Privacy Policy - CBT Tools Online

Last updated March 25, 2023

This privacy notice for OurOpenMedia (“Company,” “we,” “us,” or “our”),

describes how and why we might collect, store, use, and/or share (“process”) your

information when you use our services (“Services”), such as when you:

<ul>

<li style=”font-weight: 400;” aria-level=”1″>Visit our website at cbttoolsonline.com, or any website of ours that links</li>

<li style=”font-weight: 400;” aria-level=”1″>to this privacy notice</li>

<li style=”font-weight: 400;” aria-level=”1″>Engage with us in other related ways, including any sales, marketing, or</li>

<li style=”font-weight: 400;” aria-level=”1″>events</li>

</ul>

Reading this privacy notice will help you understand your

privacy rights and choices. If you do not agree with our policies and practices, please

do not use our Services. If you still have any questions or concerns, please contact

us at our contact page (/contact).

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice. You can find

out more details about any of these topics by using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our

Services, we may process personal information depending on how you interact with

OurOpenMedia and the Services, the choices you make, and the products and

features you use.

Do we process any sensitive personal information? We do not process sensitive

personal information.

Do we receive any information from third parties? We do not receive any

information from third parties.

How do we process your information? We process your information to provide,

improve, and administer our Services, communicate with you, for security and fraud

prevention, and to comply with law. We may also process your information for other

purposes with your consent. We process your information only when we have a valid

legal reason to do so.

In what situations and with which types of parties do we share personal

information? We may share information in specific situations and with specific

categories of third parties.

How do we keep your information safe? We have organizational and technical

processes and procedures in place to protect your personal information. However, no

electronic transmission over the internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the

applicable privacy law may mean you have certain rights regarding your personal

information.

How do you exercise your rights? The easiest way to exercise your rights is by

filling out our data subject request form available through our contact page (/contact), or

by contacting us. We will consider and act upon any request in accordance with

applicable data protection laws.

TABLE OF CONTENTS

<ol>

<li> WHAT INFORMATION DO WE COLLECT?</li>

<li> HOW DO WE PROCESS YOUR INFORMATION?</li>

<li> WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL</li>

</ol>

INFORMATION?

<li> WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?</li>

<li> WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?</li>

<li> DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?</li>

<li> IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?</li>

<li> HOW LONG DO WE KEEP YOUR INFORMATION?</li>

<li> HOW DO WE KEEP YOUR INFORMATION SAFE?</li>

<li> DO WE COLLECT INFORMATION FROM MINORS?</li>

<li> WHAT ARE YOUR PRIVACY RIGHTS?</li>

<li> CONTROLS FOR DO-NOT-TRACK FEATURES</li>

<li> DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?</li>

<li> DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?</li>

<li> DO WE MAKE UPDATES TO THIS NOTICE?</li>

<li> HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</li>

<li> HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT</li>

</ol>

FROM YOU?

<ol>

<li> WHAT INFORMATION DO WE COLLECT?</li>

</ol>

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express

an interest in obtaining information about us or our products and Services, when you

participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect

depends on the context of your interactions with us and the Services, the choices you

make, and the products and features you use. The personal information we collect

may include the following:

names

email addresses

mailing addresses

usernames

passwords

contact preferences

contact or authentication data

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate,

and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or

browser and device characteristics — is collected automatically when you visit our

Services.

We automatically collect certain information when you visit, use, or navigate the

Services. This information does not reveal your specific identity (like your name or

contact information) but may include device and usage information, such as your IP

address, browser and device characteristics, operating system, language

preferences, referring URLs, device name, country, location, information about how

and when you use our Services, and other technical information. This information is

primarily needed to maintain the security and operation of our Services, and for our

internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar

technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic,

usage, and performance information our servers automatically collect when

you access or use our Services and which we record in log files. Depending on

how you interact with us, this log data may include your IP address, device

information, browser type, and settings and information about your activity in

the Services (such as the date/time stamps associated with your usage, pages

and files viewed, searches, and other actions you take such as which features

you use), device event information (such as system activity, error reports

(sometimes called “crash dumps”), and hardware settings).

Device Data. We collect device data such as information about your computer,

phone, tablet, or other device you use to access the Services. Depending on

the device used, this device data may include information such as your IP

address (or proxy server), device and application identification numbers,

location, browser type, hardware model, Internet service provider and/or

mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your

device’s location, which can be either precise or imprecise. How much

information we collect depends on the type and settings of the device you use

to access the Services. For example, we may use GPS and other technologies

to collect geolocation data that tells us your current location (based on your IP

address). You can opt out of allowing us to collect this information either by

refusing access to the information or by disabling your Location setting on your

device. However, if you choose to opt out, you may not be able to use certain

aspects of the Services.

