Privacy notice (Web app)

Data Protection, Responsibility, and Scope

We respect the privacy of our customers and other interested parties and comply with applicable laws to protect your privacy. These laws include, in particular:

• the European Union General Data Protection Regulation (“GDPR”)
• the UK General Data Protection Regulation (“UK GDPR”)
• relevant sector- and state-specific US privacy laws

This privacy notice applies to:

• Web- and mobile app Talkturo Web-App
• The web application is reachable at: app.talkturo.com

The following categories of data subjects are covered by this data protection notice:

• Clients
• Employees of the customer
• Third parties under contract with the customer

The party responsible for processing your personal data under this Privacy Notice is:
Talkturo LLC
2261 Market Street STE 22180
San Francisco, CA 94114
United States

If you have any questions regarding data protection, please contact us at the following email address: info@talkturo.com

In the following, we explain:

• For what purposes personal data is collected and processed.
• Which categories of personal data are affected by the collection and processing.
• On what legal basis we process personal data.
• Which involved third parties, acting as data processors, are engaged in the processing of personal data.
• To which third parties personal data is transmitted.
• Further information, such as data retention periods, the rights of data subjects, and other details that help inform you about the described data processing.

Purposes for which personal data is processed

Application hosting

We process your personal data to enable the technical operation, availability, and maintenance of our applications. This includes providing the necessary infrastructure to store, manage, and deliver content and services, ensuring secure access, and supporting the reliable functioning of our online offerings.

Categories of personal data that are processed:

• Device Information
• Log data
• Technical Information
• User behavior relevant for error analysis

Legal basis for processing and transfer:

• (Pre-)Contractual activities pursuant to Art. 6 para. 1 lit. b GDPR

Involved data processors:

• Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany
• Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, United States
• Supabase, Inc., United States (server location: EU)
• LiveKit Inc., 4285 Payne Avenue, Suite 9154, CA 95157 San Jose, California, United States

Additional information:

• Location of the data center where the web app is hosted: Germany (Hetzner); database and files (Supabase): EU

Authentication and User Management (Login)

To provide secure access to our services, we process personal data for the purpose of authenticating users and managing user accounts. This ensures that only authorized individuals can access protected areas and functionalities, helps maintain the integrity and security of our systems, and enables us to manage user preferences and account-related activities efficiently. Authentication and user management are essential for delivering a personalized and secure user experience.

Categories of personal data that are processed:

• Authentication data
• Identifying Data
• Log data

Legal basis for processing and transfer:

• (Pre-)Contractual activities pursuant to Art. 6 para. 1 lit. b GDPR

Involved data processors:

• Supabase, Inc., United States (server location: EU)
• Google Ireland Limited, Gordon House, Barrow Street, D04 E5W5 Dublin, Ireland
• Meta Platforms Ireland Ltd., Merrion Road, D04 X2K5 Dublin, Ireland
• Cloudflare, Inc., United States

Customer Relationship Management (CRM)

We process your personal data for the purpose of managing and maintaining our relationship with you as a customer or prospective customer. This includes activities such as responding to your inquiries, providing customer support, managing your account, sending you relevant information about our products or services, and improving our interactions with you. The aim is to ensure effective communication, deliver a personalized experience, and support the ongoing development of our business relationship.

Categories of personal data that are processed:

• Contact data
• Identifying Data
• Personal preferences
• Transaction data

Legal basis for processing and transfer:

• Consent of the data subject pursuant to Art. 6 para. 1 lit. a GDPR
• EU Standard Contractual Clauses (SCC) pursuant to Art. 46 para. 2 lit. c and d GDPR
• EU-US Data Privacy Framework pursuant to Art. 45 para. 3 GDPR
• Legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR

Involved data processors:

• ActiveCampaign, LLC, United States

Additional information:

• Interest based on the legal basis: Manage and strengthen our customer relationships, provide effective customer support, communicate relevant information about our products and services, and develop our business operations.

Payment and Invoicing

We use the US service provider “Stripe” to process payments via its European subsidiary.

