Privacy Policy

APPLICABILITY OF PRIVACY POLICY

This Privacy Policy applies to all information we collect through our Services from current and former users, including you. “Services” means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us in connection with the Sites, the Gigafin Mobile App and our Gigafin brand generally. When you are no longer our customer, we may continue to share your information as described in this Privacy Policy. This Privacy Policy does not apply to the third-party online/mobile store from which you may have downloaded and installed the Gigafin Mobile App, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

Throughout this Privacy Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Effective Date” of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Sites and/or Gigafin Mobile App after the date such revised Privacy Policy is posted.

COLLECTION OF YOUR INFORMATION

When you visit any of the Sites or download, install, and use the Gigafin Mobile App, we may collect different types of information during your interactions with our Sites and our Gigafin Mobile App, and through our advertising and media across the Internet. This information may include personal information (e.g., name, phone number, postal address, email address, and certain payment information), technical information (e.g., technical information, including device identifier, IP address, browser type, operating system) and usage information (e.g., how you use and navigate to and from our Sites and Gigafin Mobile App, and information about content or advertisements you have been shown or have clicked on). We may combine these types of information together, and collectively refer to all of this information in this Privacy Policy as “Information.” Information may be collected as described below and through the use
of cookies, web beacons, pixels, and other similar technologies by us or by other companies on
our behalf. Below we describe the types of Information we may collect:

Registration, account, and sign-up information

We may collect Information in the course of your use of, or registration with, our Sites and/or Gigafin Mobile App. For example, when you create an account, register for, or download our Gigafin Mobile App, or sign-up for a product or service that we offer, you may provide us with certain personal information. This type of personal information may include your name, phone number, postal address, fax number,
email address, or certain payment information (e.g., credit card and billing information). We may also receive Information about your interest in and use of various products, programs, services, and content available on or through our Sites and Gigafin Mobile App.

Mobile device data

Information about you that we derive (a) from your mobile device or computer such as your device type, machine or mobile device identification number, model and manufacturer, version of your operating system, phone number, country, location, Geolocation Information (as defined below),time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes.

Personal Data

Information such as your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers). Also demographic (e.g., age, race, gender), psychographic (e.g., lifestyle, attitudes, political opinions, trade union membership, activities and interests) and other personal information that you voluntarily give to us when choosing to participate in various activities related to the Sites and/or Gigafin Mobile App, such as chat, posting messages in comment sections or in our community forums, liking posts, sending feedback, and responding to surveys. If you choose to share data about yourself via your profile, online chat, or other interactive areas of the Sites and/or Gigafin Mobile App, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses the Sites and/or the Gigafin Mobile App servers.

Derivative Data

Information our servers automatically collect when you access the Sites and/or the Gigafin Mobile App, such as your native actions that are integral to the Sites and/or Gigafin Mobile App, including liking, re-blogging, or replying to a post, as well as other interactions with the Sites and/or Gigafin Mobile App and other users via server log files.

Financial Data

Financial information, such as data related to bank account online login information and bank account and routing numbers linked to your Gigafin Mobile App account. We do not share financial information with third party social networking services such as those listed in the section of this Privacy Policy titled “Collection of Your Information – Data from Social Networks.”

Facebook Permissions

If you authorize Facebook Connect, the plug in allows us access to your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

Data from Social Networks

User information from social networking sites, such as Facebook, Instagram, Pinterest, and Twitter, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your Site and/or Gigafin Mobile App account to such social networks. This information may also include the contact information of anyone you invite to use and/or join any of the Sites and/or the Gigafin Mobile App.

Geolocation Information

Information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We may request access or permission to track Geolocation Information from your mobile device, either continuously or while you are using the Gigafin Mobile App, to provide you with location-based Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. In addition, some of our Services may ask you for permission to share your current location with other
Gigafin Mobile App users within your device settings to enhance our Services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, sensors, SMS messages, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Push Notifications

We may request to send you push notifications regarding any of your Site accounts or Gigafin Mobile App account or the Gigafin Mobile App in general. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Third-Party Data

Information from third parties, such as personal information or network or community friends, if you connect your account to the third party and grant the Gigafin Mobile App permission to access this information.

Data from Contests, Rewards and Surveys

Personal and other information you may provide us when entering contests, claiming, and collecting rewards provided to you by us and/or responding to surveys.