<li> HOW DO WE PROCESS YOUR INFORMATION?</li>

</ol>

In Short: We process your information to provide, improve, and administer our

Services, communicate with you, for security and fraud prevention, and to comply

with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on

how you interact with our Services, including:

To deliver and facilitate delivery of services to the user. We may process

your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your

information to respond to your inquiries and solve any potential issues you

might have with the requested service.

To send administrative information to you. We may process your

information to send you details about our products and services, changes to

our terms and policies, and other similar information.

To save or protect an individual’s vital interest. We may process your

information when necessary to save or protect an individual’s vital interest,

such as to prevent harm.

<li> WHAT LEGAL BASES DO WE RELY ON TO PROCESS</li>

</ol>

YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary

and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like

with your consent, to comply with laws, to provide you with services to enter into or

fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate

business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain

the valid legal bases we rely on in order to process your personal information. As

such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission

(i.e., consent) to use your personal information for a specific purpose. You can

withdraw your consent at any time.

Performance of a Contract. We may process your personal information when

we believe it is necessary to fulfill our contractual obligations to you, including

providing our Services or at your request prior to entering into a contract with

you.

Legal Obligations. We may process your information where we believe it is

necessary for compliance with our legal obligations, such as to cooperate with

a law enforcement body or regulatory agency, exercise or defend our legal

rights, or disclose your information as evidence in litigation in which we are

involved.

Vital Interests. We may process your information where we believe it is

necessary to protect your vital interests or the vital interests of a third party,

such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e.,

express consent) to use your personal information for a specific purpose, or in

situations where your permission can be inferred (i.e., implied consent). You can

withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to

process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be

obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to

assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next

of kin

If we have reasonable grounds to believe an individual has been, is, or may be

victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise

the availability or the accuracy of the information and the collection is

reasonable for purposes related to investigating a breach of an agreement or a

contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or

rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business,

or profession and the collection is consistent with the purposes for which the

information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

<li> WHEN AND WITH WHOM DO WE SHARE YOUR</li>

</ol>

PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section

and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share

your data with third-party vendors, service providers, contractors, or agents (“third

parties”) who perform services for us or on our behalf and require access to such

information to do that work. The categories of third parties we may share personal

information with are as follows:

Ad Networks

Affiliate Marketing Programs

Cloud Computing Services

Communication & Collaboration Tools

Data Analytics Services

Data Storage Service Providers

Performance Monitoring Tools

Retargeting Platforms

Sales & Marketing Tools

Social Networks

User Account Registration & Authentication Services

Website Hosting Service Providers

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection

with, or during negotiations of, any merger, sale of company assets, financing,

or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we

will require those affiliates to honor this privacy notice. Affiliates include our

parent company and any subsidiaries, joint venture partners, or other

companies that we control or that are under common control with us.

Business Partners. We may share your information with our business

partners to offer you certain products, services, or promotions.

<li> WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?</li>

</ol>

In Short: We are not responsible for the safety of any information that you share with

third parties that we may link to or who advertise on our Services, but are not

affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications

and/or contain advertisements from third parties that are not affiliated with us and

which may link to other websites, services, or applications. Accordingly, we do not

make any guarantee regarding any such third parties, and we will not be liable for

any loss or damage caused by the use of such third-party websites, services, or

applications. The inclusion of a link towards a third-party website, service, or

application does not imply an endorsement by us. We cannot guarantee the safety

and privacy of data you provide to any third parties. Any data collected by third

parties is not covered by this privacy notice. We are not responsible for the content or

privacy and security practices and policies of any third parties, including other

websites, services, or applications that may be linked to or from the Services. You

should review the policies of such third parties and contact them directly to respond

to your questions.

<li> DO WE USE COOKIES AND OTHER TRACKING</li>

</ol>

TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store

your information.

We may use cookies and similar tracking technologies (like web beacons and pixels)

to access or store information. Specific information about how we use such

technologies and how you can refuse certain cookies is set out in our Cookie Notice.

<li> IS YOUR INFORMATION TRANSFERRED</li>

</ol>

INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other

than your own.

