ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
Residents of the States of California and the Commonwealth of Virginia: these additional U.S. State Privacy Disclosures supplement the information contained in the Privacy Policy by providing additional information about Organic Apps Inc.’s (“Organic Apps”) personal data processing practices relating to individual residents of these states. Unless otherwise expressly stated, all terms defined in the Organic Apps Privacy Policy retain the same meaning in these State Privacy Disclosures.
A. CALIFORNIA CONSUMERS
If you are a consumer residing in the state of California, as defined in the California Consumer Privacy Act (CCPA), as updated by the California Privacy Rights Act (CPRA) and subsequent regulations, this section supplements and supersedes the Privacy Policy.
For the purposes of this section “personal information” (and “sensitive personal information”) have the meaning defined in the California Consumer Privacy Act (CCPA).
Categories of Personal Information
We collect the following categories of personal information about you: identifiers, commercial information, biometric information, internet or other electronic network activity information, geolocation data, audio, electronic, visual, or similar information and inferences drawn from other personal information. We collect the following categories of sensitive personal information: payment data, precise location data, username and password.
We will not collect additional categories of personal information without notifying you. You have the right to request that we limit the use or disclosure of your sensitive personal information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. We can also use your sensitive personal information to perform specific purposes set forth by applicable law (e.g., service security and integrity; service safety and quality verification).
To exercise your right to limit the use or disclosure of your sensitive personal information please notify our Data Protection Officer by e-mail [email protected]. We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request. If you have limited the use or disclosure of your sensitive personal information, we may ask you to opt back in after twelve (12) months.
Purposes
We may use your personal information to allow the operational functioning of the Website, Apps and Services. In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected.
We may also use your personal information for other reasons such as for commercial purposes, as well as for complying with the law and defending our rights before the competent authorities, as further described in the Privacy Policy.
Retention
We will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
Sources of Information
We collect personal information, either directly or indirectly, from you when you use the Website, Apps, and/or Services. You also provide personal information indirectly when you navigate the Website and/or Apps as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties working with us in connection with the Services or with the functioning of the Website and/or Apps. Please see the Privacy Policy for more details.
Use of Information
We disclose your personal information with the third parties listed in the Privacy Policy. These third parties are grouped and categorized in accordance with the different purposes of processing. As used in this section, “third party” means a person who is not a service provider or a contractor, as defined by the CCPA.
Sale of Information
As used in this section, “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
As used in this section, “sharing” means any “sharing, 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 cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
We sell or share your personal information with the third parties listed in the Privacy Policy. Please note that the exchange of personal information with a service provider pursuant to a written contract that complies with the CCPA, does not constitute a sale or sharing of your personal information.
You have the right to opt out of the sale or sharing of your personal information. To exercise your right to opt out, please notify our Data Protection Officer by e-mail at [email protected]. If you submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, such as the Global Privacy Control (GPC), we will abide by such request in a frictionless manner (as defined in the CPRA regulations). We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request. If you have opted out, we may ask you to opt back in after twelve (12) months.
CCPA Rights
Right to Know
You have the right to request:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information; and
- the specific pieces of personal information we have collected about you.
You have the right to request:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared; and
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosures above are limited to the personal information collected or used over the past twelve (12) months. Regarding personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the twelve (12) month period, and we will provide such information unless doing so involves disproportionate effort.
The information disclosed will be “portable” (i.e., delivered in an easily usable format to enable you to transmit the information to another entity without hindrance, provided that it is technically feasible).
Right to Deletion
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (e.g., where the information is used to identify and fix Website, App, and Service errors, to detect security incidents, protect against fraudulent or illegal activities, to exercise certain rights, etc.).
If no legal exception applies, as a result of exercising your right, your personal information will be deleted and we will notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so.
Right to Correction
You have the right to request that we correct any inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Opt Out of Sale
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
No Retaliation
We will not discriminate against you for exercising your rights under the CCPA, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services. However, should you choose to withhold certain required information, Organic Apps, its licensees and/or affiliates may not be able to provide you with some or all of the Services if such information is required for their provision.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
Exercising CCPA Rights
To exercise your rights under the CCPA, you need to submit your verifiable request to our Data Protection Officer by e-mail at [email protected].
A verifiable request 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 will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession relates to you. Making a verifiable consumer request does not require you to create an account. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
We will confirm receipt of your verifiable request within ten (10) days and provide information about how we will process the request. We will respond to your request within forty-five (45) days of its receipt. Should the response require more time, we will explain to you the justification therefore, and how much more time is necessary. Should we deny your request, we will explain to you the reasons behind our denial.
B. VIRGINIA CONSUMERS
If you are a consumer residing in the Commonwealth of Virginia, according to the Virginia Consumer Data Protection Act (the VCDPA), this section supplements and supersedes the Privacy Policy. This section is provided by Organic Apps as the controller operating the Website, Apps, and Services.
For the purposes of this section “personal information” (and “sensitive personal information”) have the meaning defined in the Virginia Consumer Data Protection Act (the VCDPA)
Categories of Personal Information
We collect the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, and inferred information. With your consent, we collect the following categories of sensitive data: precise location information and biometric data. We will not collect additional categories of personal data without notifying you. We will not process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time by notifying our Data Protection Officer by e-mail at [email protected].
Please note that certain exceptions set forth in the VCDPA may apply, such as when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
Purposes
We share your personal data with the third parties listed in the Privacy Policy. As used in this section, “third party” means a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller, as defined by the VCDPA.
Sale of Information
As used in this section, “sale” means any exchange of personal data for monetary consideration by the controller (Organic Apps) to a third party, as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as the disclosure of personal data to a third party for the provision of a product or service requested by you.
Right to Opt Out
You have the right to opt out of the sale of your personal data. To exercise your right to opt out, please notify our Data Protection Officer by e-mail at [email protected]. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Targeted Advertising
As used in this section, “targeted advertising” means displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests, as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller’s own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
Opt Out of Targeted Advertising
You have the right to opt out of the processing of your personal data for targeted advertising. To exercise your right to opt out, please notify our Data Protection Officer by e-mail at [email protected]. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
VCDPA Rights
Right to Access
You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data. The information disclosed will be “portable” (i.e., delivered in an easily usable format to enable you to transmit the information to another entity without hindrance, provided that it is technically feasible).
Right to Correction
You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
Right to Deletion
You have the right to request that we delete any of your personal data.
Opt Out of Processing
You have the right to opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
No Retaliation
We will not discriminate against you for exercising your rights under the VCDPA, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services. However, should you choose to withhold certain required information, Organic Apps, its licensees and/or affiliates may not be able to provide you with some or all of the Services if such information is required for their provision. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
Exercising VCDPA Rights
To exercise your rights under the VCDPA, you need to submit your verifiable request to our Data Protection Officer by e-mail at [email protected].
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate your identity and request.
Making a consumer request does not require you to create an account with us, however, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes. If you are an adult, you can make a request on behalf of a child under your parental authority.
We will respond to your request within forty-five (45) days of its receipt. Should the response require more time, we will explain to you the justification therefor, and how much more time is necessary.
Should we deny your request, we will explain to you the reasons behind our denial. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within sixty (60) days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If the appeal is denied you may contact the Attorney General to submit a complaint.