Privacy Policy

ChargeFuze is committed to explaining how we gather and use your information, keeping it secure and handling it in accordance with our legal obligations. This Privacy Policy (“Policy”) is designed to help you understand how we handle your data. It also explains your rights and choices.

1. Keeping your information safe

This Policy applies to these services, which we call the “Platform”:

• ChargeFuze.com and our other web domains (our “websites”); 
• The ChargeFuze mobile app (“App”); 
• our social media pages; and
• anywhere else we gather information about you and refer to this Policy.

How we handle your information depends on which Platform services you use and how you use them.  This Policy is grouped into these sections: 

• about us and this Policy;
• information we collect;
• how we use information, including for advertising purposes;
• when we disclose information to other parties, including for advertising purposes; and 
• your rights and controls.  

We encourage you to read this Policy carefully. If you have questions, please contact us.

2. About us and this Policy

(a) Who we are

Fuze Technology Inc. (“Fuze”, “we”, “our” or “us”) operates the Platform. This Policy supplements and is governed by our Terms of Service (“Terms”). Our Terms define capitalized terms that are used but not defined in this Policy. The Terms describe how the Platform works in general, including security measures we use to protect our systems and the information described in the Policy.
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(b) How to contact us

If you have questions or comments about this Policy or our privacy practices or would like to exercise any data or privacy rights, please email us at contact@chargefuze.com, with “Privacy” in the subject line or write to us at: Fuze Technology Inc. 10801 National Blvd., Suite 350, Los Angeles, CA 90064, Attention: Legal Department.
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(c) When this Policy applies

This Policy applies to you when you use the Platform, effective as of the Last Updated date above. By using or accessing the Platform, you signify that you have read, understand and agree to be bound by this Policy and the Terms.

Updates:  Because the Platform changes often, this Policy may change over time. Anytime we modify the Policy, we will post a revised version on the Platform and update the Last Updated date above. 

Out-of-scope:  Certain parts of the Platform work differently, and some information falls outside this Policy:

• Certain parts of the Platform may have additional terms and privacy disclosures that supplement this Policy, such as Rentals at certain venues, as presented to you prior to engaging in any such Rental.
• The Platform may contain links to and from third-party websites and services. This Policy doesn’t apply outside our Platform. See “Third Party Platforms” in our Terms to learn more.

• If you are a current or former employee or contractor of ours, this Policy does not apply to you. You may contact us about your privacy practices and rights by contacting HR or emailing contact@chargefuze.com with “Personnel Privacy” in the subject line.
• If we receive your information in our capacity as a service provider to another business, our agreement with that business governs our use of your information. We will refer any questions or concerns of yours to that business.
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(d) Location-specific sections

The Platform operates from the United States, but this Policy applies worldwide.  Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live.  For example, you may have rights under: (1) “GDPR”: implementations of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679; or (2) “CCPA”: the California Consumer Privacy Act, as amended.  

As a result, certain sections of this Policy apply to you only if you reside in a particular location:  

• California residents should consult the Rights under California law section. If you reside in a U.S. jurisdiction that has enacted a data privacy law similar to CCPA or GDPR, we extend the same rights CCPA grants to California residents to you, except where we specify otherwise.
• Residents of jurisdictions where GDPR applies – should consult the Rights under GDPR and International Data Transfers sections.

If those sections apply to you, they override any contrary descriptions elsewhere in the Policy as they relate to you. Please see How to contact us above if you have questions about your rights under other data privacy laws.

3. Information we collect

(a) Information you provide

You may use much of the Platform without providing any information about yourself. However, to use some aspects of the Platform, we will need information about you, including your first and last name, telephone number, email address and other account login credentials (“Personal Identifiers”), such as if you:

• Establish an account
• Make Rentals
• Contact or communicate with us
• Subscribe or opt-in to our newsletters, alerts, or other communications
• Participate in a contest or promotion or redeem a prize

When you submit information through the Platform, such as to enable Rentals, you are consenting to its collection, use and disclosure in accordance with this Policy.  As of the Last Updated date, we use your telephone number to identify your account and authenticate you by messaging your telephone number with a code to login.  However, information you provide us may include Personal Identifiers, whether in other contexts or if we make changes to the Platform in the future.
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(b) Information collected when you use the Platform

