Sync.Me Privacy Policy for California Residents

Last Revised: November 16, 2020

1. INTRODUCTION

If you are a California resident, the information below may apply to you in

addition to our Privacy Policy. This notice (“Privacy

Notice”) uses certain terms that have the meanings given to them by California

Consumer Privacy Act of 2018 and the California Consumer Privacy Act

Regulation by the Attorney General (collectively, “CCPA”). Any terms defined in

the CCPA have the same meaning when used in this Privacy Notice.

If you have a visual disability, you may be able to use a screen reader or other

text-to-speech or text-to-Braille tool to review the contents of this Privacy

Notice.

2. WHAT INFORMATION DO WE COLLECT?

We collect certain information which identifies an individual or may with

reasonable effort identify an individual (“Personal Information”). In addition,

we treat information which is specifically connected or linked to any Personal

Information - as long as such connection or linkage exists - as Personal

Information.

We have collected the following categories of Personal Information in the last

12 months:

• a. Category and business/commercial purpose of collection of Personal

Information

• Please check the information disclosed in section 1 (What

information we collect, why we collect it, and how it is used?) of

our general privacy policy here

• b. Categories of sources from which we collect your Personal

Information:

• Directly from consumers upon registration or use of the Service.

Directly or indirectly from activity on our Service by cookies or

other tracking technologies. From third parties that interact with

us, including social networks, other consumers who use our

Service and other publicly available sources.

• Directly from consumer's device by using cookies or other tracking

technologies.

• Directly from consumer's device using Wi-Fi or cellular technology

in your device, or by using IP address, or as directly submitted

from the consumer, or as made available on publicly available

sources

• c. Shared your Personal Information with the following categories of

third parties:


We disclose your Personal Information to third parties for a

business purpose. When we disclose Personal Information for a

business purpose, we enter into a contract that describes the

purpose and requires both parties to confidential and not use it

for any purpose except in the performance of the contract.

• In the preceding twelve (12) months, we have disclosed the

above-mentioned categories of Personal Information with the

following categories of recipients for a business purpose:

i. Our business partners;

ii. Our affiliates;

iii. Service providers;

iv. Social media networks;

v. Third-party marketing partners;

vi. Regulators, courts or competent authorities, to the extent

necessary, to comply with applicable laws, regulations and

rules (including, without limitation, federal, state or local

laws), and requests of law enforcement, regulatory and

other governmental agencies or if required to do so by

court order;

vii. We may share or transfer Personal Information to third

parties as assets that are part of a merger, acquisition,

bankruptcy, or other transaction in which the third party

assumes control of all or part of the Company. Such transfer

will be handled according to the requirement of the CCPA

and shall not be regarded as a sale of Personal Information

(as it is defined in the CCPA).

d. Sale of data

• We may sell (according to the CCPA definition of a "sale") your

Personal Information to third parties and businesses for

commercial purposes. You have the right to opt-out of a sale of

Personal Information (see below for more information on how to

exercise your rights). We sold the following categories of personal

information:

i. Identifiers (online) associated with a device used to interact

with our digital properties or advertisements (such as a

device identifier; cookies, beacons, pixel tags, mobile ad

identifiers and similar technology);

ii. Internet and other electronic network activity information

associated with a device used to interact with Digital

Properties or advertisements We do not sell the personal


information of consumers under the age of 16 if we have

actual knowledge of the individual’s age.

We do not sell personal information as the term is traditionally

understood, versus the definition under the CCPA — for example, we do

not exchange for money personal information to data brokers or third

parties for their marketing purposes independent of us.

We will not collect additional categories of personal information or use the

personal information we collected for materially different, unrelated, or

incompatible purposes without providing you notice.

3. YOUR RIGHTS UNDER THE CCPA

• 3.1 The CCPA provides consumers with specific rights regarding their

Personal Information. This section describes your CCPA rights (which

may be subject to certain exemptions or derogations) and explains

how to exercise those rights.

