Personal Information We May Collect about California Residents

Category	Examples
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.
B. Personal information categories 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.
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).
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.	Current or past job history or performance evaluations.
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.
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

We reserve the right to use de-identified or aggregate data for any purpose without limitation, and we will not attempt to re-identify the information.

 

Personal information does not include:

1. Publicly available information from government records.
2. De-identified or aggregated consumer information.
3. Information excluded from the scope of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, “California Privacy Law”), like:

（1）health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data,

（2）personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver's Privacy Protection Act of 1994.

 

We obtain the categories of personal information listed above from the following categories of sources:

1. Directly from our clients or their agents. For example, from records that our clients provide to us related to the services for which they engage us.
2. Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
3. Directly and indirectly from activity on our Services. For example, from submissions through our website portal or Services usage details collected automatically.
4. From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

 

Use of Personal Information

Seefunge discloses personal information to Seefunge’s subsidiary companies and third-party service providers and contractors.

 

Seefunge engages third-party service providers and contractors to carry out various activities and provide certain services on its behalf. Seefunge has adequate data protection agreements and data transfer mechanisms in place with each relevant sub-processor, as required by applicable data protection laws and as appropriate to ensure safeguarding of the relevant personal data.

 

We may use or disclose the personal information we collect for one or more of the following business purposes:

1. To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to provide guidance related to a medical device.
2. To provide you with information, products or services that you request from us.
3. To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
4. To audit related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards.
5. To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
6. To perform services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business,
7. For debugging to identify and repair errors that impair existing intended functionality.
8. For short-term, transient use, provided your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
9. To undertake internal research for technological development and demonstration.
10. To perform activities to verify or maintain the quality or safety of a Service or device that is owned, manufactured, manufactured for, or controlled by the company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
11. To carry out our obligations and enforce our legal rights.
12. To improve our Services and present their contents to you.
13. For testing, research, analysis and product development.
14. As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
15. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
16. As described to you when collecting your personal information or as otherwise set forth in California Privacy Law.
17. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sensitive personal information

Unless we specifically request it for a legitimate business purpose, do not send us any sensitive personal information on or through the Service or otherwise to us. Examples of Sensitive Personal Data include (1) Personal Information that reveals: an individual’s social security, driver’s license, state identification card, or passport number; an individual’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; an individual’s precise geolocation; an individual’s racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of an individual’s mail, email and text messages, unless the business is the intended recipient of the communication; an individual’s genetic data; (2) processing of biometric information for the purpose of uniquely identifying an individual; (3) Personal Information concerning an individual’s health; or (4) Personal Information concerning an individual’s sex life or sexual orientation. 

 

Sensitive Personal Data is disclosed to third parties without an appropriate legal basis. In many cases, the Data Subject must provide informed, voluntary, and explicitly consent to the disclosure. 

For more details of how "sensitive personal information" is defined by California Privacy Law see Cal. Civil Code 1798.140(ae) (as amended by the CPRA).

 

No sale of personal information

In the twelve months prior to the effective date of this Disclosure, Seefunge has not sold any personal information of data subjects, as those terms are defined under the California Consumer Privacy Act.”

 

Your California Privacy Rights

California Privacy Law provides California Residents with specific rights regarding their personal information. This section describes your rights under California Privacy Law and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting or selling that personal information.
4. The categories of third parties with whom we share that personal information.
5. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

(1)sales, identifying the personal information categories that each category of recipient purchased, and

(2)disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

You may also be entitled to request that we disclose to you the specific pieces of personal information we have collected about you in a portable, and to the extent technically feasible, readily usable format. 

 

Deletion Request Rights

 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it, or as otherwise permitted under applicable law.

 

Right to Correct Your Personal Information

 

You may also have the right to request that we update inaccurate information that we process about you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws.

 

Right to Limit Use of Your Sensitive Personal Information

 

You are entitled to limit use and disclosure of your sensitive personal information to certain business purposes. 

 

Exercising these Rights

If you want to exercise these rights, use our Data 

 

California Privacy Law provides California Residents with specific rights regarding their personal information. This section describes your rights under California Privacy Law and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

 

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting or selling that personal information.
4. The categories of third parties with whom we share that personal information.
5. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

(1)sales, identifying the personal information categories that each category of recipient purchased, and

(2)disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

You may also be entitled to request that we disclose to you the specific pieces of personal information we have collected about you in a portable, and to the extent technically feasible, readily usable format. 

 

Deletion Request Rights

 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it, or as otherwise permitted under applicable law.

 

Right to Correct Your Personal Information

 

You may also have the right to request that we update inaccurate information that we process about you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws.

 

Right to Limit Use of Your Sensitive Personal Information

 

You are entitled to limit use and disclosure of your sensitive personal information to certain business purposes. 

 

Non-Discrimination

We will not discriminate against you for exercising any of your rights under California Privacy Law. Unless permitted by law, we will not:

1. Deny you goods or services,
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties,
3. Provide you a different level or quality of goods or services, or
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Children’s Privacy

We do not knowingly disclose personal information about children under the age of 18 to third-parties for monetary or other valuable consideration (i.e., “sell” or “share,” as those terms are defined in California Privacy Law). 

 

Changes to this Policy

We reserve the right to amend this Policy at our discretion and at any time. When we update this Policy, we will indicate when it was most recently updated by changing the last updated date. Unless otherwise indicated, updates to this Policy are effective immediately upon posting. If we make material changes to this Policy, we may notify you by email or through a notice on our website homepage.

 

Contact Information

If you have any questions or comments about this Policy, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California Privacy Law, please do not hesitate to contact us via email at info@seefunge.com.

 

If you are a California Resident, are under 18 and are a registered user of the Services, you may contact us by using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy to remove content or information that you have posted to the Services. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, if you posted in a public forum, like social media, some of your content may have been reposted by another user.

 

November 15, 2024