engage third-party Service providers to oversee and assess the utilization of our Service.

• Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and presents reports on website traffic. Google employs the data gathered to track and oversee the usage of our Service. This data 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, utilizes cookies to present ads on our Service. The use of the DoubleClick cookie by Google and its partners allows them to deliver 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 offer paid products and/or services through the Service, utilizing third-party services for payment processing (e.g., payment processors).

We will not retain or gather your payment card details. This information is directly provided to our third-party payment processors, and their use of your personal information is governed by their Privacy Policy. These processors comply with PCI-DSS standards managed 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 employs remarketing services to display ads to you after you've accessed or visited our Service. We and our third-party vendors utilize cookies and non-cookie technologies to recognize your device, comprehend your Service usage, and enhance our Service based on your interests. This allows us to provide you with ads that are more likely to capture your interest.

The information regarding your activity on our Service collected, stored, used, processed, and transferred by these third-party vendors follows their Privacy Policies. This information is utilized to enable us 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 employ non-cookie technologies that are not affected by browser settings blocking cookies. Your browser might not enable you to block such technologies. You can utilize the following third-party tools to reject the collection and utilization of information for the purpose of delivering interest-based advertising:

• 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 opt-out of personalized advertising by activating privacy features on your mobile device, like Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). Consult your mobile device Help system for guidance.

We may share information, including hashed email addresses (if available) or other online identifiers gathered on our Service, with these third-party vendors. This enables them to identify and present you with ads on various devices and browsers. To learn more about the technologies and cross-device capabilities of these vendors, please refer to each vendor's Privacy Policy.

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/gaoptout- for 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 handle 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 cases, the Company is more than willing to provide clarification on the specific legal basis that applies 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. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also possess the right to object when we process your personal data for direct marketing purposes.

Exercising of Your GDPR Data Protection Rights

To assert Your rights of access, rectification, erasure, and objection, feel free to reach out to Us. Please be aware that we may request verification of Your identity before addressing such requests. We strive to respond to Your inquiries promptly upon receiving them.

Additionally, You possess the right to file a complaint with a Data Protection Authority regarding Our acquisition and utilization of Your Personal Data. For further details, especially if You are in the European Economic Area (EEA), we recommend contacting Your local data protection authority within the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This section of the privacy notice is specific to California residents and complements the details outlined in Our Privacy Policy. It pertains exclusively to all visitors, users, and other individuals residing in the State of California.

Categories of Personal Information Collected

We gather information that can be linked, either directly or indirectly, to a specific Consumer or Device. The ensuing catalog comprises categories of personal information that we might collect or may have gathered from California residents within the past twelve (12) months.

Please be aware that the categories and instances listed below adhere to the definitions outlined in the CCPA/CPRA. This does not imply that every example of personal information within a category has been collected by Us. It signifies our genuine belief, to the best of Our awareness, that some information within the relevant category could potentially have been collected. For instance, 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: 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: 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: 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 J: 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 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 encompasses information obtained from third-party vendors we use to monitor and analyze the use of our Service, provide advertising, deliver targeted advertising, process payments, or offer other services to You.

Use of Personal Information

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

• To operate our Service and provide You with Our Service.

• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.

• To fulfill or 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 bear in mind that the categories specified above align with the definitions provided by the CCPA/CPRA. This does not imply that every instance within a category of personal information was indeed disclosed. It signifies our genuine belief, to the best of our knowledge, that certain information within the relevant category could potentially have been disclosed.

Upon disclosing personal information for a business or commercial purpose, we establish a contract delineating the purpose and mandating the recipient to maintain the confidentiality of that personal information. Additionally, they are obliged not to utilize it for any purpose aside from 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

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

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 outlined in our Privacy Policy, including activities such as advertising, marketing, and analytics. These activities may be considered a sale under CCPA/CPRA.

Sale of Personal Information of Minors Under 16 Years of Age

We do not intentionally collect personal information from minors under the age of 16 via our Service, though certain third-party websites we link to might 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.

We do not sell the personal information of Consumers we know are under 16 years of age unless we have received explicit authorization (the "right to opt-in") 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 have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient 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 have the right to 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 have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.

• The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.

• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

  • Denying goods or services to You

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

  • Providing a different level or quality of goods or services to You

  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

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

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

• By email: feedback@goldwrightmedia.com

• By visiting this page on our website: www.goldwrightmedia.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 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, "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, select "Privacy Preferences," "Update Privacy Preferences," or "Do Not Sell My Personal Information" buttons on the Service to review Your privacy preferences and opt out of cookies and other technologies that we may use. Please note that You will need to opt out from each browser You use to access the Service.

Moreover, You can choose not to receive personalized ads served by our Service Providers by following 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

If you are a California resident, you have the right to restrict the use and disclosure of your sensitive personal information to that which is required to perform the services or provide the goods reasonably anticipated by an average consumer who requests such services or goods.

We collect, use, and disclose sensitive personal information only as necessary to provide the Service. For further details regarding how we utilize your personal information, please refer to the "Use of Your Personal Data" section or reach out to us for more information.

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 the age of 13. If you are a parent or guardian and are aware that your child has provided us with Personal Data, please contact us. If we discover that we have unintentionally collected Personal Data from an individual under the age of 13 without parental consent verification, we will take steps to remove that information from our servers.

In instances where we need to rely on consent as a legal basis for processing your information, and your country mandates parental consent, we may request consent from your parent before collecting and using that information.

Links to Other Websites

Our Service may include links to websites operated by third parties. If you click on a third-party link, you will be directed to that third party's site. We highly recommend that you review the Privacy Policy of each site you visit.

We do not have control over, and take 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 also notify You via email or through a prominent notice on Our Service prior to the changes taking effect, and update the "Last updated" date at the top of this Privacy Policy.

We recommend that You review this Privacy Policy periodically for any modifications. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

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

• By email: feedback@goldwrightmedia.com

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