Privacy Notice
CrunchLabs Privacy Notice
Last Updated: April 19, 2024
This Privacy Notice applies to the processing of personal information by CrunchLabs LLC (“CrunchLabs,” “we,” “us,” or “our”) including on our website available at crunchlabs.com and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”). For clarity, the Services include Build-a-Box and Hack Pack subscription packages.
Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”), please see Annex A – Supplemental CCPA Privacy Notice.
1. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.
2. PERSONAL INFORMATION WE COLLECT
We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.
A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.
- Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, and other information you store with your account.
- Photos and Video. We may collect personal information from you if choose to upload it in connection with your use of any of our photo or video features or other parts of the Services.
- Purchases. We may collect personal information and details associated with your purchases, including payment information, and mailing address. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details). We may also collect the names, birthdays and mailing addresses of recipients of your purchases if you choose to provide that information to us.
- Donations, Gifts and Sponsorships. We may collect personal information about users in need if you choose to submit suggestions identifying users or groups of users in need. We may also collect personal information about you if you choose to make a donation, gift or sponsorship on our site to send our Services to users in need.
- Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tools.
- Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., reviews and/or feedback of purchases you have made, messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.
B. Personal Information Collected Automatically
We may collect personal information automatically when you use the Services.
- Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
- Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
- Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
- -- Cookies. Cookies are small text files stored in device browsers.
- -- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
C. Personal Information Collected from Third Parties
We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others. We may also collect personal information from schools or educators about the students they purchase the Services for.
3. HOW WE USE PERSONAL INFORMATION
We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.
A. Provide the Services
We use personal information to fulfill our contract with you and provide the Services, such as:
- Managing your information;
- Providing access to certain areas, functionalities, and features of the Services;
- Answering requests for support;
- Communicating with you, including sending recipients of the Services birthday messages;
- Sharing personal information with third parties as needed to provide the Services;
- Processing your financial information and other payment methods for products and Services purchased;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
B. Administrative Purposes
We use personal information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Storing personal information on equipment on earth or outer space for our business purposes;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Carrying out analytics;
- Measuring interest and engagement in the Services;
- Improving, upgrading, or enhancing the Services;
- Developing new products and services;
- Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
- Debugging to identify and repair errors with the Services;
- Auditing relating to interactions, transactions, and other compliance activities;
- Enforcing our agreements and policies; and
- Carrying out activities that are required to comply with our legal obligations.
C. Marketing
We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.
Some of our marketing activities may be considered a “sale” or “targeted advertising” under applicable privacy laws.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent or Direction
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.
E. Automated Decision Making
We may engage in automated decision making, including profiling.
Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.
Services that include elements of automated decision-making include:
- Temporary blocklist of IP addresses associated with repeated failed transactions. This blocklist persists for a small number of hours.
- Temporary blocklist of credit cards associated with blocklisted IP addresses. This blocklist persists for a small number of days.
If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
4. HOW WE DISCLOSE PERSONAL INFORMATION
We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide the Services
We may disclose any of the personal information we collect to the categories of third parties described below.
- Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.
Some of the service providers we may use include:
- -- Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.
- -- Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.
- Other Users You Share or Interact With. The Services may allow CrunchLabs users to share personal information or interact with other users of the Services.
- Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology, such as Discord (each a “Third-Party Service”).
Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
- Affiliates. We may share your personal information with our corporate affiliates.
- Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”
Some of the advertising Technologies we may use include:
- -- Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are described below.
- Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).
- Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.
Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.
The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.
Please note you must separately opt out in each browser and on each device.
- Additional Opt-Out. If you have additional questions about our use of our personal information, you may contact us as set forth in “Contact Us” below.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
- Confirm Whether We Are Processing Your Personal Information;
- Request Access to or Portability of Your Personal Information;
- Request Correction of Your Personal Information;
- Request Deletion of Your Personal Information;
- Request Restriction of or Object to our Processing of Your Personal Information;
- Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and
- Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.
To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include [asking you to confirm the email address we have associated with you].
Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
All personal information processed by us may be transferred, processed, and stored anywhere in the world or outer space, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.
If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
7. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR
This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.
In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.