Categories of personal data that are processed:

• Cookies and similar technologies
• Invoice data
• Payment data
• Technical Information

Legal basis for processing and transfer:

• (Pre-)Contractual activities pursuant to Art. 6 para. 1 lit. b GDPR
• EU Standard Contractual Clauses (SCC) pursuant to Art. 46 para. 2 lit. c and d GDPR
• EU-US Data Privacy Framework pursuant to Art. 45 para. 3 GDPR

Involved data processors:

• Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, D02 H611 Dublin, Ireland

Additional information:

• For more detailed information on data protection relating to privacy at Stripe, please refer to the Stripe Privacy Policy.

Subscription management

We use Stripe Billing to manage recurring payments and subscriptions.

Categories of personal data that are processed:

• Cookies and similar technologies
• Invoice data
• Payment data
• Subscription related data
• Technical Information

Legal basis for processing and transfer:

• (Pre-)Contractual activities pursuant to Art. 6 para. 1 lit. b GDPR
• EU Standard Contractual Clauses (SCC) pursuant to Art. 46 para. 2 lit. c and d GDPR
• EU-US Data Privacy Framework pursuant to Art. 45 para. 3 GDPR

Involved data processors:

• Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, D02 H611 Dublin, Ireland

Additional information:

• For more detailed information on data protection relating to privacy at Stripe, please refer to the Stripe Privacy Policy.

Provision of the services offered

With our application "Talkturo Web-App" we offer the following service: Konfigurieren, Verwalten und Bereitstellen eines KI- Telefon-Assistenten sowie einer mobilen Telefonie-App. In this subsection, we outline data processed and third-party service providers involved for the direct provisioning of our services.

Categories of personal data that are processed:

• AI prompts and other AI-related information
• Appointment data
• Configuration data
• Contact Information (if personalized content delivered)
• Data related to service quality
• Identifying Data
• Technical authentication data (e.g., API keys)
• Telephone numbers

Legal basis for processing and transfer:

• (Pre-)Contractual activities pursuant to Art. 6 para. 1 lit. b GDPR

Involved data processors:

• Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany
• Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, United States
• Supabase, Inc., United States (server location: EU)
• LiveKit Inc., 4285 Payne Avenue, Suite 9154, CA 95157 San Jose, California, United States
• Telnyx LLC, United States
• Twilio Ireland Limited, 25-28 North Wall Quay, D01 H104 Dublin, Ireland
• Meta Platforms Ireland Ltd., Merrion Road, D04 X2K5 Dublin, Ireland
• Nylas, Inc., 2100 Geng Rd. #2100, Palo Alto, CA 94303, United States
• OpenAI Ireland Ltd., 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland
• Resend, Inc., United States

Establish contact via email

We process your personal data when you contact us via e-mail in order to respond to your inquiries, provide you with requested information, or otherwise communicate with you. This enables us to address your questions, support requests, or other concerns efficiently and effectively.

Categories of personal data that are processed:

• Contact data
• Information that you send us by e-mail

Legal basis for processing and transfer:

• EU Standard Contractual Clauses (SCC) pursuant to Art. 46 para. 2 lit. c and d GDPR
• EU-US Data Privacy Framework pursuant to Art. 45 para. 3 GDPR
• Legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR

Involved data processors:

• Resend, Inc., United States

Additional information:

• Interest based on the legal basis: Enable effective communication with you to respond to your inquiries.
• We ask that you do not transmit any special categories of personal data when contacting us. These categories include the following data:
  • Ethnic origin.
  • Political opinions.
  • Religious or philosophical beliefs.
  • Trade union membership.
  • Genetic data.
  • Biometric data.
  • Health data.
  • Data concerning sex life or sexual orientation.
• If we become aware of a transfer of sensitive categories of data, we will arrange for these to be deleted under consideration of reasonable effort.

Offering live chat or chatbot features

To provide users with real-time support and assistance, we offer live chat and/or chatbot features on our platform. These features enable users to communicate directly with our support team or receive automated responses to their inquiries. The processing of personal data is necessary to facilitate these interactions, ensure effective communication, and improve the quality of our support services.

