Privacy Policy
Last Updated: 09/08/2023
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237 Global (“we” or “us”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we or our third-party service providers collect through the App.
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This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party, including Facebook, Inc., Apple Inc., Google Inc., Microsoft Corp., Blackberry, any wireless carriers, or any third party operating any site or property to which the App contains a link. In addition, the inclusion of a link within the App does not imply endorsement of, or affiliation with, the linked site or property by us. Please note that the App may offer the ability to access and submit (including, for example, via a third-party software application or service) certain information directly to third parties, such as Facebook, or to an application platform, such as Apple’s App Store or Google Play. Such information is submitted by you directly to such third parties, and this Privacy Policy does not apply to any such information.
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If you are a California resident, please see the “Additional Information Regarding California” section at the end of this Privacy Policy for further information on our collection and use of your personal information.
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UPDATES TO THIS PRIVACY POLICY
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We may change this Privacy Policy at any time. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we make the revised Privacy Policy available within or through the App.
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PERSONAL INFORMATION
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“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including, for example:
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Name
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Address
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Telephone number
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Email address
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Credit and debit card number
We may use a third-party payment service to process payments made through the App. If you wish to make a payment through the App, your Personal Information may be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.
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How We May Collect Personal Information
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We and our service providers collect Personal Information in a variety of ways, including:
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Through the App: We collect Personal Information through the App, such as when you register or make a purchase.
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Offline: We collect Personal Information from you offline, such as when you place an order over the phone or contact customer service.
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From Other Sources: We receive your Personal Information from other sources, such as companies from which you have purchased tickets, products or services that we fulfill; public databases; joint marketing partners; social media platforms; and other third parties.
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We need to collect Personal Information in order to provide the requested products and services to you. If you do not provide the information requested, we may not be able to provide the App or our products or services. If you submit any Personal Information relating to other people to us or to our service providers in connection with the App, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
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Use of Personal Information
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We and our service providers use Personal Information for our legitimate business purposes, including:
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Providing the functionality of the App and fulfilling your requests.
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To respond to your inquiries and fulfill your requests, when you contact us or our service provider via one of our online forms or otherwise, for example, when you send us questions, or when you request information about our products and services.
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To send you administrative information, including information regarding the App and changes to our terms, conditions and policies.
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To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
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To allow you to send messages (for example, music clips or information about us) to a friend through the App, if you choose to do so.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials.
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To send you marketing related push notifications, emails, and text messages, with information about our services, products and other news about us.
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We will engage in this activity with your consent (if required by applicable law) or where we have a legitimate interest.
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Analysis of Personal Information for business reporting and providing personalized services.
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To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so that we can improve the App.
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To better understand you, so that we can personalize our interactions with you and your experience on the App, including by presenting information, content, products and offers tailored to your interests.
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We will provide personalized services either with your consent or because we have a legitimate interest.
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Allowing you to participate in sweepstakes, contests or other promotions.
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We may offer you the opportunity to participate in sweepstakes, contests and other promotions. Some of these activities have additional rules with information about how we use and disclose your Personal Information.
We use this information to manage our contractual relationship with you. Aggregating and/or anonymizing Personal Information.
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We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
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Accomplishing our business purposes.
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For data analysis, for example, to improve the efficiency of the App.
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For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
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For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
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For developing new products and services.
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For enhancing, improving or modifying our current products and services.
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For identifying usage trends.
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For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
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For operating and expanding our business activities, for example, understanding which parts of the App are of most interest to our users so we can focus our energies on meeting our users’ interests.
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We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation and/or because we have a legitimate interest.
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Disclosure of Personal Information
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We disclose Personal Information:
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To our third-party service providers, to facilitate services they provide to us. These can include providers of services such as app development and operation, hosting, data analysis, payment processing, order fulfillment, information technology and infrastructure provision, customer service, email delivery, auditing and other services.
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To third parties, to permit them to send marketing communications to you, consistent with your choices.
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To third parties that sponsor contests, sweepstakes and similar promotions.
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By using the App, you may elect to disclose Personal Information.
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To anyone to whom you send messages on or through the App.
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On message boards, chat, profile pages, blogs and other services to which you are able to post information and materials. Please note that any information and materials that you post or disclose on or through the App may be available to other App users and to the general public and may be redistributed through the Internet and other media channels where they will reach an even broader audience. Additionally, please note that, per our Terms of Use, we retain certain rights in the information and materials that you post on or through the App, and we may use and disclose such information and materials (including any Personal Information included therein) in accordance with our Terms of Use. We urge you to be very careful when deciding to disclose information on or through the App. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF ANY INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH THE APP.
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Other Uses and Disclosures
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We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
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To comply with applicable law and regulations, including laws outside your country of residence.
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To cooperate with public and government authorities, to respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.
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To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide information we believe is important.
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For other legal reasons.
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To enforce our terms and conditions.
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To protect our rights, privacy, safety or property and/or that of our affiliates, our service providers, you or others.
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In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding). Such third parties may include, for example, an acquiring entity and its advisors.
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Sensitive Information
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Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise to us.
