Ninja Miles Privacy Policy

Sango technologies, Inc. (hereinafter referred to as "Our Company") will handle Your personal data obtained in connection with the use of the Service in accordance with the following "Ninja Miles Privacy Policy". Note that if You agree any matters individually in connection with the use of the Service (hereinafter referred to as "separate agreements"), such separate agreements shall take precedence over this privacy policy.

Article 1 (Interpretation and Definitions)

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
1. Account means a unique account created for You to access our Service or parts of our Service.
2. Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
3. Application refers to Ninja Miles, the software program provided by the Company.
4. Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal data and determines the purposes and means of the processing of Consumers' personal data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal data, that does business in the State of California.
5. CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
6. Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Sango technologies, Inc., 3-20-2 Tamagawa, Setagaya, Tokyo, Japan.
7. For the purpose of the GDPR, the Company shall be the Data Controller.
8. Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
9. Country refers to: Japan
10. Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
11. Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
12. Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
13. GDPR refers to EU General Data Protection Regulation.
14. Personal Data is any information that relates to an identified or identifiable individual.
15. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
16. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
17. Service refers to the Application.
18. Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
19. Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
20. Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
21. You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
22. Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Article 2 (Handling of Your Personal Data)

When You download this application, the personal data You input at the application software download site specified in the following items will be managed by the operator specified in each item (hereinafter referred to as the "Site Operator"). Any doubts or disputes regarding the personal data will be resolved between you and the Site Operator, and You shall not make any claims or complaints against Our Company. Even if you suffer damages as a result of the Site Operator disclosing or providing the personal data to a third party, Our Company shall not be liable for any compensation.
1. "Google Play" is a website operated by Google for smartphones and tablets with Android OS: Google LLC
2. "AppStore" is a website operated by Apple for iOS smartphones and tablets: Apple Inc.
Apart from personal data entered at the download site for the application software specified in each item of the preceding paragraph, You agree that your personal data acquired by Our Company in the course of using the Service will be handled in accordance with Our Company's Personal Data Protection Policy and this Privacy Policy.
Personal data includes the following information:
1. Email address (excluding the email address specified in the next paragraph)
2. Email address and icon information You use when logging in to external services
3. Identifiers (codes that identify customers, advertising identifiers such as IDFA and AAID [Note 1], and identifiers that are irreversibly converted from email addresses or phone numbers)
4. Keyboard input information (including the number of characters entered and other input information; the same applies below)
5. Browsing History Information
6. Information that You voluntarily provide in response to surveys conducted within the Service (hereinafter referred to as "Survey Information") [Note 2]
7. Device information (including but not limited to SIM settings, currency, language, country)
8. Information regarding Your purchase of products and use of services through targeted advertising (product name, service name, quantity, number of uses, amount)
The purposes for which Our Company uses personal data are as follows:
1. To provide the Service and services within the Service that are appropriate for each users
2. To identify users
3. To distribute information regarding the Service
4. To respond to inquiries regarding the Service
5. For statistical understanding, market research, usage analysis, and creation of aggregated statistical data to enhance the Service
6. To maintain and improve the Service and to implement various campaigns and other promotional plans
7. To analyze personal data and deliver advertisements about products and services that meet Your needs and interests.
8. To plan, develop, consider, and provide new products and services for Our Company, Our affiliates, or partner businesses
9. To provide to third parties
10. To award points to customers who are eligible for points from the Service
11. To obtain purchase (transaction) history information from third parties when making purchases, contracts, or using services via the Service or using the functions within the Service application, and to use this information for the purposes set forth in the preceding paragraphs of this section after linking it with personal data
12. To receive identifiers (limited to advertising identifiers and identifiers related to email addresses) from third parties, match and analyze them with personal data, and then provide them to the third parties (note that in principle, this is limited to cases where it can be confirmed that the customer related to the identifier has agreed to the provision of the identifier to the third party).
Our Company will provide the following personal data to third parties (including advertising businesses, analysis businesses, other client businesses of our company, and businesses affiliated with our company) in writing or electronic data. Note that in the case in item 1, in principle, this will only be done if we can confirm that the customer related to the identifier has consented to the provision to the third party.
1. Identifiers (excluding identifiers related to telephone numbers)
2. Keyboard input information acquired by Our Company after the start of use of the Service and processed through a processing process specified by Our Company so that a specific individual cannot be identified
3. Browsing History Information
4. Survey information You provide after You start using the Service
5. Device Information
The personal data in each item of the preceding paragraph will be used for the following purposes in a manner that does not identify specific individuals by the third party, and may be provided to the third party's client companies. (Our purposes for using the personal data are as set out in Paragraph 4 of this Article.)