Categories of personal data that are processed:

• Communications Data
• Cookies and similar technologies
• Information you provide as free text
• Technical Information

Legal basis for processing and transfer:

• EU Standard Contractual Clauses (SCC) pursuant to Art. 46 para. 2 lit. c and d GDPR
• Legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR

Involved data processors:

• Crisp IM SAS, France

Additional information:

• Our legitimate interest lies in providing timely and effective support to users, resolving their inquiries, and enhancing the overall quality of our services.
• We ask that you do not transmit any special categories of personal data when contacting us. These categories include the following data:
  • Ethnic origin.
  • Political opinions.
  • Religious or philosophical beliefs.
  • Trade union membership.
  • Genetic data.
  • Biometric data.
  • Health data.
  • Data concerning sex life or sexual orientation.
• If we become aware of a transfer of sensitive categories of data, we will arrange for these to be deleted under consideration of reasonable effort.

Delivering product news

Categories of personal data that are processed:

• Contact data
• Identifying Data

Legal basis for processing and transfer:

• Binding Corporate Rules (BCR) pursuant to Art. 46 para. 2 lit. b GDPR
• EU Standard Contractual Clauses (SCC) pursuant to Art. 46 para. 2 lit. c and d GDPR
• EU-US Data Privacy Framework pursuant to Art. 45 para. 3 GDPR
• Legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR

Involved data processors:

• ActiveCampaign, LLC, United States

Additional information:

• Further information on data protection at Twilio can be found in the Twilio Privacy Notice.
• The Twilio Binding Corporate Rules (BCR) can be foud on the Twilio Website.

License- and abuse control

Categories of personal data that are processed:

• Login and access protocols
• device and usage data
• User identifiers

Legal basis for processing and transfer:

• EU Standard Contractual Clauses (SCC) pursuant to Art. 46 para. 2 lit. c and d GDPR
• EU-US Data Privacy Framework pursuant to Art. 45 para. 3 GDPR
• Legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR

Involved data processors:

• Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany
• Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, United States
• Supabase, Inc., United States (server location: EU)
• Cloudflare, Inc., United States

Additional information:

• Legitimate interest: Ensuring network and information security

Additional Information

Cookies

This application uses cookies and similar technologies to store and process personal data and information. Cookies may be used for various purposes, including ensuring the application’s basic functionality, analyzing usage, personalizing content, and providing targeted advertising, depending on the specific service or feature you use.
The processing of personal data through cookies is carried out on the legal basis specified for each respective service, as detailed in this privacy notice. For non-essential cookies (such as those used for analytics or marketing purposes), we will only process your personal data if you have given your explicit consent. Strictly necessary cookies, which are essential for the application's operation, are set without your prior consent but are limited to what is required for the service to function.
You have the right to control the use of cookies at any time. You can manage your cookie preferences through our cookie settings tool, which allows you to accept, reject, or customize your choices for different categories of cookies. You may also withdraw your consent at any time, and this will not affect the lawfulness of processing based on consent before its withdrawal.
In addition, you can configure your web browser’s settings to control how it handles cookies, including blocking or deleting cookies, restricting storage processes, and determining how long cookies are stored on your device. Please note that disabling certain cookies may impact the application's functionality.

Data retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this privacy notice, or as long as required by contractual or legal retention obligations. Once your personal data is no longer needed for these purposes, or when applicable retention periods have expired, your data will be deleted or anonymized in accordance with applicable data protection laws

Protection of Personal Data

We safeguard personal data by implementing appropriate technical and organizational measures in accordance with applicable data protection laws and recognized industry standards. These measures include, where feasible, the pseudonymization and encryption of personal data both in transit and at rest. Our security practices are regularly reviewed and updated to ensure the ongoing confidentiality, integrity, and availability of your personal information.

Withdrawal of consent

If you have given your consent to the processing of your personal data for a specific purpose based on Art. 6 para. 1 lit. a GDPR, you can withdraw this consent at any time. The lawfulness of the processing of the personal data until the withdrawal is not affected by the withdrawal.

