A p p e n d i x :   P r o c e s s i n g   o f   P e r s o n a l   I n f o r m a t i o n   o f   C a l i f o r n i a   R e s i d e n t s

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In addition to the Policy above, this “Appendix: Processing of Personal Information of California Residents” (this “Appendix”) shall apply to the processing of personal information of the Users residing in the State of California in the United States in accordance with the California Consumer Privacy Act of 2018 (the “CCPA”). If there is any discrepancy between the provisions of this Appendix and the provisions of the Policy, the provisions of this Appendix shall take precedence.

1. Definitions

The definitions of the terms used in this Appendix are the same as those under the CCPA. In particular:

“Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a User’s personal information by the business to a third party (meaning anyone other than the Company, our subcontractors and other business partners, hereinafter the same applies in this Appendix) for monetary or other valuable consideration.

“Share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a User’s personal information by the business to a third party for cross-context behavioral advertising.

2. Notice of Collection

The Company will collect and has collected in the last twelve (12) months, the following categories of personal information of the Users. The Company has not disclosed Users’ personal information to any third party for a business purpose in the last twelve (12) months. 

We do not sell or share and will not sell or share in the future any of the personal information collected from the Users.

For details on the personal information we collect, refer to Section “1. Categories of Personal Information We Collect” of the Policy. For details on the business purposes and commercial purposes of personal information we collect, refer to Section “2. Purposes of Use of Personal Information and Legal Grounds for Data Processing” of the Policy. For details on the sources of the personal information we collect, refer to Section “4. Sources of Personal Information” of the Policy. For details on the retention period of the personal information we collect, refer to Section “7. Retention Period of and Security Measures for Personal Information” of the Policy.

3. Users’ Rights under the CCPA

The CCPA provides residents of California with specific rights regarding personal information. If the User is a California resident, the following describes their rights under the CCPA and explains how to exercise those rights.

1. Right to Access Personal Information

The Users are entitled to request that we disclose certain information to them about our collection, sharing, disclosure or use of their personal information. Once we receive and confirm a verifiable User request, we will disclose the following information to such User.

• The categories of personal information we collected about the User;
• The sources for the personal information we collected about the User;
• Our business or commercial purposes for collecting, selling, or sharing such personal information;
• The categories of third parties with whom we share such personal information;
• The categories of personal information that we have sold, and for each category identified, the categories of third parties to whom we sold such personal information;
• The categories of personal information that we have disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed such personal information; and
• The specific pieces of personal information we collected about the User.

2.Right to Request Deletion

Each User is entitled to request that we delete any of such User’s personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a verifiable User request, we will delete such User’s personal information from our records (and notify our outsourcing companies etc., to delete the same), unless an exception applies. 

We may deny the User’s deletion request if retaining the information is necessary for us or our outsourcing companies etc., in order to: 

• Complete the transaction for which the personal information was collected, fulfill the terms of a product recall conducted in accordance with a written warranty or federal law, provide goods or services requested by the User, or take measures that are reasonably anticipated by the User within the context of our ongoing business relationship with such User, or otherwise perform our contract with the User;
• Help to ensure security and integrity to the extent the use of the User’s personal information is reasonably necessary and proportionate for those purposes;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the rights of other Users to exercise their free speech rights, or exercise other rights provided for by the laws and regulations;
• 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 the User previously provided informed consent; 
• Enable solely internal uses that are reasonably aligned with User expectations and the context in which the User provided the personal information based on the relationship between the User and the Company; and to
• Comply with legal obligations.

3.Right to Request Correction

The Users are entitled to request that we correct any inaccurate personal information of a User that we have collected and retained. Once we receive and confirm a verifiable User request, we will correct such User’s inaccurate personal information (and notify our outsourcing companies etc., to correct the same). We may deny the User’s request for correction if we determine that the contested personal information is more likely than not to be accurate based on the totality of the circumstances.

4.Right to Opt-Out of Sale or Sharing

We have not sold or shared any User’s personal information in the past twelve (12) months and we will not sell or share such personal information in the future. Since the Services are directed to Users who are not under the age of 16, we will not intentionally sell or share the personal information of any User who is under the age of 16.

5.Right to Limit the Use of Sensitive Personal Information

The Company will not use or disclose any sensitive personal information collected from the Users for any purpose other than the following: 

• Performing the services or providing the goods reasonably expected by an average consumer who requests such goods or services;
• Helping to ensure security and integrity;
• Performing short-term, transient use (except for those involving profiling or changes to the future User experience);
• Performing services on behalf of the Company; and
• Maintaining or enhancing the quality or safety of the services (including the Services) and devices of the Company.

6.Right to Non-Discrimination

We will not discriminate against the Users for exercising any of their rights under the CCPA. Moreover, unless permitted under the CCPA due to the Users’ exercise of their rights, we will not: 

• Deny goods or services to the Users;
• Charge the Users different prices or rates for goods or services;
• Provide the Users with a different level or quality of goods or services;
• Suggest that the Users may receive a different price or rate for goods or services or a different level or quality of goods or services; or
• Retaliate against an employee, applicant for employment, or independent contractor.

7.How to Exercise Your Rights

In order for the Users to exercise the rights under the CCPA, they are requested to submit a verifiable User request to us by contacting us as set forth in Section “12. Inquiries” of the Policy. The Users need to complete a User request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.

Only the User, a natural person or a person registered with the California Secretary of State that the User authorizes to act on the User’s behalf, or a person who has a power of attorney or is acting as a conservator for the User, may submit a verifiable User request related to the User’s personal information. If permitted under the CCPA, we may perform procedures to verify the identity and authority of the agent as required under the CCPA.

Established: 4 1, 2025