Purpose of Use:
1. Delivering advertisements based on Your needs and interests
2. Trade area analysis, behavioral analysis and other research and analysis
3. Provision of database products, data analysis tools, and other products and services provided by such third parties, distribution of information, distribution of advertisements, response to inquiries, or implementation of promotional projects
4. Compiling statistical data
5. Planning and development of new products and services
The personal information Our Company provides about You may be combined with personal data already held by the recipient.
Our Company collects browsing history information about the Application by customers using information collection modules provided by third parties as specified below. Accordingly, Our Company provides browsing history information to the providers of the information collection modules. These information collection modules collect browsing historical information without including any personally identifiable information, and the collected information is managed in accordance with the privacy policy and other regulations of the providers of the information collection modules as specified in each item. In addition, we may collect personal data in a manner that is not easily noticeable to the individual. To ensure the security of the Application, improve usability, manage sessions, Our Company collects and transmits externally information about users' location information, access logs, and cookies.
1. AppsFlyer（AppsFlyer Inc.）：https://www.appsflyer.com/jp/services-privacy-policy
2. Applovin（AppLovin Corporation）：https://www.applovin.com/privacy-jp/
3. Unity Ads（Unity Technologies）：https://unity3d.com/legal/privacy-policy
4. Pangle（ByteDance Ltd.）：https://www.pangleglobal.com/jp/privacy
5. Liftoff（Liftoff, Inc.）：https://vungle.com/privacy/
6. Mintegral（Mintegral International Limited）：https://www.mintegral.com/jp/privacy/
7. LINE（LINE）：https://terms.line.me/line_rules_optimize?lang=ja
8. InMobi（InMobi）：https://www.inmobi.com/privacy-policy/
9. DT Exchange（DigitalTurbine）：https://www.fyber.com/privacy-policy/
10. AdMob（Google Japan G.K.）：https://www.google.com/adsense/new/localized-terms
11. Tapjoy（Tapjoy）：https://www.tapjoy.com/legal/general/privacy-policy/
12. Meta（Meta Platforms, Inc.）：https://business.facebook.com/policies_center/
13. Moloco（Moloco, Inc.）：https://www.moloco.com/privacy-policy
14. Mixpanel （Mixpanel, Inc.）：https://mixpanel.com/legal/privacy-policy/
In order to prevent the leakage, loss, or damage of personal data and to otherwise safely manage personal data, Our Company will take sufficient security measures, such as establishing handling regulations regarding safety management and establishing an implementation system, and will take appropriate measures to ensure the accuracy and currency of information necessary to achieve the intended use. In the unlikely event that a problem occurs, Our Company will promptly take appropriate corrective measures.
Our Company may outsource the handling of personal data within the scope of the purpose of use agreed upon under this Privacy Policy. In such cases, we will select a party that satisfies a sufficient level of protection for personal data, enter a contract with the outsourcing party that we deem appropriate, and provide appropriate supervision.
You may request the disclosure, notification of the purpose of use, correction, addition, deletion, suspension of use, erasure, disclosure of records of provision to third parties, suspension of provision to third parties (hereinafter referred to as "Disclosure") of Your personal data, and in this case, Our Company will promptly respond and take action in a manner designated by Our Company. Note that, depending on the item of personal data such as email address, the collection or use of such data is a prerequisite for providing the Application, and therefore Our Company will stop collecting such data only if you unsubscribe from the Application in a manner designated by Our Company. When requesting Disclosure, please contact Our Company's contact details set forth in Article 24.
Opt-out options regarding personal data are as follows:
1. You can opt out of the use of IDFA and AAID identifiers by accessing the following website from Your device.
  https://support.apple.com/ja-jp/HT202074
  https://support.google.com/googleplay/answer/3405269
2. You may change the settings of the Application so that You do not permit Our Company to obtain keyboard input information by performing the specified operations on the Application. Note that, if you do so, you will not be able to use some of the functions of the Application, such as being unable to add Miles by using the Application.
Notwithstanding the preceding paragraph, Our Company may provide personal data to a third party without Your consent in any of the following cases:
1. When there is a legal basis
2. When it is necessary for the protection of a person's life, body, or property and it is difficult to obtain the individual's consent
3. When it is particularly necessary for the improvement of public health or the promotion of healthy child development and it is difficult to obtain the individual's consent
4. When it is necessary to cooperate with a national government agency, local government, or a person commissioned by them in carrying out duties prescribed by law, and obtaining the individual's consent is likely to impede the performance of said duties
5. When requested to disclose personal data by a court, the public prosecutor's office, the police, or an agency with equivalent authority
It is entirely up to Your discretion whether or notYou provide Our Company with Your personal information. Note that if You do not provide Our Company with Your personal information, Our Company may not be able to provide You with some of Your desired services or activities.
[Note 1] An advertising identifier is a code used to identify the device You use when conducting targeted advertising. It is possible to identify the device You use, but it cannot identify You as an individual by itself.
IDFA (Identification for Advertisers): An identifier for Your device (iOS) issued by Apple Inc.
AAID (Advertising ID): An identifier for Your device (Android) issued by Google LLC.
[Note 2] For example, information considered to be collected may include date of birth (age), gender, marital status, family structure, whether or not You have children, the ages of Your children, occupation, job title, area of residence, type of housing, highest level of education, annual income, annual household income, hobbies, preferences, habits, lifestyle, and other similar items specified by Our Company.