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OTHER INFORMATION
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“Other Information” is information that does not reveal your specific identity or does not directly relate to an identifiable individual. We and our third-party service providers may collect Other Information, such as:
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Usage information
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Geographic location information
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Demographic and other information provided by you
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If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.
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How We Collect Other Information
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We and our service providers collect Other Information in a variety of ways, including:
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Through your use of the App: When you download and use the App, we may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App. We also collect information about how you interact with the App. For example, we may use analytic tools to help us better serve you through improved products, services and revisions to the App. This information may let us know which services and features you are using the most within the App, as well as device type and hardware features, country and language of download, and other usage information.
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Geographic location information: If you use any location-enabled products or services, you may be sending us location information. When you use a location-enabled service, we may collect and process information about your precise geographical location, such as GPS signals. We use your device’s physical location to provide you with personalized location-based services, content and advertisements. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, we may not be able to provide you with the applicable personalized services and content.
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From you: We may collect demographic and other information, such as your age or gender, when you voluntarily provide it to us. Unless combined with Personal Information, this information does not personally identify you.
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Uses and Disclosures of Other Information
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We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. We may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
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SECURITY
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We seek to use reasonable physical, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
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CHILDREN
The App is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16) through the App.
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JURISDICTION AND CROSS-BORDER TRANSFER
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Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the App, you understand that you are transferring your information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security agencies in those other countries may be entitled to access your Personal Information.
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CHOICES AND ACCESS
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Your choices regarding our use and disclosure of your Personal Information
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We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
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Receiving marketing-related emails from us: If you do not want to receive marketing-related emails from us on a going-forward basis, you may opt-out by using the unsubscribe mechanism provided in the email.
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Receiving push notifications from us: If you do not want to receive push notifications from us, you may opt out using your device settings.
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Receiving text messages from us: If you do not want to receive text messages from us on a going-forward basis, you may reply “STOP” to any such message in order to opt-out of receiving similar such messages.
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Our sharing of your Personal Information with third parties for their marketing purposes: If you prefer that we not share your Personal Information on a going-forward basis with third parties for their marketing purposes, you may opt-out from such sharing by emailing us at info@237global.com.
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We will try to comply with your request(s) as soon as reasonably practicable. Please note that, if you opt out from receiving marketing-related messages from us, we may still send administrative messages to you, from which you cannot opt out.
How you can request to access, change or delete your Personal Information and Posted Content
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If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us or content you have previously posted on the App, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you
may contact our service provider at datarequests@237global.com. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Privacy Policy for more information about the requests you may make under California law.
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In your request, please make clear what Personal Information or posted content you would like to have changed or removed, or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. We may need to retain certain information or content for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
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If you request that we remove posted content or information, please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
RETENTION PERIOD
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We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (1) the length of time we have an ongoing relationship with you and provide the App to you (for example, for as long as you have an account with us or keep using the App); (2) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time); and (3) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
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CONTACTING US
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237 Global is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at
32 West 22nd Street New York, NY 10010 info@237global.com
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Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.
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FOR NEVADA RESIDENTS
We do not sell Covered Information as defined under Nevada law. If you would like to make any inquiry regarding the sale of your Covered Information, please contact datarequests@237global.com.
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ADDITIONAL INFORMATION REGARDING CALIFORNIA
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Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed for a business purpose within the preceding 12 months:
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(1) We collected the following categories of Personal Information:
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Identifiers, such as name, address, account name and IP address;
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Personal information, as defined in the California safeguards law, such as contact information and financial information;
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Commercial information, such as transaction information and purchase history;
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Internet or network activity information, such as browsing history and interactions with our website;
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Geolocation data, such as device location;
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Audio, electronic, visual and similar information, such as call and video recordings; and
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Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
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(2) As described above, we collect this Personal Information from you as well as from other categories of sources, such as companies from which you have purchased tickets, products, or services that we fulfill, public databases, joint marketing partners, and social media platforms. As also described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.
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(3) We disclosed the following Personal Information to third parties, such as our service providers and business partners, for our operational business purposes:
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Identifiers, such as name, address, account name and IP address;
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Personal information, as defined in the California safeguards law, such as contact information and financial information;
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Commercial information, such as transaction information and purchase history;
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Internet or network activity information, such as browsing history and interactions with our website;
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Geolocation data, such as device location;
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Audio, electronic, visual and similar information, such as call and video recordings; and
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Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an
individual’s preferences and characteristics.
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We have not sold Personal Information for purposes of the CCPA. For purposes of this section (“Additional Information Regarding California”) of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business
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(4) If you are a California resident, you may request that we:
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(A) Disclose to you the following information covering the 12 months preceding your request, pursuant to our obligations under the CCPA:
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The categories of Personal Information we collected about you and the categories of sources from which we collected such
Personal Information;
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The specific pieces of Personal Information we collected about you;
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The business or commercial purpose for collecting Personal Information about you; and
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The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
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(B) Delete Personal Information we collected from you.
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To make a request for the disclosures or deletion described above, please contact us at datarequests@237global.com. We will respond to your request consistent with applicable law.
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You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
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ADDITIONAL INFORMATION REGARDING THE EEA
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You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.