Transfer of data

We only transfer or disclose your personal data to third parties when required by applicable law, regulation, or legal process, or when it is necessary for the performance or provision of our services to you. In all cases, we ensure that any transfer of your personal data complies with relevant data protection laws, including the General Data Protection Regulation (GDPR) where applicable. Third-party data processors process personal data only as necessary to deliver the agreed-upon services, in accordance with our instructions and applicable data protection agreements. We do not sell your personal data to third parties. If we intend to use your personal data for purposes that require your consent under applicable law, we will obtain your explicit consent beforehand.

Rights of Data Subjects

Right of Access

You have the right to request at any time information about the personal data we store about you and to receive a copy of that information. Furthermore, you have the right to obtain confirmation as to whether the personal data in question is being processed.

Right to Rectification

Should your data be inaccurate or incomplete, we will rectify it upon request.

Right to Data Portability

If we process your personal data in an automated way based on your consent or based on a corresponding agreement, you have the right to request a copy of your data in a structured, commonly used, and machine-readable format, which can be sent to you or another party. This right applies only to the personal data that you have provided to us.

Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data under certain circumstances.

Right to Erasure

You have the right to have the personal data processed by us deleted, insofar as this is legally permissible.

Objection to Processing

You can object to the processing of your personal data, for example, by not using certain services. If you object to the processing of your personal data for certain purposes, this may result in the inability to use the services concerned.

Right to Lodge a Complaint

If you believe that we are not processing your personal data correctly, you can contact us. You also have the right to lodge a complaint with a supervisory authority. For more information on the supervisory authorities in the European Union, please click here.
All rights can be exercised by sending an e-mail to the contact named at the beginning of this privacy notice.

Data Transfer to the United States of America and the Data Privacy Framework

To ensure the protection of your personal data when it is transferred outside the European Economic Area (EEA), we rely on recognized legal mechanisms in accordance with the General Data Protection Regulation (GDPR).

On July 10, 2023, the European Commission adopted an adequacy decision under Article 45(1) GDPR for the EU-US Data Privacy Framework (DPF). This means that personal data can be lawfully transferred from the EEA to organizations in the United States that participate in the DPF, as these organizations are considered to provide an adequate level of data protection equivalent to that of the EU.

What does this mean for you?

• When we use US-based service providers to process your personal data, we ensure that such providers are certified under the EU-US Data Privacy Framework. Certification requires these organizations to adhere to strict data protection principles and is subject to oversight and enforcement by US authorities.
• The adequacy decision provides a valid legal basis for these data transfers, ensuring your rights and protections under the GDPR are maintained.
• You can verify whether a US service provider is currently certified under the Data Privacy Framework by visiting the official Data Privacy Framework website.

If we engage a US service provider that is not certified under the Data Privacy Framework, we will clearly inform you in this privacy notice and specify the alternative legal safeguards in place for such transfers (for example, Standard Contractual Clauses approved by the European Commission).

Regardless of the transfer mechanism, you retain all rights provided under the GDPR, including the right to access, rectify, erase, or restrict the processing of your personal data, as well as the right to lodge a complaint with a supervisory authority.

For more details about the EU-US Data Privacy Framework and the adequacy decision, you can visit the European Commission’s website.

Standard Contractual Clauses

In order to enable data transfer to countries without an adequacy decision, the EU Commission has drawn up standard contracts (standard contractual clauses). These standard contractual clauses require contractual partners to adhere to a level of data protection comparable to that in the EU. These contractual texts are made available on the European Commission's website. Standard contractual clauses are abbreviated to “SCC”.

Additional privacy notice information for U.S. residents

This section provides additional information to U.S. residents whose personal information is collected, used, and/or disclosed pursuant to applicable U.S. law and supplements the general information of our global privacy practices outlined in this privacy notice.
We comply with all applicable US federal and state privacy laws, including but not limited to the Children’s Online Privacy Protection Act (COPPA), California Consumer Privacy Act (CCPA/CPRA), and the privacy laws of Virginia, Colorado, Connecticut, Utah, Delaware, Nevada, and other applicable states.

Important note on wording

Parts of this section may refer to the general part of this privacy notice (the content preceding this section). Please note that the term “personal data” is used in the general section, but this section refers to “personal information.” Since the term “personal data” encompasses the scope of “personal information,” the term “personal data” can be considered at least equivalent to “personal information.”