We may process Personal Data under the following conditions:
1. Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
2. Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
3. Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
4. Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
5. Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
6. Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
1. Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
2. Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
3. Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
4. Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
5. Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
6. Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Article 6 (CCPA/CPRA Privacy Notice)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
1. Category A: Identifiers.
  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
  Collected: Yes.
2. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  Examples: 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.
  Collected: Yes.
3. Category C: Protected classification characteristics under California or federal law.
  Examples: 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).
  Collected: No.
4. Category D: Commercial information.
  Examples: Records and history of products or services purchased or considered.
  Collected: No.
5. Category E: Biometric information.
  Examples: 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.
  Collected: No.
6. Category F: Internet or other similar network activity.
  Examples: Interaction with our Service or advertisement.
  Collected: Yes.
7. Category G: Geolocation data.
  Examples: Approximate physical location.
  Collected: No.
8. Category H: Sensory data.
  Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
  Collected: No.
9. Category I: Professional or employment-related information.
  Examples: Current or past job history or performance evaluations.
  Collected: No.
10. Category 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)).
  Examples: 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.
  Collected: No.
11. Category K: Inferences drawn from other personal information.
  Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  Collected: No.
12. Category L: Sensitive personal information.
  Examples: Account login and password information, geolocation data.
  Collected: Yes.
13. Under CCPA/CPRA, personal information does not include:
  1. Publicly available information from government records
    1. Deidentified or aggregated consumer information
    2. Information excluded from the CCPA/CPRA's scope, such as:
      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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Article 7 (Use of Personal Information)