As you use the Platform, cookies and other technology we use may generate technical data about which features you use, how you use them and the devices you use to access our services.  Some of this information is collected by technology on the websites and may not be processed by us or associated with you as a person.  This information may include:

• “Commercial Information” about your Rentals and interactions with Stations and Chargers.    
• “Device Information” related to the device you use to interact with the Platform, such as your IP address, its advertising IDs (random numbers resettable through your device’s settings, such as the device’s Apple IDFA or Android Advertising ID), its browser and operating system, its internet service provider, and its settings.
• “Internet Activity” related to your use of the Platform, such as the pages you visit, the sites you use before or after visiting ours, your actions within the Platform, the content or advertisements you interact with, general geolocation information, time stamps and performance logs and reports.
• “Sensitive Information” if you consent to provide us your precise location while you use the App.  You have the option to provide your approximate or precise location.  We only collect or process your approximate or precise location if you consent to provide it to us.  We only process your precise location to help you find Stations near you and we do not store it after you close the App.  For clarity, we do not collect your full credit card number and any payment-related security information when you make a Rental payment.  Full payment information is only collected and processed by our payment processing partners.

Upon accessing the Platform, we provide you with a “Cookie Preferences” banner, which you may use to opt out of our use of cookies to collect this information about you by clicking “Deny” and then “Submit”. Please note that, if you click “Deny” via the “Cookie Preferences” banner, we will only set “essential cookies,” which are required for the Platform to function as intended.
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(c) Information we don’t collect

For clarity, we do not collect:

• Sensitive personal information, unless you consent to provide your precise location to us while using the App, which is only accessible to us while you are using the App.
• Personal information about anyone under the age of 16 (see Use by minors below for more details)

We don’t sell, share or otherwise use any of those types of information. When used herein, “personal information” shall mean any data that identifies, relates to, or could reasonably be linked to you or your household, directly, or indirectly, as set forth under CCPA and other applicable U.S. state privacy laws.

4. How we use information

Here is a detailed explanation of the various reasons we use your information, together with practical examples:

1. To provide our content, services and products to you
   • Create and manage your account
   • Provide you with customer support and respond to your requests
   • Facilitate your Rentals and process payments refunds
   • Communicate with you about our services
2. To manage your account or facilitate Rentals
   • Register you on the App to allow you to rent Chargers
   • Administer your account on new features and apps
3. To improve our services and develop new ones
   • Administer focus groups, market studies and surveys
   • Review interactions with customer teams to improve our quality of service
   • Develop new content and services
4. To operate advertising and marketing campaigns
   • Administer sweepstakes, contests, discounts or other offers
   • Contact you about offers that may interest you
   • Text you, after you have given your consent and only until you withdraw it, about offers, including on a personalized basis.
5. To prevent, detect and fight fraud and other illegal or unauthorized activities
   • Find and address ongoing, suspected or alleged violations of our Terms
   • Retain data related to violations of our Terms to prevent against recurrences
   • Enforce or exercise our rights; for example, those in our Terms
6. To ensure legal compliance
   • Verify copyright or IP claims
   • Comply with legal requirements
   • Assist law enforcement

(a) Purposes

We rely on the following purposes to collect and use your information as described in this Policy:

• Commercial purposes: At times, we process your information to advance your economic interests or our economic interests.  These purposes include performing the contract that you have with us, as embodied by our Terms, which advance our economic interests and yours.  For instance, if you Rent a Charger from us, we use your information to complete your payment and provide your product to you.  
• Business purposes: Most often, we process your information for operational reasons, in a reasonably necessary and proportionate manner (i.e., for business purposes under CCPA). For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
• Comply with applicable laws and regulations: We also process your information where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement.  
• Consent: From time to time, we may ask for your consent to collect specific information, such as your precise geolocation, or use your information for certain specific reasons, like providing your email address or phone number for direct marketing purposes. In general, you may withdraw your consent by changing your settings (such as browser or device settings) or following instructions provided with information we send you based on the consent you gave us (such as texting ‘stop’ to text messages from us). You may always withdraw your consent at any time – just contact us.
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(b) Security

We take reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information against loss, unauthorized access, and illegal use or disclosure.  Access to personal information is limited to our personnel whose work requires such access. 

The security of your personal information is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your personal information, we cannot ensure or warrant the absolute security of any information you transmit to the Platform, and you do so at your own risk.

