WOOW PRIVACY POLICY

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Last Updated: December 14, 2022

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Welcome to WOOW, an App + web-based hosting, communications, and content creation/sharing platform owned and operated by WOOW.LLC, with address at 600 Broadway Ste 200 #1379, Albany, NY 12207 (“Company”, “we”, “us”, or “our”). Your privacy is very important to us, and in order to best protect your information, we have adopted this privacy policy (“Privacy Policy”), which describes the types of information we collect from registered or unregistered end users (each, a “user”, “you” or “your”) of the WOOW website, https://www.woow.mobi/ (the “SiteSite”), and/or the WOOW mobile application (the “App”, and collectively with the Site and all services provided therein, the “Platform”), how such information is used, processed and in certain cases disclosed by us, and your rights and choices regarding the information you provide to us. Please read this Privacy Policy carefully prior to your use of, or creation of a registered User account (an “Account”) on, the Platform. If you do not agree to abide by this Privacy Policy, please do not use our Platform or create an Account. By accessing and using the Platform and/or creating an Account, you are deemed to have read, accepted, executed and be bound by this Privacy Policy, including, without limitation, the information collection, use and disclosure practises described herein. This Privacy Policy is governed by the Platform Terms of Service available at https://www.Woow.mobi/terms, which includes all disclaimers of warranties and limitations of liabilities. Capitalised terms that are used but not defined in this Privacy Policy have the respective meanings assigned to such terms in the Terms of Service.

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1. Information We Collect and Receive

In order for Us to (i) provide You with the services and functionalities offered via the Platform, (ii) engage in troubleshooting activities, and (iii) improve upon the Platform’s performance, safety and security, We may collect and process some or all of the following types of information about You:

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· Personal Information. Information that could be directly associated with you, or used to contact or identify you, including, without limitation, information you provide us when you create an Account such as your name, age, date of birth, gender, address, email address, social media login details, telephone number, photograph, and username/password, as well as certain User Content you upload to, or post on, the Platform, including, without limitation, UGC (“ Personal Information ”). As stated in our Terms of Service, while we do not actively monitor the interactions between Users of the Platform and are under no obligation to do so, we may in certain cases collect information related to your interactions with other Users of the Platform, including, without limitation, comments you make, and other User Content that that you upload to, or post on, the Platform that becomes publicly available to other Users.

· Usage Information. Information that is not Personal Information, but that relates to your usage of the Platform or that is necessary for the proper functioning or improvement of the Platform, including: (i) times and dates and the extent of your usage of the Platform; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Platform; (iii) device keyboard settings; (iv) the User Accounts and/or User Content you view, like, comment on, share, follow, message, add memes to, and otherwise interact with, as well as the foregoing that other Users do with respect to your Account and/or User Content; (v) usage history such as areas and pages within the Platform that you access or use and/or which buttons in the Platform you click on; (vi) search terms you type in on the Platform; (vii) the URL or advertisement that may have referred you to the Platform; (viii) the mobile platform or service provider you use; and (ix) other device and Platform access information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers, as well as your push notification token. Only content posted or shared on the app is collected. We do not collect additional information or activities from your personal device or store any such data.

· Behavioural Information. Your contact or subscriber information, which we link with your activity on the Platform across all your devices using your email or social media log-in details, as well as engagement scores (“likes”, comments, repeated views), related Users based on your Platform behaviour, and opt-ins and communication preferences.

· Location Data. We may collect location data based on your network,  not your device. Clarification:  This is a very broad geo-location data which identifies only the city of the user, needed for your analytics. We DO NOT, NOR WILL IN FUTURE, collect your geolocation based on your device, Bluetooth, access point etc, which identify a device within 2-3 feet (1-2 metres). YOUR PRIVACY IS VERY IMPORTANT FOR US.

· Contacts Data. User can choose whether to find other users of the Platform using our 'Find Friends' function. This functionality allows you to see which of your friends from either your telephone's contact list or Facebook friends list is using the Platform and offers you the option to follow them. You can also use this function to invite your contacts to join you on the Platform. We will use the contact information you have for that person, either from within your telephone's contact list or Facebook friends list and give you the option to send them either an SMS, email or third party message (such as Whatsapp, Facebook (including Facebook Messenger) or Twitter) inviting them to view your WOOW profile.