CrunchLabs’ processing of your personal information may be supported by one or more of the following lawful bases:
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Privacy Notice Section |
Lawful Basis: Performance of a Contract (i.e., to provide the Services to you) |
Lawful Basis: Legitimate Interest |
Lawful Basis: Consent |
Lawful Basis: For Compliance with Legal Obligations |
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Section 3A: Provide the Services |
✔ |
✔ |
✔ |
✔ |
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Section 3B: Administrative Purposes |
✔ |
✔ |
✔ |
✔ |
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Section 3C: Marketing |
✔ |
✔ |
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Section 3D: With Your Consent or Direction |
✔ |
✔ |
✔ |
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Section 3E: Automated Decision Making |
✔ |
✔ |
✔ |
✔ |
9. CHILDREN’S PERSONAL INFORMATION
Some features of the Services are intended for children. Thus, we may collect personal information that requires verifiable parental consent under the Children's Online Privacy Protection Act. For more details regarding our processing of personal information that we collect from children, please see our attached Supplemental Privacy Notice for Children.
10. THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
11. CONTACT US
CrunchLabs is the controller of the personal information we process under this Privacy Notice.
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: help@crunchlabs.com
Toll-Free Phone Number: 866-479-6623
ANNEX A – SUPPLEMENTAL CCPA PRIVACY NOTICE
This Supplemental CCPA Privacy Notice supplements our Privacy Notice and only applies to our processing of personal information that is subject to the CCPA.
NOTICE AT COLLECTION
At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.
- Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.
- Uses of Personal Information. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.
- Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? Yes. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. If we have previously “sold” personal information or “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “sell” or “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising’ for instructions on how to opt-out of these activities.
- How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
- Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA.
CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED
We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources.
OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, SOLD, AND/OR SHARED
The CCPA provides California residents with the right to know what categories of personal information CrunchLabs has collected about them, whether CrunchLabs disclosed that personal information for a business purpose (e.g., to a service provider), whether CrunchLabs “sold” that personal information, and whether CrunchLabs “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:
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Category of Personal Information Collected by CrunchLabs |
Category of Third Parties To Whom Personal Information is Disclosed to for a Business Purpose |
Category of Third Parties To Whom Personal Information is Sold and/or Shared |
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Identifiers |
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Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
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Protected classification characteristics under California or federal law |
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Commercial information |
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Biometric information |
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Internet or other electronic network activity |
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Geolocation data |
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Sensory data |
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Professional or employment-related information |
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Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)) |
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Inferences drawn from other personal information to create a profile about a consumer |
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Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number |
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Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
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Personal information that reveals a consumer’s precise geolocation |
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Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
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Personal information that reveals the contents of a consumer’s mail, email, and text messages unless CrunchLabs is the intended recipient of the communication |
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Personal information that reveals consumer’s genetic data |
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Biometric information that is processed for the purpose of uniquely identifying a consumer |
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Personal information collected and analyzed concerning a consumer’s health |
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Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation |
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USES OF PERSONAL INFORMATION
We may use and disclose the personal information that we collect for the following business and commercial purposes:
- Providing the Services as further described in our Privacy Notice;
- Processing for administrative purposes as further described in our Privacy Notice;
- Processing for marketing purposes as further described in our Privacy Notice;
- Processing with your consent or direction as further described in our Privacy Notice;
- Processing to carry out automated decision making as further described in our Privacy Notice;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with CrunchLabs;
- Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar Services;
- Providing advertising and marketing services;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by CrunchLabs, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by CrunchLabs.
RIGHT TO OPT OUT OF “SALES” OF PERSONAL INFORMATION AND/OR “SHARING” FOR “CROSS-CONTEXT BEHAVIORAL ADVERTISING”
We “sell” your personal information or “share” your personal information for “cross-contextual behavioral advertising” to provide you with “cross-context behavioral advertising” about CrunchLabs’ products and services.
California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by emailing us at help@crunchlabs.com.
DISCLOSURE REGARDING INDIVIDUALS UNDER THE AGE OF 16
CrunchLabs does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. CrunchLabs does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
DISCLOSURE REGARDING SENSITIVE PERSONAL INFORMATION
CrunchLabs only uses and discloses sensitive personal information for the following purposes:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at CrunchLabs and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- For short-term, transient use.
- Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by CrunchLabs, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by CrunchLabs.
- For purposes that do not infer characteristics about individuals.
NON-DISCRIMINATION
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
