California Privacy Rights

Your California Privacy Rights

This section of our Policy applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Reform Act (“CPRA”).

If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

The categories of Personal Information we have collected about you;
The categories of sources from which the Personal Information is collected;
Our business or commercial purpose for collecting or selling Personal Information;
The categories of third parties with whom we share Personal Information;
The specific pieces of Personal Information we have collected about you;
The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
The categories of Personal Information about you that we disclosed for a business purpose.
The categories of sensitive personal information to be collected and the purposes for which the categories of sensitive personal information are collected or used and whether such information is sold or shared.

Right to Deletion of Personal Information

You have the right to request that we delete Personal Information about you that we have collected from you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Right to Correct Personal Information

You have the right to request that we correct any inaccurate information that we maintain about you.

Right to Opt-Out

You have the right to opt out of the sale or sharing of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “personal information” in such a way that making advertising and analytics technology linked to you for a benefit may be considered a “sale.” To opt out of the sale or sharing of your data use this web form.

Right to Limit the Use or Disclosure of Sensitive Personal Information

To the extent that we use or disclose Sensitive Personal Information for reasons other than those listed in the CCPA, you have the right to limit that use or disclosure of sensitive personal information. We do not use Sensitive Personal Information for reasons other than those listed in this Policy.

Right to Non-Discrimination

We may not discriminate against you because you have exercised any of the aforementioned rights, including by:

Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing you a different level or quality of goods or services; or
Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.

This includes the right of current and prospective employees not to be retaliated against for the exercise of their CCPA rights.

However, as permitted by the CCPA, we may offer you certain financial incentives. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may withdraw at any time.

Notice of Financial Incentives

As permitted by the CCPA, we may offer you certain financial incentives such as discounted products and services in exchange for receiving personal information such as your email address. This information allows us to tailor our communications and products and services suggestions for you. This, in turn, helps us establish a stronger relationship with you – something we greatly value.

The value of these discounts vary. For example, you could receive $10 off your purchase when you provide us with your email address.

In determining the value of this data to Company, we consider the profit generated from products that include Personal Information, which is reasonably correlated to the value provided to the consumer through personalized coupons, promotions, and other discounts or offers.

The use of these financial incentives is voluntary and requires your prior opt-in consent, which you may revoke at any time. If you no longer wish to receive communications from us, see “Choices and Access to Information” below.

Personal Information We Collect about California Consumers

We collect certain types of Personal Information about you during your relationship with us, as stated above. In particular, we collected the following categories of Personal Information from California consumers within the last twelve (12) months:

Category of Personal Information Collected	Collected (Yes/No)	Sources of Personal Information Collected
Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above.	Yes	You Automatically Third Parties
The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above.	Yes	You Automatically Third Parties
Characteristics of protected classifications under California or federal law list any of these that you collect: race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.	No	N/A
Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time.	Yes	You Automatically Third Parties
Biometric Information.	No	N/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, mobile apps, or Company pages or accounts on any third-party social media platforms.	Yes	Automatically
Geolocation data.	Yes	Automatically
Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above.	Yes	Automatically
Professional or employment-related information.	Yes	You Automatically Third Parties
Education information.	No	N/A
Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	Yes	Third Parties
Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, past or spent criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number.	Yes	You Automatically

How to Exercise Your California Privacy Rights

You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently.

To exercise your rights provided under this Policy, submit your request via this web form.

Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. This might include asking for your email address.

If you use an authorized agent to exercise your rights, we may require proof of written authorization you have given the authorized agent to make the request on your behalf.

We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time.

Data Sharing for Direct Marketing Purposes

Embr Labs does not share information with third parties for their independent marketing or promotional purposes.

If you are a California resident under 18 years of age and a registered user of our Services, you may request that we remove content and information that you post on our Services. To obtain removal of such content and information, please contact us at the information below with a short description of the content or information you would like to have removed. Please note that such a request does not necessarily ensure complete or comprehensive removal of content posted by you, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user.

Choices and Access to Information

If you no longer wish to receive marketing communications from Company, please follow the “unsubscribe” instructions that are included at the bottom of each message. We may still send you certain communications relating to the Services you use, such as service announcements and administrative messages.

You have the right and ability to edit certain account information on our Services at any time by logging into your account using the mobile application. Users may also have additional rights to access, review, correct, delete, or inquire about information that we hold about them. To make such a request, please use this webform. Please note that we may need to verify your identity or request additional information from you before we are able to comply with your request.

Data Retention and Deletion

We retain information for as long as reasonably necessary to deliver our Services to you or to fulfill the purposes described in this Policy, or as required by law. To request the deletion of your personal information, please use this webform. We will make our best effort to delete all personal information about you. However, please note that certain information, including other information, may be retained in backup databases or for analytic purposes.

Information for Site users from outside the United States

The personal and other information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any personal or other information to us, you expressly consent to such transfer and processing. Our contracts with our service providers ensure that they use appropriate safeguards to transfer your Personal Information to the United States.

Children’s Privacy

The Services are not directed to children under the age of 16, and Company does not knowingly collect personal information from anyone who is under the age of 16 or sell or share such information. We recommend that persons over 16 but under 18 years of age ask their parents for permission before using the Services or sending any information about themselves to anyone over the Internet.

Links to Other Websites or Services

The Services may contain links to and from the websites or apps of other third parties. If you follow a link to any of these websites or apps, please note that these websites and apps, and any services that may be accessible through them, have their own privacy policies. A link to any third-party site does not imply that we endorse or accept any responsibility for the content or use of such site. We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites and apps. This Privacy Policy applies only to information collected in connection with the Services.

Changes to this Policy

Our Services may change from time to time. As a result, we may need to change this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and without prior notice. We will post any revised Privacy Policy on our website with an “effective date” indicating when the changes will take effect. We encourage you to review this Privacy Policy periodically.

For Additional Information

If you have any questions about this Policy, please contact us at embrlabs.com/contact (select Data Privacy in the What Can We Help With? section) or at: Embr Labs, 24 Roland St Ste 102, Boston, MA 02129 USA.

v2.4.2, Updated: June 20, 2023

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