· Messages. We may, but are not obligated to, collect and process information you provide, including any Personal Information, in the context of composing, sending, or receiving messages to other Users (that means the content as well as information about when the message has been sent, received and/or read and the participants of the communication) through our Service's messaging functionality. Please be aware that messages sent to other users of our Service will be accessible by those other users and that we are not responsible for the manner in which those users use or disclose messages.

· Customer Support. We collect information that you provide to us, including any Personal Information, when you contact us for customer-support purposes. While certain types of information described above, such as Usage Information and Third-Party Information, are generally non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Platform, as described above. If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information. We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you. YOUR PERSONAL INFORMATION IS PROTECTED

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We do not collect any activity that is conducted off of the app on your personal device.

Safety:

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1. European Union Users

European Union data protection law requires a “lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas (“EEA”). Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (“GDPR”), which are summarised below.

· Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your email address when you create your Account, or making certain User Content publicly available on the Platform.

· Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Platform, such as fulfilling any future subscription based, or other transactional, services.

· Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Platforms.

· Legitimate Interests: This is a technical term that means we have a good and fair reason to use your Personal Information and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Platform by Users and to keep the Platform secure, (ii) may also send you promotional communications about our Platform and services subject to your right to opt-out, and (iii) analyse how Users interact with our Platform or other Users (although we are not obligated to do so) so we can understand better what elements do or do not work well, what services/functionalities may be necessary or desirable to provide you with the best User experience on the Platform, and to ensure the safety and security of the Platform, which allows us to improve and develop the quality of the online experience we offer all our Users.

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1. Privacy by Third-Party Platform Feature

Augmented Reality Functionality

To provide our Users with augmented reality functionality, which enable Users transform their appearance, or the appearance of certain objects, in User Content, we use object recognition software. Object recognition is an algorithm designed to help a computer generally understand what objects are in an image. Object recognition software is different from facial recognition software, and while the underlying technology object recognition can determine what is or isn’t a face, the technology does not recognize specific faces or the identity of specific individuals.

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1. Use of Information We Collect

We may use the information we collect about/from you to:

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We may also use certain collected information on an aggregated and/or anonymized basis in order to conduct market research, engage in project planning, for troubleshooting purposes, to help detect and protect against error, fraud or other criminal activity.

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1. Email Notifications and Opt-Out

We maintain a strict “no-spam” policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt-out as provided herein, by accepting the Terms of Service and this Privacy Policy, you expressly agree that we may use your information to contact you by email in order to deliver you information that is relevant to your use of the Platform such as administrative notices, product/service enhancements or “newsletters”, or that, in some cases, is targeted to your interests, such as information about User Content or service/functionalities offerings that we believe you may be interested in learning more about. You may choose to stop receiving these email communications from us by following the instructions included in such communications or by contacting us at legal@woow.mobi. If a third party vendor provides such newsletters, you may unsubscribe in accordance with the instructions provided by such third party. If you are having problems unsubscribing please contact us at legal@woow.mobi (forwarding the newsletter, if applicable, and including in the Subject line the word “Unsubscribe”), and you will be removed within seven (7) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.

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1. Sharing Your Information

Information that May be Publicly Accessible

As described in more detail in Sections 5 of the Terms of Service, certain Personal Information that you upload to the Platform (such as certain Account profile information), certain User Content (such as UGC you upload to and make public on the Platform, or comments that you post to the Platform), and certain Platform usage information (such as User Content you “like”), will automatically, or upon your selection, be made publicly available to other Users on the Platform. You acknowledge and agree that certain Account information (such as your Account profile name, picture, and/or User Content, etc.) that you provide in connection with (i) the registration of your Account and (ii) your general use of the Platform, such as uploading User Content, will be publicly viewable by all Users of the Platform. We are not responsible for the privacy practises of the other Users who will view and use this information, so you should carefully consider whether to upload any User Content on the Platform or how you identify yourself on the Platform. You should not disclose your home address or the address of your place of business, or other locations you frequent on a regular basis in any User Content.

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Location Information

You may share your location information with other Users. We do not share your location with other Users.

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Information We May Share with Third Parties

WE DO NOT SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES FOR ANY REASON. 

Except for: Necessary or required by any applicable law, rule or regulation, including a subpoena or similar legal process or request/order; However we strongly advise legal authorities around the world before issuing a subpoena. We don't collect any private data, thus the only thing you will get, is registration form of the user. We are not under any obligation to verify the authenticity of  user's information provided during registration.