Our servers are located in the United States. If you are accessing our Services from

outside the United States, please be aware that your information may be transferred

to, stored, and processed by us in our facilities and by those third parties with whom

we may share your personal information (see “WHEN AND WITH WHOM DO WE

SHARE YOUR PERSONAL INFORMATION?” above), in the United States, and

other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK),

then these countries may not necessarily have data protection laws or other similar

laws as comprehensive as those in your country. However, we will take all necessary

measures to protect your personal information in accordance with this privacy notice

and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by

using the European Commission’s Standard Contractual Clauses for transfers of

personal information between our group companies and between us and our third-

party providers. These clauses require all recipients to protect all personal

information that they process originating from the EEA or UK in accordance with

European data protection laws and regulations. Our Standard Contractual Clauses

can be provided upon request. We have implemented similar appropriate safeguards

with our third-party service providers and partners and further details can be provided

upon request.

<li> HOW LONG DO WE KEEP YOUR INFORMATION?</li>

</ol>

In Short: We keep your information for as long as necessary to fulfill the purposes

outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the

purposes set out in this privacy notice, unless a longer retention period is required or

permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymize such information, or, if this is not

possible (for example, because your personal information has been stored in backup

archives), then we will securely store your personal information and isolate it from

any further processing until deletion is possible.

<li> HOW DO WE KEEP YOUR INFORMATION SAFE?</li>

</ol>

In Short: We aim to protect your personal information through a system of

organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational

security measures designed to protect the security of any personal information we

process. However, despite our safeguards and efforts to secure your information, no

electronic transmission over the Internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Although

we will do our best to protect your personal information, transmission of personal

information to and from our Services is at your own risk. You should only access the

Services within a secure environment.

<li> DO WE COLLECT INFORMATION FROM MINORS?</li>

</ol>

In Short: We do not knowingly collect data from or market to children under 18 years

of age.

We do not knowingly solicit data from or market to children under 18 years of age. By

using the Services, you represent that you are at least 18 or that you are the parent

or guardian of such a minor and consent to such minor dependent’s use of the

Services. If we learn that personal information from users less than 18 years of age

has been collected, we will deactivate the account and take reasonable measures to

promptly delete such data from our records. If you become aware of any data we

may have collected from children under age 18, please contact us at

our contact page (/contact).

<li> WHAT ARE YOUR PRIVACY RIGHTS?</li>

</ol>

In Short: In some regions, such as the European Economic Area (EEA), United

Kingdom (UK), and Canada, you have rights that allow you greater access to and

control over your personal information. You may review, change, or terminate your

account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under

applicable data protection laws. These may include the right (i) to request access and

obtain a copy of your personal information, (ii) to request rectification or erasure; (iii)

to restrict the processing of your personal information; and (iv) if applicable, to data

portability. In certain circumstances, you may also have the right to object to the

processing of your personal information. You can make such a request by contacting

us by using the contact details provided in the section “HOW CAN YOU CONTACT

US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data

protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing

your personal information, you also have the right to complain to your local data

protection supervisory authority. You can find their contact details here:

https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities

are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your

personal information, which may be express and/or implied consent depending on

the applicable law, you have the right to withdraw your consent at any time. You can

withdraw your consent at any time by contacting us by using the contact details

provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

below.

However, please note that this will not affect the lawfulness of the processing before

its withdrawal nor, when applicable law allows, will it affect the processing of your

personal information conducted in reliance on lawful processing grounds other than

consent.

Opting out of marketing and promotional communications: You can unsubscribe

from our marketing and promotional communications at any time by clicking on the

unsubscribe link in the emails that we send, or by contacting us using the details

provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

below. You will then be removed from the marketing lists. However, we may still

communicate with you — for example, to send you service-related messages that are

necessary for the administration and use of your account, to respond to service

requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies

by default. If you prefer, you can usually choose to set your browser to remove

cookies and to reject cookies. If you choose to remove cookies or reject cookies, this

could affect certain features or services of our Services. To opt out of interest-based

advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at

our contact page (/contact).

<li> CONTROLS FOR DO-NOT-TRACK FEATURES</li>

</ol>

Most web browsers and some mobile operating systems and mobile applications

include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your

privacy preference not to have data about your online browsing activities monitored

and collected. At this stage no uniform technology standard for recognizing and

implementing DNT signals has been finalized. As such, we do not currently respond

to DNT browser signals or any other mechanism that automatically communicates

your choice not to be tracked online. If a standard for online tracking is adopted that

we must follow in the future, we will inform you about that practice in a revised

version of this privacy notice.