Supplemental information on collection, usage, and sharing of your personal information

Categories of personal information collected, used, and shared

Please refer to the general part of this privacy notice, which outlines:

• The purposes for which personal information is collected.
• The categories of personal information that are collected for each purpose.
• Involved third parties and service providers with whom personal information is shared for each purpose.

Use and disclosure of personal information for business purposes or commercial purposes

We may use or disclose personal information we collect for “business purposes” or “commercial purposes”, which are outlined in the general part of this privacy notice as purposes of processing.
We may use or disclose, and may have used or disclosed in the last twelve (12) months, the categories of personal information outlined for each purpose in the general part of this privacy notice for business or commercial purposes.

Sources of personal information

We obtain the categories of personal information listed in the general part of the privacy notice from the following categories of sources:

• Directly from the individual (e.g., actively entering an email address).
• Automatically through the app (e.g., through cookies, analytics...).

Do not sell my personal information or share or process my personal information for targeted advertising

Residents of specific US states (e.g., California) may opt out of the “sale” of their personal information. Such residents may also opt out of the sharing or processing of their personal information for targeted advertising.
We may provide third parties information to recognize you across devices and enable marketing and delivery of targeted advertising to you. The disclosure of personal information for this purpose to third parties may be considered a “sale” of personal information under applicable law and is sharing of personal information and the processing of personal information for targeted advertising purposes.
If you or (in certain states where required by law) your authorized agent would like to opt out of the use or disclosure of your information for such purposes (to the extent this is considered a sale, share, or targeted advertising), you may do so in the footer or settings menu provided, depending on the options provided.
Please note, if you use different browsers, devices, or services, you may need to make your elections separately.

Additional information for residents of Nevada

Certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration. “Covered information” includes first and last name, address, email address, phone number, or an identifier that allows a specific person to be contacted either physically or online.

Children's and minors privacy in the U.S.

Our services are not directed to, intended for, or designed to attract children under 13 years of age. We do not knowingly collect, use, store, or disclose personal information from anyone under the age of 13. If you are under 13 years old, please do not use our services or provide any personal information to us.

Compliance with the Children's Online Privacy Protection Act (COPPA)

In accordance with the Children's Online Privacy Protection Act (COPPA), if we become aware that we have inadvertently collected personal information from a child under 13 years of age without proper parental consent, we will:

• Immediately flag the information for review and suspend data processing.
• Contact the parent or guardian if contact information is available.
• Delete the information within a reasonable timeframe, typically within 30 days of discovery.
• Document the deletion to ensure compliance with applicable laws.
• Review our systems to prevent similar occurrences.

Additional protections for minors between 13 and 16 years of age

For California and other states with similar applicable law, we provide additional protections under the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and other relevant laws for residents between 13 and 16 years of age:

• We will not sell or share your personal information without your direct, affirmative consent (opt-in).
• You have the right to opt-out of the sale or sharing of your personal information at any time.
• We will honor your requests to delete your personal information, subject to certain legal exceptions.

Rights for minors under the age of 18

If you are under the age of 18 and a resident of California or another state with similar relevant law, you have the right to request and obtain removal of content or information publicly posted. If you find we have posted information about you publicly, you are a resident of California or a state with similar relevant law, and you want to request removal of such data, you can contact us using the contact information provided below. We may verify your identity using appropriate methods.

Parental rights

If you are a parent or legal guardian and believe that your child under 13 has provided personal information to us, or if you are a parent of a California or other relevant US state resident between 13 and 16 years of age and have concerns about our data practices, please contact us using the contact information below. Upon verification of your identity and relationship to the child, we will:

• Provide you with a description of the personal information we may have collected.
• Give you the opportunity to review any personal information we have collected.
• Allow you to request the deletion of your child's personal information.
• Refuse to permit further collection of your child's personal information.