Social Networking

As described above, the Platform allows you to create an Account via certain SM Login Channels. By using this functionality, you give us permission to access all of the elements of your SM Login Channel account profile information that you have made available to be shared and to use it in accordance with the applicable SM Login Channel’s terms of use and this Privacy Policy. Please refer to the privacy settings in your SM Login Channel for information about what data is shared with us and other connected applications and to manage the data that is shared through your SM Login Channel account, including information about your activities using our Platform. WOOW does not retain your username or password for SM Login Channels for any longer than is necessary to complete an interaction. If you would like to disconnect an SM Login Channel user account from the Platform, refer to the settings of that social media account and its provider.

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Music Service Plug-ins

As described above, the Platform allows you to access certain of your music subscription libraries via certain music services. By using this functionality, you give us permission to access all of the elements of your music service account profile information that you have made available to be shared and to use it in accordance with the applicable music service terms of use and this Privacy Policy. Please refer to the privacy settings in your music service account for information about what data is shared with us and other connected applications and to manage the data that is shared through your music service account, including information about your activities using our Platform.

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Company does not retain your username or password for your music services for any longer than is necessary to complete an interaction. If you would like to disconnect a music service user account from the Platform, refer to the settings of that music service account and its provider.

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1. Storage and Transfer of Information

· Information collected by us may be stored and processed in the United States or any other country in which we or our agents maintain facilities. By using the Platform, you expressly consent to any such transfer and storage of information outside of your country of residence, where data protection laws may be different and/or less stringent. However, we will endeavour to take reasonable measures to keep up an adequate level of data protection also when sharing your Personal Information with such countries.

· We make no representation or warranty with respect to any duty to permanently store any information you may provide or that we otherwise collect about you. We strive to keep our processing activities with respect to your Personal Information as limited as possible. By using the Platform and providing us with information (including Personal Information), you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties. We may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format. This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Platform.

· With respect to any Personal Information that may be originally collected and stored in the EEA, if and when we transfer your Personal Information to countries outside the EEA, we will do so under the Commission’s model contracts for the transfer of Personal Information to third countries ( e. , standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate). For a copy of these Standard Contractual Clauses, please contact us at legal@woow.mobi.

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1. Link to Third Party Websites

The Platform may include links to other websites, mobile applications or services (“Third Party Sites”), whose privacy practises may differ from those set forth herein. Such links are not an endorsement by the Company of those Third Party Sites and/or the products or services they offer. If you visit Third Party Sites or submit Information to any of those Third Party Sites, your visit and Information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Third Party Site you visit, as it may differ substantially from that of this privacy statement. Company makes no representations or warranties with respect to, nor is Company responsible for the privacy policies of, any Third Party Sites. If you decide to click on any such links or access any Third Party Sites appearing on the Platform, you do so at your own risk.

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1. Your Rights

In certain circumstances you have the right to access the Personal Information that we collect/hold about you and to correct, update, or request deletion of your Personal Information. Prior to the fulfilment of your request concerning your Personal Information, we will ask you to verify your identity before we can act upon your request. You have the following rights:

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1. Do Not Track Requests

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Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not alter our practises when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

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1. Security

The security of your information is important to us, and we take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk. We follow generally accepted industry standards to protect your information, both during transmission and once we receive it, and to keep such Information confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorised alteration. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and the nature of security risks is constantly evolving, as are the technical and organisational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete and absolute security of any Information collected, stored or used by us cannot therefore be guaranteed. In the unlikely event that an unauthorised third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorised third party’s ability to view, use or disseminate such information. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. If you have any questions about security on our Platform, you can contact us at legal@woow.mobi .

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1. Information Relating to Children

Our Platform is not directed to children under the age of thirteen (13), and we do not knowingly collect, use, or disclose Personal Information from (i) children under the age of thirteen (13) or (ii) children between the age of 13 and 18 (or any greater age required to be deemed to have reached the age of majority under the applicable law of the state or jurisdiction of such child’s primary residence) that do not have parental or legal guardian consent to use the Platform. If we ever discover that we have inadvertently collected Personal Information from children under the age of thirteen (13) on or through the Platform, we will delete it from our records as soon as possible. If you believe that we have Personal Information about, or have collected Personal Information from, (i) a child under 13, or (ii) between the age of 13 and 18 (or any greater age required to be deemed to have reached the age of majority under the applicable law of the state or jurisdiction of such child’s primary residence) without parental/legal guardian consent, or that such a person is using the Platform, please see Section 13 of the Terms of Service for available remedies, including how to contact us to report this.