<li> DO CALIFORNIA RESIDENTS HAVE SPECIFIC</li>

</ol>

PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights

regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law,

permits our users who are California residents to request and obtain from us, once a

year and free of charge, information about categories of personal information (if any)

we disclosed to third parties for direct marketing purposes and the names and

addresses of all third parties with which we shared personal information in the

immediately preceding calendar year. If you are a California resident and would like

to make such a request, please submit your request in writing to us using the contact

information provided below.

If you are under 18 years of age, reside in California, and have a registered account

with Services, you have the right to request removal of unwanted data that you

publicly post on the Services. To request removal of such data, please contact us

using the contact information provided below and include the email address

associated with your account and a statement that you reside in California. We will

make sure the data is not publicly displayed on the Services, but please be aware

that the data may not be completely or comprehensively removed from all our

systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or

transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the

State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and

obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve

(12) months:

Category Examples Collected

<ol>

<li> Identifiers</li>

</ol>

Contact details, such as real name, alias,

postal address, telephone or mobile

contact number, unique personal identifier,

online identifier, Internet Protocol address,

email address, and account name

YES

<ol>

<li> Personal information</li>

</ol>

categories listed in the

California Customer

Records statute

Name, contact information, education,

employment, employment history, and

financial information

NO

<ol>

<li> Protected classification</li>

</ol>

characteristics under

California or federal law

Gender and date of birth NO

<ol>

<li> Commercial information</li>

</ol>

Transaction information, purchase history,

financial details, and payment information

YES

<ol>

<li> Biometric information Fingerprints and voiceprints NO</li>

</ol>

<ol>

<li> Internet or other similar</li>

</ol>

network activity

Browsing history, search history, online

behavior, interest data, and interactions

with our and other websites, applications,

systems, and advertisements

YES

<ol>

<li> Geolocation data Device location YES</li>

<li> Audio, electronic, visual,</li>

</ol>

thermal, olfactory, or similar

information

Images and audio, video or call recordings

created in connection with our business

activities

NO

<ol>

<li> Professional or</li>

</ol>

employment-related

information

Business contact details in order to

provide you our Services at a business

level or job title, work history, and

professional qualifications if you apply for

a job with us

NO

<ol>

<li> Education Information Student records and directory information NO</li>

</ol>

<ol>

<li> Inferences drawn from</li>

</ol>

other personal information

Inferences drawn from any of the collected

personal information listed above to create

a profile or summary about, for example,

an individual’s preferences and

characteristics

YES

<ol>

<li> Sensitive Personal</li>

</ol>

Information NO

We will use and retain the collected personal information as needed to provide the

Services or for:

Category A – As long as the user has an account with us

Category D – 1 year

Category F – 1 year

Category G – 1 year

Category K – As long as the user has an account with us

We may also collect other personal information outside of these categories through

instances where you interact with us in person, online, or by phone or mail in the

context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

OurOpenMedia collects and shares your personal information through:

Targeting cookies/Marketing cookies

Social media cookies

Beacons/Pixels/Tags

Click redirects: Online Therapy Affiliate Programs.

Social media plugins: Facebook, Instagram, Twitter. We use social media

features, such as a “Like” button, and widgets, such as a “Share” button, in our

Services. Such features may process your Internet Protocol (IP) address and

track which page you are visiting on our website. We may place a cookie to

enable the feature to work correctly. If you are logged in on a certain social

media platform and you interact with a widget or button belonging to that social

media platform, this information may be recorded to your profile of such social

media platform. To avoid this, you should log out from that social media

platform before accessing or using the Services. Social media features and

widgets may be hosted by a third party or hosted directly on our Services. Your

interactions with these features are governed by the privacy notices of the

companies that provide them. By clicking on one of these buttons, you agree

to the use of this plugin and consequently the transfer of personal information

to the corresponding social media service. We have no control over the

essence and extent of these transmitted data or their additional processing.

More information about our data collection and sharing practices can be found in this

privacy notice.

You can opt out from the selling or sharing of your personal information by disabling

cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My

Personal Information link on our homepage.

You may contact us by visiting our contact page (/contact), or by referring to the

contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a

request if the authorized agent does not submit proof that they have been validly

authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a

written contract between us and each service provider. Each service provider is a for-

profit entity that processes the information on our behalf, following the same strict

privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for

undertaking internal research for technological development and demonstration. This

is not considered to be “selling” of your personal information.

OurOpenMedia has disclosed the following categories of personal information

to third parties for a business or commercial purpose in the preceding twelve (12)

months:

The categories of third parties to whom we disclosed personal information for a

business or commercial purpose can be found under “WHEN AND WITH WHOM DO

WE SHARE YOUR PERSONAL INFORMATION?”.