5. Our disclosures of information to others

Since our goal is to help you stay charged so you never miss a moment, the principal reason we exchange your information is to enhance your experience of the Platform and make sure it works well for all users.  

This section describes how and why we exchange personal information with contractors and third parties.  It also describes exchanges made for certain purposes, like legal reasons and consensual direct marketing.  We may also disclose deidentified and/or anonymized data for these purposes.
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(a) Functional disclosures

In addition to the use of trackers described above, we contract with companies or individuals to provide certain services related to the functionality and features of the Platform, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and administration of contests and other promotions. We refer to them as “contractors.” We use commercially reasonable efforts to only engage or interact with contractors that take appropriate measures to protect information about you, such as Personal Identifiers, Commercial Information, Internet Activity, and Device Information; however, it is the responsibility of such contractors to comply with applicable law and their respective privacy policies, and we take no responsibility for their privacy practices and compliance.

We may disclose information about you, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, to contractors as necessary for them to perform their services. Contractors are not permitted to use information about you for any other purpose. In the past twelve (12) months, we have disclosed these types of information to the following types of contractors:

• Analytics providers, namely Google Analytics, to tell us how the Platform is doing, such as which parts interest visitors and how long they visit before leaving. Among other data, they may receive your IP address.
• Various hosting services and data processors to provide the infrastructure of the Platform, such as Google Cloud and MongoDB, which ensures that traffic is from real people, not computers. Among other data, they may receive your IP address and Device Information.
• Messaging providers, namely Twilio, to facilitate text messages to you, such as to authenticate your account. They receive your phone number.
• Payment providers, namely Stripe, to process payments between you and us, such as for subscriptions or products. These providers receive information about your Rental in order to tie your payment process to your Rental. We don’t receive all of the information you may provide to them as part of that process (for instance, we don’t receive full payment-account numbers).
• Support providers to provide live chat support to you when you request it.  They may be able to retrieve information about you that is relevant to your requests, such as account information and Rental details.

Notwithstanding the disclosure of your Personal Identifiers, Commercial Information, Internet Activity, and Device Information to contractors for functional purposes, we have not sold (as such term is defined under the CCPA and other applicable U.S. state privacy laws) such information in the past twelve (12) months.

(b) For legal reasons

Finally, we may disclose personal information:

• In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms and other agreements; or
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.  

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(c) Advertising with anonymous website data

Your information:  We don’t share or sell any information we can associate with an individual person for behavioral ads (i.e., ads targeted to you), including any information collected by or provided through our App or that you disclose to us in connection with use of the App or Rentals. This includes Commercial Information and Sensitive Information. We segregate this information about you from the anonymous data collected by the website.

Anonymous data:  However, technology on our websites process Device Information and Internet Activity about the devices and identifiers associated with a visit to a website.  We do not and generally cannot associate any Device Information or Internet Activity collected by technology on our websites with you or any other person, as we only receive Personal Identifiers, if you provide it to us in the App or in communications with us.  

We may place advertisements through third parties based on Device Information and Internet Activity collected by technology on our websites.Because we do not maintain records of our own about this Device Information and Internet Activity and do not associate it with any individual’s personal information, we do not ‘share’ any personal information for purposes of CCPA and other applicable U.S. state privacy laws. We cannot honor requests for disclosure, correction or deletion of any Device Information and Internet Activity collected on our websites unless the requester is able to identify the Device Information and Internet Activity that was created or associated with their device or internet activity.

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(d) With your consent or at your request

We may periodically ask for your consent to disclose your information to third parties. Whenever we ask your consent for this reason, we will summarize the purpose and scope of the disclosure. For example, we may offer discounts to you if you consent to join our mailing list or participate in a promotion involving direct marketing communications. In that case, the Platform will present a checkbox near the submission button explaining that by clicking the checkbox, you agree to share your email with us for those purposes.

(i) Direct marketing

We only exchange information about you with third parties for direct marketing purposes if you opt in, and will only do so until you opt out.  

We may share information about you with third party sponsors or partners who will use it for marketing purposes but only if you opt in to such sharing or do not opt out when prompted.  We will never share information in this manner without giving you one of these two options.

6. How long we retain your information

We retain your information only as long as we reasonably need it for the purposes described under How we use information, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.  

How long we need information for those purposes varies by category, and even within categories.  These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information. 