• You have the right to know what Personal Information is being

collected about you, this include the right to request that we

disclose what Personal Information of yours we collect, use,

disclose, and sell;

• You have the right to request the erasure/deletion of your

Personal Information (e.g. from our records and the records of our

service providers). Please note that there may be circumstances in

which we are required to retain your Personal Information, for

example for the establishment, exercise or defense of legal claims;

• You have the right to know whether your Personal Information is

sold or disclosed and to whom;

• You have the right to the restriction of, or to object to, the

processing of your Personal Information, including the right to opt

in or opt out of sale of your Personal Information to third parties,

if applicable, where such requests are permitted by law;

• You have the right not to receive discriminatory treatment for the

exercise of the privacy rights conferred by the CCPA;

• You have a right to lodge a complaint with your local data

protection supervisory authority (i.e., your place of habitual

residence, place or work or place of alleged infringement) at any

time or before the relevant institutions in your place of residence

(e.g. the Attorney General in your State). We ask that you please

attempt to resolve any issues with us before you contact your

local supervisory authority and/or relevant institution. You have

certain choices about your Personal Information. Where you have

consented to the processing of your Personal Information, you



may withdraw that consent at any time and prevent further

processing by contacting us as described in this Privacy Policy.

Even if you opt out, we may still collect and use non-Personal

Information regarding your activities on our services and for other

legal purposes as described above. While we cannot guarantee

privacy perfection, we will address any requests to the best of our

ability as soon as possible. We will process such requests in

accordance with applicable laws. You have a right to opt-out of

the Sale of Personal Information

3.2 Exercising Your Rights

• You can exercise your rights by submitting a verifiable consumer

request to our email address: privacy@sync.me. You may use an

authorized agent to submit a request on your behalf if you provide

the authorized agent written permission signed by you. To protect

your privacy, we may take steps to verify your identity before

fulfilling your request. Subject to legal and other permissible

considerations, we will make every reasonable effort to honor

your request promptly in accordance with applicable law, or we

will inform you if we require further information in order to fulfil

your request. When processing your request, we may ask you for

additional information to confirm or verify your identity and for

security purposes, before processing and/or honoring your

request. We reserve the right to charge a fee where permitted by

law, for instance if your request is manifestly unfounded or

excessive. In the event that your request would adversely affect

the rights and freedoms of others (for example, would impact the

duty of confidentiality we owe to others) or if we are legally

entitled to deal with your request in a different way than initial

requested, we will address your request to the maximum extent

possible, all in accordance with applicable law.

• Right to opt-out: If you do not want us to sell your Personal

Information to third parties, you may do so by visiting this link:

[https://sync.me/do-not-sell/]. After you opt-out, we may

continue to share some Personal Information with our partners

(who will function as our service providers in such instance) to

help us perform business-related functions such as, but not

limited to, providing the Service, ensuring that the Service is

working correctly and securely, providing aggregate statistics and

analytics and/or preventing fraud. If you access this site (or app)

from other devices or browsers, visit the links below from those



devices or browsers to ensure your choice applies to the Personal

Information collected when you use those devices or browsers.

Additionally, although clicking the “Do Not Sell My Personal

Information” link [https://sync.me/do-not-sell/] will opt you out of

the sale of your Personal Information for advertising purposes, it

will not opt you out of the use of previously collected and sold

Personal Information (except for Personal Information sold within

90 days prior to your exercising your right to opt- out) or all

interest-based advertising. If you would like more information

about how to opt-out of interest-based advertising in desktop and

mobile browsers on a particular device, please

visit http://optout.aboutads.info/#/ and http://optout.networkad

vertisina.ora/#. You may also download the App Choices app

at http://www.aboutads.info/appchoices to opt-out in connection

with mobile apps, or use the platform controls on your mobile

device to opt-out.

• Marketing emails – opt-out: You may choose not to receive

marketing email of this type by sending a single email with the

subject "BLOCK" to privacy@sync.me. Please note that the email

must come from the email account you wish to block.

3.3 Response Timing and Format

• In accordance with the CCPA, our goal is to respond to a verifiable

consumer request within 45 days of its receipt. If we require more

time, we will inform you of the reason and extension period in

writing within the first 45 days period. We will deliver our written

response, by mail or electronically, at your option. Any disclosures

we provide will cover only the 12-month period preceding the

request. If reasonably possible, we will provide your Personal

Information in a format that is readily useable and should allow

you to transmit the information without hindrance.