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1. Sweepstakes, Contests and Promotions

We may offer sweepstakes, contests, and other promotions through the Platform (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.

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1. Contacting Us

In the event that you wish to make a complaint or request concerning your Personal Information or our privacy practises, or have questions, concerns or comments about this Privacy Policy, please contact us in the first instance at legal@woow.mobi and we will endeavour to deal with your request as soon as possible. You can also write to us at Woow LLC; 600 Broadway Ste 200 #1379, Albany, NY 12207; Attn: Privacy Policy. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute process set forth in the Terms of Service.

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1. Updates; Notification of Privacy Policy Changes

We may update this Privacy Policy to reflect changes to our information practises from time to time in our sole discretion. If we make any material changes to this Privacy Policy we will notify you by posting such changes on the Platform prior to the change becoming effective. We will also update the “Last Updated” date at the top of this Privacy Policy, which reflects the effective date of such Privacy Policy, and we encourage you to periodically review this Privacy Policy for the latest information on our privacy practises. Once a change becomes effective, your continued use of the Platform and/or creation of an Account shall automatically constitute your acceptance of such changes.

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1. Your California Privacy Rights

This section provides additional details about the Personal Information we may collect about California-resident Users and the rights afforded to them under California Civil Code Section 1798.83 and the California Consumer Privacy Act of 2018 (“ CCPA ”). California-resident Users are entitled to additional privacy rights which are further described below. California-resident Users who wish to request further information about our compliance with the above referenced statutes or who have questions more generally about our Privacy Policy or the CCPA and our privacy commitments to our Users should not hesitate to contact us in accordance with the procedures set forth below.

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What Information We Collect

As also detailed in the “ Information We Collect and Receive ” section above, through the Platform we collect certain Personal Information, including such information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California-resident User or his or her device. In particular, the Platform, has collected the following categories of Personal Information within the last twelve (12) months:

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Category Examples Collected. YES are what we collect.

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. YES

B. Personal Information

categories listed in the

California Customer Records statute (Cal. Civ. Code §

1798.80(e)).

A name, signature, physical

characteristics or description, address, telephone number,

education, employment, bank account number, credit card number, debit card number, or any other financial information.

Some Personal Information included in this category may overlap with other categories.

YES

C. Protected classification

characteristics under

California or federal law.

Age (40 years or older), race, colour, ancestry, national origin,

citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioural, and biological characteristics,

or activity patterns used to extract a template or other identifier

or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

NO

G. Geolocation data.

Physical location or movements. Partial only (City / Country.)

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or

employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education

information (per the Family)

Educational Rights and Privacy

Act (20 U.S.C. Section 1232g,

34 C.F.R. Part 99)).

Education records directly related to a student maintained by an

educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other Personal Information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

NO
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Personal Information does not include:

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How We Use Personal Information

We collect Personal Information for the business and commercial purposes described in the “ Use of Information We Collect ” section above. We share Personal Information with the categories of third parties described in the “ Sharing Your Information ” section above. We do not sell (as such term is defined in the CCPA) Personal Information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies (for WOOW website) for certain purposes as further described in the “Cookies and Other Tracking Technologies” section above.

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California Residents’ Rights and Choices with Respect to Personal Information

Subject to certain limitations, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights, which specifically includes:

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Access to Specific Information and Data Portability Rights

You have the right to request that the Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights subsection below), we will disclose to you:

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Deletion Request Rights

You have the right to request that the Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights subsection below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at legal@woow.mobi. Only you, or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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Response Timing and Format

Company endeavours to respond to a verifiable California residents request within forty-five (45) days of its receipt. If the Company requires more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

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Personal Information Sales Opt-Out and Opt-In Rights

We will not sell your Personal Information to any party. If in the future, we anticipate selling your Personal Information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

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Non-Discrimination

Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Company will not:

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Contacting Company

If you have any questions or comments about this notice, the ways in which Company collects and uses your information described above and in the Privacy Policy, generally, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by email at legal@woow.mobi. Company will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute process set forth in the Terms of Service.

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