For example, we delete some Internet Activity at some soon as you exit the Platform, whereas we may retain records of your Rentals for several years as required by law or contract, such as agreements with our payment processors or under our accounting standards.

7. Your rights

(a) In General

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

• Opting Out of Communications
  • If you no longer want to receive messages from us, you can opt out (as applicable) by sending “STOP” in response to a text message, using the unsubscribe link at the bottom of our communications, unchecking the applicable box to opt out when prompted, or by simply not opting in when prompted.  You may also at any time opt out of receiving communications from us by contacting us.
  • Please note that even if you unsubscribe from our communications, we may still need to contact you with important information related to your account and your purchases.  For example, even if you have unsubscribed from our promotional emails, we will still send you confirmation of a purchase you have made on our Platform or to alert you to changes to our Terms or Privacy Policy.
• Exercising rights:  If any of the location-specific rights listed below apply to you, you may exercise them as described under Requesting information
• Disallowing Location Data Collection

When using the App, you may consent to share your precise or approximate geolocation with us so we can customize help you locate nearby Stations.  You may change your location sharing settings at the browser or device level at any time.

• Opting Out of Personalized Advertising
  If you wish to opt out of personalized advertising in general, in addition to any location-specific rights that may apply, you have a few options:
  • On your mobile device, you can visit https://youradchoices.com/appchoices to learn about and download the Digital Advertising Alliance’s opt-out app, which allows you to opt your mobile device out of personalized advertising from participating companies.
  • Your mobile device settings may allow you to limit the use of information from your device; check your operating system documentation for details.
  • You can learn more about advertising networks and personalized advertising, and your ability to opt out, by visiting the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.

(b) Rights under GDPR

This section applies to you only if you reside in a jurisdiction where GDPR applies.  

For GDPR purposes, the data controller is Fuze Technology UK Limited, 7 Savoy Court, London WC2R 0EX.  

The purposes and the legal bases for our collecting and processing of personal data under GDPR are generally described under How we use information above. The Purposes above generally correspond to a legal basis under GDPR; for example, the basis for our commercial purpose is our legitimate interest.  

Depending on your jurisdiction’s enactment of GDPR, you may have these rights:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we might not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You may exercise rights under GDPR as described under Requesting information below.  If you do not provide personal data to us or withdraw consent for processing personal data, we may not be able to provide you with certain aspects of the Platform.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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(c) International Data Transfers

If you reside outside the United States, we transfer information about you for processing in the United States.  By providing information about you to enable Platform services, you consent to the processing of such data in the United States.  The transfer of this information to the United States is necessary for the performance of our contract for use of the Platform.

When we transfer personal data subject to GDPR outside of Fuze Technology UK Limited, we use standard contract clauses approved by the EU for this purpose, or another appropriate transfer mechanism.  If you wish to learn more about such international data transfers, contact us. 

Note that U.S. law is not equivalent to GDPR. As of the Last Updated date above, the U.S. has not been deemed an “adequate” jurisdiction under GDPR for the purposes of international data transfers. However, the EU and the U.S. are negotiating the terms of an adequacy determination that may go into effect in the years to come.
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(d) U.S. state-law rights

This section applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights, including any analogous rights, which, as of the Last Updated date above, includes Colorado, Connecticut, Florida, Montana, Oregon, Texas, Utah, and Virginia. Except as noted in this section, we extend these California rights to residents of those states regardless of whether applicable law in those states includes all of these rights.
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(i) Rights under CCPA

The California Consumer Privacy Act (“CCPA”) provides California consumers with additional rights regarding their personal information (as defined in CCPA).  

The categories of personal information we collect are generally described in Information we collect above, and depend on how you use the Platform.    For clarity, we have collected personal information for these CCPA categories of business and commercial purposes in the last twelve months:

• Advertising and Marketing
• Error Management
• Internal Research
• Provide Products or Platform
• Quality Assurance
• Security
• Short-Term Transient Use

The categories of third parties to whom we disclose and sell or share personal information are under for personalized ads and with your consent or at your request above. The disclosures under Purposes describe with business purpose or commercial purpose for those disclosures of information.

Under CCPA, California consumers have the following rights:
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(1) Rights to Know, Access, Correct and Delete

You have the right to request that we disclose, correct and delete personal information about you that we have collected. Your right to know includes the personal information we have sold or shared or disclosed for a business purpose or a commercial purpose.

