CCPA | Sing Sharp

Privacy Notice for California Residents

Effective Date: March 12, 2022

Last reviewed on: March 12, 2022

This Privacy Notice For California Residents supplements the information contained in Sing Sharp’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Any capitalized terms not defined herein or in the CCPA have the meaning provided in the Privacy Policy.

Information We Collect

Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, the Services have collected the following categories of personal information from its consumers within the last twelve (12) months. The specific information collected from each category below is detailed in "Types of Data Collected" of the Privacy Policy.

Category A. Identifiers, such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Collected: Yes

Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name, physical characteristics or description, address, telephone number, or any financial 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: such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.

Collected: No

Category D. Commercial information: such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected: Yes

Category E. Biometric information: such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information.

Collected: No

Category F. Internet or other similar network activity, such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Collected: No

Category G. Geolocation data, such as physical location.

Collected: Yes

Category H. Sensory data, such as audio, electronic, visual, or similar information.

Collected: Yes

Category I. Professional or employment-related information, such as current or past job history or performance evaluations.

Collected: No

Category J. Non - public education information(per the Family Educational Rights and Privacy Act (20 U.S.C.Section 1232g, 34 C.F.R.Part 99)), such as education records.

Collected: No

Category K. Inferences drawn from other personal information, such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: Yes

Personal information does not include:

- Publicly available information from government records.

- Deidentified or aggregated consumer information.

- Information excluded from the CCPA's scope, like:

- 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.

Sing Sharp obtains the categories of personal information listed above from the sources described in "Types of Data Collected" of the Privacy Policy.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the business purposes described in "Use of Your Personal Data and Content" of the Privacy Policy. Sing Sharp 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.

Sharing Personal Information

Sing Sharp may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties:

- Service providers

- Advertising networks

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category G: Geolocation data.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Sing Sharp disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 purpose 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(also called a data portability request).

- If we disclosed your personal information for a business purpose, disclosing: disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Sing Sharp delete any of your personal information that we collected from you and retained, subject to certain exceptions. In order to provide You with greater control over Your Personal Data and Content, “Delete Account” is available within the Service (Profile/Delete Account). Upon completion of “Delete Account” action, all Your Personal Data and Content are permanently deleted from Your Devices and from Our server. Exception may apply under certain circumstances. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by using our support form. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer 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 cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to confirm receipt of your request within 10 days, as well as provide general information about how the business will process the request. We also endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. We will deliver our written response by mail or electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.The response we provide will also explain the reasons we cannot comply with a request, if applicable.For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 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's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Notice

Sing Sharp reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Sing Sharp collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us via our support form.

MAG