We are committed to providing a safe, secure, and outstanding service. Therefore, before permitting you to use the Services, we may require additional information from you that we can use to verify your identity, address, or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.

When you are using the Services, we collect information about your Gigafin Mobile App account transactions, and we may collect Geolocation Information and/or information about your computer or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with other users of the Gigafin Mobile App or our customer support team.

INFORMATION FROM MINORS

The Services are not directed to persons under the age of 18, and therefore we do not knowingly solicit information from or market to minors. If we obtain actual knowledge that we have collected personal information from a minor, we will promptly delete it, unless we are legally obligated to retain such data. If you become aware of any data we have collected from a person under the age of 18, please contact us using the contact information provided below.

HOW WE USE COOKIES AND WEB BEACONS

We may use cookies, web beacons, tracking pixels, and other tracking technologies (collectively “Tracking Technologies”) on the Sites and Gigafin Mobile App. We use Tracking Technologies to recognize you as a user of the Sites and Gigafin Mobile App; customize Services, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; improve your experience with the Sites and Gigafin Mobile App and to promote trust and safety across our Services. When you access our Sites and Gigafin Mobile App, your personal information is not collected through the use of Tracking Technology. Most browsers are set to accept cookies by default. You can remove or reject cookies but be aware that such action could affect the availability and functionality of the Sites and Gigafin Mobile App. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis. For more information see our Cookies Policy.

SECURITY OF YOUR INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems, and while we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our best efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

If we learn of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that we may communicate with you electronically. We may post a notice on the Sites or send you a push notification or a Gigafin in-app message on your mobile device if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at [email protected].

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience with our Sites and our Gigafin Mobile App. Specifically, we may use information collected about you via the Sites or the Gigafin Mobile App to:

• create and manage your Gigafin Mobile App account;
• provide the Services and customer support you request;
• generate a personal profile about you to make future visits to the Sites and/or the Gigafin Mobile App more personalized;
• process transactions and send notices about your transactions or your Gigafin Mobile App activity;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent potentially fraudulent, prohibited or illegal activities, and enforce our Gigafin Mobile App End User License Agreement and our Mobile App/Website Terms and Conditions through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
• create an account connection between your Gigafin Mobile App account and a third-party account or platform;
• administer loyalty and rewards programs, sweepstakes, promotions, and contests;
• compile anonymous statistical data and analysis for use internally or with third parties;
• deliver targeted rewards, coupons, written and video content, and other information relating to the Sites and Gigafin Mobile App to you;
• email you regarding your Gigafin Mobile App account;
• enable user-to-user communications;
• increase the efficiency and operation of the Sites and the Gigafin Mobile App;
• monitor and analyze usage and trends to improve your experience with the Sites and the Gigafin Mobile App;
• notify you of updates to the Sites and the Gigafin Mobile App; and
• request feedback and contact you about your use of the Sites and the Gigafin Mobile App.

HOW WE SHARE YOUR PERSONAL INFORMATION WITH OTHER PARTIES

We do not share your personal information with third parties for their promotional or marketing purposes. We do not sell your personal information for money. Some personal information is public information (including your Gigafin Mobile App username, profile photo, profile first and last name, month, and year of account creation), and may be seen by anyone on the internet, whether or not they have a Gigafin Mobile App account. Public information may also be seen, accessed, reshared or downloaded through our APIs or third-party services that integrate with our Services.

We may share your personal information as follows:

Legal and Law Enforcement Purposes

We may disclose your personal information in response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request. We also may disclose your personal information to third parties: (i) in connection with fraud prevention activities, (ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, and (v) as otherwise required by law.

Business Partners

We may share your personal information with our business partners who assist us in providing Services to you or who provide fraud detection or similar services on our behalf. In all our dealings with business partners, we require them to honor this Privacy Policy. Third-Party Service Providers. We may share your personal information with third parties that we contract with who help with parts of our business operations (for example, fraud prevention, payment processing, customer service or technology services). Our contracts with third-party service providers dictate that they `only use your personal information in connection with the services they perform for us and not for their own benefit.

Other Third Parties

We may share your Information with other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.