• To protect your privacy, we may take steps to verify your identity

before fulfilling your request. Subject to legal and other

permissible considerations, we will make every reasonable effort

to honor your request promptly in accordance with applicable law

or inform you if we require further information in order to fulfil

your request. When processing your request, we may ask you for

additional information to confirm or verify your identity and for

security purposes, before processing and/or honoring your

request. We reserve the right to charge a fee where permitted by

law, for instance if your request is manifestly unfounded or


excessive (if we determine that the request warrants a fee, we will

tell you why we made that decision and provide you with a cost

estimate before completing your request). In the event that your

request would adversely affect the rights and freedoms of others

(for example, would impact the duty of confidentiality we owe to

others) or if we are legally entitled to deal with your request in a

different way than initial requested, we will address your request

to the maximum extent possible, all in accordance with applicable

law.

• In case of rejection, the response we provide will explain the

reasons for which we cannot comply with your request.

• Please note that these CCPA rights are not absolute and requests

are subject to any applicable legal requirements, including legal

and ethical reporting or document retention obligations.

• 3.4 Designating Agents

• Only you or a person authorized to act on your behalf may make a

consumer request related to your Personal Information. You may

use an authorized agent to submit a request on your behalf if you

provide the authorized agent written permission signed by you.

You can designate an authorized agent to make a request under

the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity

registered with the Secretary of State of California;

• You sign a written declaration that you authorize the

authorized agent to act on your behalf.

• If you use an authorized agent to submit a request to

exercise your right to know or your right to request

deletion, please mail a certified copy of your written

declaration authorizing the authorized agent to act on your

behalf using the contact information below.

If you provide an authorized agent with power of attorney

pursuant to Probate Code sections 4000 to 4465, it may not be

necessary to perform these steps and we will respond to any

request from such authorized agent in accordance with the CCPA.

4. NON-DISCRIMINATION

If you decide to exercise your rights, you will not receive any discriminatory

treatment by us for the exercise of the privacy rights conferred by the CCPA.

However, note that some features of our Website/App, our products and/or

our services will not function without your Personal Information. Unless

permitted by the CCPA, we will not:


Deny you goods or services.

• Charge you different prices or rates for goods or services, including

through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or

services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA

that can result in different prices, rates, or quality levels. Any CCPA-permitted

financial incentive we offer will reasonably relate to your Personal

Information’s value and contain written terms that describe the program.

If you provide us with the above-mentioned categories of Personal

Information, our Service will enable you to report and block spam calls and get

a live caller-id and spam detector. If you do not provide your Personal

Information or ask us to delete or to not sell or share your Personal

Information, we will not be able to provide you with our App service, since

your Personal Information is essential to provide our Service to you.

5. DO-NOT-TRACK SIGNALS (SHINE THE LIGHT)

"Do Not Track" ("DNT") mechanisms is a privacy preference that users can set

in certain web browsers. Please note that we currently do not respond to web

browser DNT signals that provide a method to opt out of the collection of

information about online activities over time and across third-party websites

or online services.

6. UPDATES OR AMENDMENTS TO THE PRIVACY NOTICE

We reserve the right to change this Privacy Notice at any time, so please revisit this page frequently. If we implement significant changes to the use of

your Personal Information in a manner different from that stated at the time of

collection, we will provide notice of such changes of this Privacy Notice on the

Service and/or we will send you an e-mail regarding such changes to the e-mail

address that you volunteered, or by other means. To the maximum extent

permitted by law, such substantial changes will take effect seven (7) days after

such notice was provided on any of the above-mentioned methods. Otherwise,

all other changes to this Privacy Notice are effective as of the stated “Last

Revised” date, and your continued use of the Service after the Last Revised

date will constitute acceptance of, and agreement to be bound by, those

changes.

7. HOW TO CONTACT US

If you have any questions (or comments) concerning this Privacy Notice, you

are welcome to contact us here: privacy@sync.me.