Contact information

If you are a parent or guardian with questions or concerns about your child's privacy, or if you believe your child has provided us with personal information, please contact us:
Mailing Address:
Talkturo LLC
2261 Market Street STE 22180
San Francisco, CA 94114
United States
Email:
When contacting us, please include:

• Your child's name and age.
• The email address, username, or another identifier associated with your child's information (if known).
• A description of your concern or request.
• Verification of your identity as the parent or legal guardian.

Verification Process

To protect your child's privacy and security, we may require verification of your identity as the parent or legal guardian, using methods deemed reasonable under the circumstances, before taking action on your request.

Your rights according to applicable federal and US state privacy laws

Depending on where you live, you may have certain rights with respect to your information. Those rights are listed in the following and may apply based on applicable local law.

The right to notice

You have the right to be notified which categories of personal information are being collected and the purposes for which the personal information is being used.

The right to request

You may request that we disclose the following information to you, as required by law:

• The categories of personal information we have collected about you.
• The categories of sources from which we collected your personal information.
• The business or commercial purposes for collecting, selling, or sharing your personal information.
• The categories of third parties with whom we share your personal information.
• The specific pieces of personal information we have collected about you.
• The categories of personal information we have sold or disclosed for a business purpose, and the categories of third parties to whom it was sold or disclosed.

Right to delete

You may request that we delete personal information we have collected from you, subject to certain exceptions provided by law.

Right to correct or update

You may request that we correct inaccurate personal information we maintain about you.

Right to opt out of sharing or selling your personal information

You have the right to direct us not to sell or share your personal information.

Right to limit the use of personal information

Where required by local law, you may request that we limit the use and disclosure of your personal information or sensitive personal information as defined by applicable law. If we collect sensitive personal information as defined by the CPRA or other applicable local law, we will specify the types collected and how you can limit their use.

• Sensitive personal information may include, for example, government identifiers, financial data, precise geolocation, racial or ethnic origin, and more.
• For details on the specific sensitive personal information we collect and your options to limit its use, please contact us as described below in the “How to Exercise Your Rights” section.

Right to Non-Discrimination

You have the right not to be discriminated against (as provided by applicable law) for exercising your rights under some local laws, such as in California.

Right to appeal and complaint

If you have any unresolved concerns, you may have the right to file a complaint with your data protection authority.

How to exercise your rights

You may exercise your rights by contacting us via:
Email
info@talkturo.com
Postal mail:
Talkturo LLC
2261 Market Street STE 22180
San Francisco, CA 94114
United States
Toll-free telephone number (if available and required)

To process your request, we may need to verify your identity. Information provided for verification will only be used for this purpose. If we cannot verify your identity or link your request to the personal information we hold, we may not be able to fulfill your request.
You may also designate an authorized agent to make a request on your behalf. If you use an authorized agent, we may require proof of authorization and may ask you to verify your identity directly with us.

Limits on your privacy rights and choices.

In some instances, your choices may be limited, such as when fulfilling your request would impair the rights of others, our ability to provide the service you requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to exercise your rights” section above. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

Exceptions to and impacts of exercising privacy rights

We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on your state of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

Your Rights according to California's Shine the Light law

California residents with an established business relationship with us can request, once a year, information about how their personal information is shared with third parties for their direct marketing purposes.
If you'd like to request more information under the California Shine the Light law and you are a California resident, you can contact us using the information provided in this privacy notice.

Universal Opt-Out

We honor universal opt-out signals (such as Global Privacy Control) where required by law.

Data breach notification

In the event of a data breach involving your personal information, we will notify you promptly as required by relevant federal and state law and may offer remediation if appropriate.

Further information related to US federal and state privacy laws

For more information about our privacy practices or your rights, please contact us using the details in the "How to Exercise Your Rights" section.
This privacy notice is reviewed and updated at least once every 12 months as required by the CCPA or other similar applicable laws. You can find the date of the last update at the end of this privacy notice under "Changes to this privacy notice".

Changes to this privacy notice

We may update this privacy notice occasionally to reflect changes in our data processing practices, legal requirements, or other operational needs. Any modifications will be published on this page, and the "Date of publication" below will be updated accordingly. We encourage you to review this notice periodically to stay informed about how we protect your personal data.

Date of publication of the current version: November 2, 2026