• For the purposes of this privacy policy, an “account connection” with such a third party is a connection you authorize or enable between your Site account and/or Gigafin Mobile App account and a non-Site account and/or a non-Gigafin account or platform that you lawfully control or own. When you authorize such a connection, we and the third-party will exchange your personal information and other information directly. Examples of account connections include, without limitation: linking your Gigafin Mobile App account to a social media account or social messaging service or connecting your Gigafin Mobile App account to a third-party data aggregation or banks and other financial services companies.
• If you connect your Gigafin Mobile App account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Gigafin Mobile App account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all
  such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Policy.
• Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection. For example, personal information that we share with a third-party account or platform such as a social media account may in turn be shared with certain other
  parties, including the general public, depending on the third-party’s account or platform privacy practices.

We do not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third- party social networks, such information is no longer under our control and is subject to the terms of use and privacy policies of such third parties.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.

If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly and providing the third-party with all instructions and directives necessary to terminate receipt of correspondence, emails or other communications from such third-party.

Sponsors and co-promotions

We may sometimes offer content or programs (e.g., contests, sweepstakes, promotions, games, applications, or Social Media site integrations) that are sponsored by or co-branded with identified parties. By virtue of these relationships, the sponsoring or co-branding parties may collect or obtain personal information from visitors that participate in the activity. We have no control over these sponsoring or co-branding parties’ use of this personal information. We encourage you to visit the privacy policy of any such sponsoring or co-branding party to learn about their data practices prior to providing personal information through sponsored or co-branded content or programs.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your personal information with unaffiliated third parties for marketing purposes, as permitted by law.

If you with to withdraw your consent or opt-out of our sharing your personal information with unaffiliated third parties for the third parties’ direct marketing purposes, you may do so under certain circumstances by sending us a request to do so (along with your full name, email address, postal codes, and the subject line labeled “Opt-Out of Sharing Personal Information with Third-Party Marketers”) by regular U.S. mail or by email as follows:

By Regular U.S. Mail By Email
Mobilitypay Holdings, Inc. [email protected].
Attn: Chief of Staff
28126 Peacock Ridge Drive, #210
Rancho Palos Verdes, CA 90275

Interactions with Other Users

If you interact with other users of the Sites and/or the Gigafin Mobile App, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, and following blogs.

Online Postings

When you post comments, contributions or other content to the Sites or the Gigafin Mobile App, your posts may be viewed by all users and may be publicly distributed
outside the Sites and Gigafin Mobile App in perpetuity.

 

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Sites and/or use the Gigafin Mobile App. These companies may use information about your visits to the Sites or your use of the Gigafin Mobile App and other websites that are contained in web cookies in order to provide advertisements about goods and services of
interest to you.

 

Change of Control

We may transfer your personal information in the event of a business transaction, such as if we or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

THIRD-PARTY WEBSITES

The Sites and the Gigafin Mobile App may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Sites or the Gigafin Mobile App, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of the personal information that you may have provided to such third-party websites and applications. Before visiting and providing any personal information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your personal information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Sites and/or the Gigafin Mobile App.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

To access the personal information that we have collected about you online from the Sites and/or the Gigafin Mobile App, or to update your user profile, please log into your account if you have created one with us, or send an email to [email protected]. For California residents, please see below for additional information on accessing information about you.

CALIFORNIA PRIVACY RIGHTS

The “California Privacy Rights” section of this Privacy Policy discusses and notifies California residents of our obligations and your legal rights under the California Consumer Privacy Act of 2018 (or CCPA). These obligations and rights apply to businesses doing business in California and to California residents and information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or families, or devices that are linked to California consumers or families (“California Personal Information”). Further, the “California Privacy Rights” section of this Privacy Policy provides you with information on how to exercise your rights under the CCPA in connection with your relationship with us.

California Personal Information We Collect

We have not collected any California Personal Information within the 12 months prior to the Effective Date of this Privacy Policy. However, our Sites and Gigafin Mobile App are, or will be, capable of collecting the following categories of California Personal Information from consumers: Category Examples Collected

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	No
B. Personal Information Categories – as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	No
C. Protected classification characteristics under California or federal law.	Age (40 years or older), 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, genetic information (including familial genetic information).	No
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	No
G. Geolocation data	Physical location or movements	No
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment- related information	Current or past job history or performance evaluations.	No
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))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
L. Equipment information	Equipment information. Information about your internet connection, the equipment you use to access our Website, and usage details.	No

California Personal Information We Used for Our Business Purposes

We may use California Personal Information for our business purposes such as maintaining or servicing accounts, providing customer service or processing payments. We did not use any California Personal Information within the 12 months prior to the Effective Date of this Privacy Policy.

