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.