PRIVACY POLICY

Your California Privacy Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. If you are a California resident, your CCPA rights are described below. If you have any questions about whether any of the following applies to you, please email us at [email protected].

You have the right to request certain information about our collection and use of your personal information over the past 12 months, including the following:

• The categories of personal information that we have collected about you, as those categories are defined under the CCPA.
• The categories of sources from which that personal information was collected.
• The business or commercial purpose for collecting or selling your personal information.
• The categories of third parties with whom we have shared your personal information.
• The specific pieces of personal information that we have collected about you.
• If we have disclosed your personal information for a business purpose over the past 12 months, we will identify the categories of personal information shared with each category of third-party recipient.

In addition to the rights described above, the CCPA requires disclosure of the categories of personal information collected and shared with our affiliates over the past 12 months. Those categories, as described by the CCPA, consist of the following:

• Identifiers, including name, email address, IP address, and an ID or number assigned to your data.
• Other individual records such as phone number, employment history, bank account numbers, or credit or debit card information that you provide to us. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
• Demographics, such as your age or gender, marital status, and national origin. This category includes data that may qualify as protected classifications under other California or federal laws.
• Commercial information, including purchases and engagement with Company.
• Internet activity, including your interactions with our services and what led you to our Website.
• Geolocation data such as your location when visiting the Website.
• Inferences, including information about your interests, preferences and favorites.

We may use and disclose this information for the purposes listed in this Privacy Policy. 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. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Disclosures and Sales of Personal Information for Business Purpose

The CCPA contains a broad definition of what constitutes a “sale” of your personal information. In the preceding twelve (12) months, the Company has disclosed and/or sold the categories of personal information listed above for a business purpose.

We may disclose and/or sell your personal information with the following categories of third parties:

• Service Providers
• Data Aggregators
• Advertisers

Personal Information Sales Opt-Out and Opt-In Rights

If you are a California resident 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at to [email protected].

Exercising Access, Data Portability, and Deletion Rights

If you are a California resident you have the right to request deletion of the personal information that we have collected from you, subject to limited exceptions: for example, we may retain personal information to complete a transaction with you, or we may retain information that would affect the privacy of others or interfere with legal requirements. If your deletion request is subject to an exception under the CCPA we may deny your deletion request.

To exercise the rights described above, you should send us written request via email to [email protected] or via the Company address listed below.  Please ensure that your request (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information; and (2) provides sufficient detail to allow us to understand, evaluate, and respond to your request. We may not be obligated or able to respond to requests that do not meet these criteria.

For your security we may require you to verify your identity before we can act on your request. There may be information we will not return in response to your access request, such as information that would affect the privacy of others or interfere with legal requirements. Similarly, there may be reasons why we cannot comply with your deletion request, such as the need to keep your personal information to fulfill a legal obligation.

The Company will use commercially reasonable efforts to respond to any complete and valid request within 30 days of receipt. There is no cost to submit a valid request although Company may require a fee if your request(s) are excessive, repetitive, or unreasonable. You will not be charged a fee, and your fee-bearing request will not be processed, without Company providing you with prior written notice.

Should you choose to exercise any of your rights under the CCPA, the Company will not deny you any services, charge you different rates, or provide lesser quality services. However, in the future the Company may elect to offer different tiers of services as allowed by applicable laws (including the CCPA) which may contain differing prices, rates, or levels of quality, which may be related to the value of personal information that we receive from you.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: Fairways & Dreams, 200 W. Ridge Pike, Suite L-205A, Conshohocken, PA 19428.