California Personal Information We Have Sold

We do not sell your California Personal Information for money. However, under the CCPA our use of cookies and other Tracking Technologies in connection with our Services may be deemed a “sale” of Personal Information. See our Cookies Policy.

We did not sell any California Personal Information within the 12 months prior to the effective
Date of this Privacy Policy.

Your California Privacy Rights to Request Disclosure of Information We Collect and Share
About You

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits you to request information about our practices related to the disclosure of your California Personal Information by us to certain third parties for their direct marketing purposes. You may be able to opt-out of our sharing of your California Personal Information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. Please send your request (along with your full name, email address, postal address, and the subject line labeled “Your California Privacy Rights-Opt-Out of Sharing Personal Information with Third-Party Marketers”) by regular U.S. mail or by email as follows:

In addition to the foregoing, if you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to your California Personal Information. In particular, you can request the following:

• The categories of your California Personal Information that we have collected.
• The categories of sources from which we collected California Personal Information.
• The business or commercial purposes for which we collected or sold California Personal Information.
• The categories of third parties with which we shared California Personal Information.
• The specific pieces of California Personal Information we collected about you (also called a data portability request).

 

You can submit a request to us for the following additional information:

• The categories of third parties to which we have sold California Personal Information, and the category or categories of California Personal Information sold to each.
• The categories of California Personal Information that we have shared with service providers who provide services for us like payment processing.

Your Right to Ask Us Not to Sell Your California Personal Information

Targeting-related cookies collect information for analytics and personalize your experience with targeted ads. Under the CCPA, the use of cookies and other Tracking Technologies by us, and the sharing of
cookie and other Tracking Technology data by us to advertising networks (targeting cookies),
may constitute a sale of your Personal Information by us. Under the CCPA, you have the right to
opt-out of the sale of your California Personal Information to third parties.

You can always tell us not to sell your California Personal Information by visiting here: https://www.gigafin.com/do-not-sell/. Once we receive and process your request, we will not share your California Personal Information with any third parties for targeted advertising unless you later allow us to do so. If you enabled privacy controls on your browser (such as a plugin), we accept that as a valid request to opt-out. Therefore we will not be able to track your activity through the web which may affect our ability to personalize ads according to your experience. For more information see our Cookies Policy.

Your Right to Request the Deletion of California Personal Information

You have the right to request that we delete any of your California Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your California Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining your California Personal Information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the California 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 contacting us by regular U.S. mail or by email as follows:

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 California 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 California 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 California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use California Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Time to Your Verifiable Consumer Request and Format of the Information to be Provided to You

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account or by mail or email, at your option. If you do not have an account with us, we will deliver our written response by either mail or email, at your option.

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 California Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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.

Our Support for the Exercise of Your Data Rights

We are committed to providing you control over your California Personal Information. If you exercise any of the rights explained in this section of the Privacy Policy, we will not disadvantage you. You will not be denied or charged different prices or rates for our Services or provided a different level or quality of Services because you have exercised your rights under this Privacy Policy or under the CCPA.

Consumers Under 16 Years Old

As stated earlier in this Privacy Policy, our Services are not directed to persons under the age of 18, and therefore we do not knowingly collect information from or market to minors (see INFORMATION FROM MINORS). However, notwithstanding this fact, you should be advised that the CCPA has specific rules regarding the use of California Public Information from consumers under 16 years of age. Given the mandates of the CCPA, and consistent with the other provisions of this Privacy Policy, if we knowingly collect the California Personal Information of a consumer under the age of 18, we will not sell the information. If you would like further information on how we handle California Personal Information from
consumers under the age of 18 years of age, or if you have questions about these information practices, you may contact us at:

CONTACT US

If you have any questions or comments about this Privacy Policy, please contact us at:

MobilityPay Holdings, Inc.
Attention: Chief of Staff
28126 Peacock Ridge Drive, #210
Rancho Palos Verdes, CA 90275
(O) 310.541.4102
(F) 310.377.8069
[email protected]