OurOpenMedia has sold or shared the following categories of personal

information to third parties in the preceding twelve (12) months:

The categories of third parties to whom we sold personal information are:

The categories of third parties to whom we shared personal information with are:

Ad Networks

Affiliate Marketing Programs

Data Analytics Services

Retargeting Platforms

Social Networks

User Account Registration & Authentication Services

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your

personal information, we will respect your request and delete your personal

information, subject to certain exceptions provided by law, such as (but not limited to)

the exercise by another consumer of his or her right to free speech, our compliance

requirements resulting from a legal obligation, or any processing that may be

required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or disclosed for a

business purpose;

the categories of third parties to whom the personal information was sold,

shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal

information; and

the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete

consumer information that is de-identified in response to a consumer request or to re-

identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer’s sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are

the same person about whom we have the information in our system. These

verification efforts require us to ask you to provide information so that we can match it

with information you have previously provided us. For instance, depending on the

type of request you submit, we may ask you to provide certain information so that we

can match the information you provide with the information we already have on file,

or we may contact you through a communication method (e.g., phone or email) that

you have previously provided to us. We may also use other verification methods as

the circumstances dictate.

We will only use personal information provided in your request to verify your identity

or authority to make the request. To the extent possible, we will avoid requesting

additional information from you for the purposes of verification. However, if we cannot

verify your identity from the information already maintained by us, we may request

that you provide additional information for the purposes of verifying your identity and

for security or fraud-prevention purposes. We will delete such additionally provided

information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer

relevant, or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on

your behalf. We may deny a request from an authorized agent that does not

submit proof that they have been validly authorized to act on your behalf in

accordance with the CCPA.

To exercise these rights, you can contact us by visiting our contact page (/contact), or

by referring to the contact details at the bottom of this document. If you have a

complaint about how we handle your data, we would like to hear from you.

<li> DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY</li>

</ol>

RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights

regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

”Consumer” means a natural person who is a resident of the Commonwealth acting

only in an individual or household context. It does not include a natural person acting

in a commercial or employment context.

”Personal data” means any information that is linked or reasonably linkable to an

identified or identifiable natural person. “Personal data” does not include de-identified

data or publicly available information.

”Sale of personal data” means the exchange of personal data for monetary

consideration.

If this definition “consumer” applies to you, we must adhere to certain rights and

obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how

you interact with OurOpenMedia and our Services. To find out more, please visit

the following links:

Personal data we collect

How we use your personal data

When and with whom we share your personal data

Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising, the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects (“profiling”)

OurOpenMedia has not sold any personal data to third parties for business or

commercial purposes. OurOpenMedia will not sell personal data in the future

belonging to website visitors, users, and other consumers.

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this

privacy notice.

You may contact us by email at our contact page (/contact), by visiting

our contact page (/contact), or by referring to the contact details at the bottom of this

document.

If you are using an authorized agent to exercise your rights, we may deny a request if

the authorized agent does not submit proof that they have been validly authorized to

act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to

verify you and your consumer’s request. If you submit the request through an

authorized agent, we may need to collect additional information to verify your identity

before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases,

within forty-five (45) days of receipt. The response period may be extended once by

forty-five (45) additional days when reasonably necessary. We will inform you of any

such extension within the initial 45-day response period, together with the reason for

the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision

and reasoning behind it. If you wish to appeal our decision, please email us at

our contact page (/contact). Within sixty (60) days of receipt of an appeal, we will

inform you in writing of any action taken or not taken in response to the appeal,

including a written explanation of the reasons for the decisions. If your appeal if

denied, you may contact the Attorney General to submit a complaint.

<li> DO WE MAKE UPDATES TO THIS NOTICE?</li>

</ol>

In Short: Yes, we will update this notice as necessary to stay compliant with relevant

laws.

We may update this privacy notice from time to time. The updated version will be

indicated by an updated “Revised” date and the updated version will be effective as

soon as it is accessible. If we make material changes to this privacy notice, we may

notify you either by prominently posting a notice of such changes or by directly

sending you a notification. We encourage you to review this privacy notice frequently

to be informed of how we are protecting your information.

<li> HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</li>

</ol>

If you have questions or comments about this notice, you may contact our Data

Protection Officer (DPO) ,S.M, by email at our contact page (/contact)

OurOpenMedia

233 West 1st St

North Vancouver, BC

<li> HOW CAN YOU REVIEW, UPDATE, OR DELETE THE</li>

</ol>

DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request

access to the personal information we collect from you, change that information, or

delete it. To request to review, update, or delete your personal information, please

visit our contact page (/contact).