Finally, we may deny deletion requests, in whole or in part, with respect to information we reasonably need to:

• comply with legal obligations;

• allow you, other consumers, or us to exercise free-speech rights or other legal rights;
• complete an obligation that you have requested (for instance, if a product you purchased carries a warranty or could reasonably be subject to recall under applicable law); or
• if we use the information only for internal purposes reasonably aligned with consumer expectations.

To exercise any of these rights, see Request process for CCPA rights below.
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(2) Rights to Limit and Opt-Out of Sharing/Sale

You also have the right to direct us (1) not to ‘share’ or sell your personal information and (2) limit our disclosure and use of your sensitive personal information to purposes necessary to provide the Platform to you.  

Because we do not ‘share’ information we can associate with anyone and do not maintain any sensitive personal information you may have temporarily provided to the App, we lack the ability to tie a requester to any information ‘shared’.  As a result, we do not currently offer an online mechanism to exercise the right to opt-out of sharing or sales or limit our disclosure of sensitive personal information.  Please contact us if you are able to associate your name or other Personal Identifiers with particular Device Information or Internet Activity and would like us to disclose responsive information in our records or delete some or all of that information.   

As of the Last Updated date, we have no knowledge of any use of ‘personal information’ (as defined in CCPA) from individuals under the age of 16 for ‘sale’ or ‘sharing’ purposes.
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(3) Right of No Retaliation

CCPA prohibits us from discriminating against you if you exercise rights under CCPA, except when you opted in to a financial incentive involving certain of your personal information, and subsequently restrict our use of that personal information through a CCPA rights request.  

• For example, if we offer you a discount code for consenting to receive marketing emails, and you then require us to delete your email address, we may not honor that discount code.

Your right of no retaliation doesn’t need to be exercised.  We never retaliate against anyone exercising their rights under this Policy or CCPA.
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(4) Preference signals

We are currently in the process of exploring how to automatically honor any global opt-out preference signal sent from California IP addresses to our websites through browser or device-level settings, provided the signal complies with CCPA’s requirements. Our goal is for the Platform to automatically respond to compliant signals by opting California residents out of any sharing or sale of their data in a frictionless manner.
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(5) Request process for CCPA rights

To submit a CCPA request relating to the foregoing rights, please contact us as described under Requesting information below.  That section generally applies to requests to exercise CCPA rights.  However, in addition:

• A California resident’s authorized agent may submit CCPA rights request. some text
  • Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described below. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf. 
  • An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required. 
• We will acknowledge your request within 10 days, and our goal is to fulfill your request within 45 days.  However, we may you that we will require up to 45 further days to fulfill your request, along with an explanation of why our response is delayed.  
• We provide responses in the manner we receive your request (i.e., with an email response to an email request).
• If you are a resident of Oregon or Texas, you may appeal our denial of your request within 45 days of your receipt of our written denial. To exercise your right to appeal, please contact us as described under Requesting information below.

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(ii) Other California law

Because we only give your information to third parties for direct marketing purposes with your consent, and always allow you to opt out of direct marketing communications after opting in, we believe we are not currently required to comply with California Civil Code Section 1798.83.

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(e) Requesting information

(i) Submitting requests

To exercise any of your GDPR rights or U.S. state-law rights, as applicable, contact us.  Your request must:

• provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain.  
• Omit (not include) social security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information.

(ii) Verifying requests

We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain.  If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with law that applies to you.  

If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.
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(iii) Responses to requests

We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests.  The content of our response will vary with the nature of your request, but will always respond in accordance with any deadlines or requirements specified by the laws that applies to you.

Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers’ account with us, or the security of our systems or networks.  We do not disclose account passwords or any other non-personal information that enables access to an account.

Please understand, however, that we reserve the right to retain an archive of any deleted information, to the extent permitted by law.  We may also retain deidentified or aggregate data derived from information about you.

8. Use by minors

The Platform is intended for adult users eighteen (18) years of age or older.  We do not knowingly collect information from anyone under the age of 16, and we do not share or sell information about anyone under 16 without affirmative authorization.  If we learn that we have collected information from a child under age 16, we will delete that information as quickly as possible.  

• If you are under 16:  sorry, but please leave the Platform.  If you’ve already sent us information, please contact us first so we can delete it.  
• If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with information, please contact us.