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
1. To operate our Service and provide You with Our Service.
2. To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
3. To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
4. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
5. As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
6. For internal administrative and auditing purposes.
7. To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
8. Other one-time uses.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Article 8 (Disclosure of Personal Information)

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
1. Category A: Identifiers
2. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
3. Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:
1. Service Providers
2. Our affiliates
3. Our business partners
4. Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Article 10 (Sale of Personal Information)

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
1. Category A: Identifiers
2. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
3. Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Article 11 (Sale of Personal Information of Minors Under 16 Years of Age)

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Article 12 (Your Rights under the CCPA/CPRA)

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
1. The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
2. The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your 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 purposes for collecting or selling that personal information
  4. The categories of third parties with whom We share that personal information
  5. The specific pieces of personal information We collected about You
  6. If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
    1. The categories of personal information categories sold
    2. The categories of personal information categories disclosed
3. The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Us.
4. The right to correct Personal Data. You have the right to correct or rectify any any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
5. The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.
6. The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your 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 et. 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.
7. The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
  1. Denying goods or services to You
  2. Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  3. Providing a different level or quality of goods or services to You
  4. Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Article 13 (Exercising Your CCPA/CPRA Data Protection Rights)

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:
1. By email: support@sango-tech.com
  Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
1. Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
2. 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 the required information if We cannot:
1. Verify Your identity or authority to make the request
2. And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Article 14 (Do Not Sell My Personal Information)

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use. If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Service to review your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.
1. The NAI's opt-out platform:http://www.networkadvertising.org/choices/
2. The EDAA's opt-out platformhttp://www.youronlinechoices.com/
3. The DAA's opt-out platform:http://optout.aboutads.info/?c=2\&lang=EN
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:
1. "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
2. "Limit Ad Tracking" on iOS devices
  You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Article 15 (Limit the Use or Disclosure of My Sensitive Personal Information)

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.

Article 16 ("Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA))

Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Article 17 (Your California Privacy Rights (California's Shine the Light law))

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

Article 18 (California Privacy Rights for Minor Users (California Business and Professions Code Section 22581))

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Article 19 (Children's Privacy)

The Service may contain content appropriate for children under the age of 13. As a parent, you should know that through the Service children under the age of 13 may participate in activities that involve the collection or use of personal information. We use reasonable efforts to ensure that before we collect any personal information from a child, the child's parent receives notice of and consents to our personal information practices.
We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these Users. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
We may ask a User to verify its date of birth before collecting any personal information from them. If the User is under the age of 13, the Service will be either blocked or redirected to a parental consent process.

Article 20 (Information Collected from Children Under the Age of 13)

The Company may collect and store persistent identifiers such as cookies or IP addresses from Children without parental consent for the purpose of supporting the internal operation of the Service.
We may collect and store other personal information about children if this information is submitted by a child with prior parent consent or by the parent or guardian of the child.
The Company may collect and store the following types of personal information about a child when submitted by a child with prior parental consent or by the parent or guardian of the child:
1. First and/or last name
2. Date of birth
3. Gender
4. Grade level
5. Email address
6. Telephone number
7. Parent's or guardian's name
8. Parent's or guardian's email address
For further details on the information We might collect, You can refer to the "Types of Data Collected" section of this Privacy Policy. We follow our standard Privacy Policy for the disclosure of personal information collected from and about children.

Article 21 (Parental Access)

A parent who has already given the Company permission to collect and use his child personal information can, at any time:
1. Review, correct or delete the child's personal information
2. Discontinue further collection or use of the child's personal information
To make such a request, You can write to Us using the contact information provided in this Privacy Policy.

Article 22 (Links to Other Websites)

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Article 23 (Changes to this Privacy Policy)

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. If You use the Service after this Privacy Policy has been changed, You will be deemed to have agreed to the change.

Article 24 (Contact Us)

If you have any questions about this Privacy Policy, You can contact us:

By email: support@sango-tech.com