This Privacy Policy delineates our protocols and practices concerning the gathering, utilization, and revelation of your data when you employ the Service. It also elucidates your privacy rights and the legal safeguards that apply to you.

We leverage your personal data to furnish and enhance the Service. Your utilization of the Service implies your consent to the collection and utilization of information as outlined in this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with capitalized initial letters are defined under the following conditions. These definitions maintain their meaning whether they are in the singular or plural form.

Definitions

For the purposes of this Privacy Policy:

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to Essential, the software program provided by the Company.

• Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

• CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Drayfield Labs Limited.
  For the purpose of the GDPR, the Company is the Data Controller.

• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Device means any device that can access the Service such as a cellphone or a digital tablet.

• GDPR refers to EU General Data Protection Regulation.

• Personal Data is any information that relates to an identified or identifiable individual.
  For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

• Service refers to the Application.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

During your use of our Service, we may request you to furnish us with specific personally identifiable information that enables us to get in touch with or distinguish you. This information may encompass, but is not confined to:

• Email address

• Usage Data

Usage Data

Usage Data is gathered automatically when you use the Service. This data may encompass details like your device's Internet Protocol (IP) address, browser type, browser version, the pages you visit on our Service, the date and time of your visits, the duration of your visits to those pages, unique device identifiers, and additional diagnostic information.

When you access the Service through a mobile device, we may automatically collect specific information, including, but not limited to, the kind of mobile device you utilize, your mobile device's unique ID, your mobile device's IP address, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, and other diagnostic data.

Additionally, we may collect information that your browser transmits whenever you visit our Service or access it via a mobile device.

Information Collected while Using the Application

During your use of our Application, and with your prior consent, we may gather information to facilitate the features of our Application:

• Pictures and other information from your Device's camera and photo library

We employ this data to deliver the features of our Service and to enhance and tailor it. This information may either be uploaded to the Company's servers and/or a Service Provider's server, or it may be saved directly on your device.

You have the flexibility to enable or disable access to this information at any point by adjusting your Device settings.

Use of Your Personal Data

The Company may utilize Personal Data for the following objectives:

• Service Maintenance: To provide and sustain our Service, which includes monitoring its usage.

• Contract Fulfillment: For the execution, observance, and administration of any contractual agreements with us through the Service.

• Communication: To contact you via email or equivalent electronic means, such as push notifications through a mobile application, regarding updates or informational communications linked to the features, products, or services, including security updates when necessary or reasonable for their implementation.

• Information Provision: To offer you news, special offers, and general information concerning other goods, services, and events that are akin to those you have already acquired or inquired about, unless you have opted not to receive such information.

• Request Handling: To attend to and manage your requests to us.

• Targeted Advertising: Your information may be used to craft and display content and advertising tailored to your interests and/or location, and to assess its effectiveness. We may collaborate with third-party vendors to accomplish this.

• Business Transfers: Your information may be utilized to assess or perform a merger, divestiture, reorganization, dissolution, or other transaction involving the sale or transfer of some or all of our assets, whether as a going concern or part of a bankruptcy, liquidation, or similar process, in which Personal Data regarding our Service users is among the assets conveyed.

• Other Objectives: We may apply your information for other purposes such as data analysis, recognizing usage trends, and evaluating and refining our Service, products, services, and your user experience.

We may divulge your personal information under the following circumstances:

• Service Providers: We may share your personal information with service providers for functions like monitoring and analyzing Service usage, displaying ads, aiding in Service support and maintenance, and advertising to you on third-party websites after you have visited our Service. We may also share your information for payment processing and contacting you.

• Business Transfers: Your personal data may be disclosed or transferred in connection with, or during negotiations of, any merger, sale of company assets, financing, or the acquisition of all or part of our business by another entity.

• Affiliates: Your information may be shared with our affiliates, and in such cases, we will require those affiliates to adhere to this Privacy Policy. Affiliates encompass our parent company, subsidiaries, joint venture partners, or companies under our common control.

• Business Partners: We may share your information with our business partners to offer specific products, services, or promotions.

• Other Users: When you provide personal information or engage in interactions in public areas with other users, this information may be accessible to and distributable among all users, even beyond our Service.

• With Your Consent: We may reveal your personal information for any other purpose with your explicit consent.

Retention of Your Personal Data

The Company will maintain your Personal Data only for the duration necessary to fulfill the objectives outlined in this Privacy Policy. We will uphold and utilize your Personal Data to the extent obligatory to comply with our legal responsibilities (for instance, if we are compelled to retain your data to adhere to relevant laws), resolve disputes, and enforce our legal agreements and policies.

Furthermore, the Company will also keep Usage Data for internal analytical purposes. Usage Data is typically retained for a shorter duration, except in situations where this data serves to enhance security or boost the functionality of our Service, or when legal obligations necessitate the prolonged retention of such data.

Transfer of Your Personal Data

Your data, including Personal Data, is processed at the Company's operational premises and in any other locations where the entities involved in the processing are situated. This implies that such information may be transmitted to, and retained on, computers positioned outside your state, province, country, or any other governmental jurisdiction. These jurisdictions may have data protection laws differing from those in your jurisdiction.

By consenting to this Privacy Policy and subsequently submitting such information, you signify your acceptance of this data transfer.

The Company will take all reasonable measures to guarantee that your data is handled securely and in conformity with this Privacy Policy. No transfer of your Personal Data will occur to an organization or country unless suitable safeguards, including data security and protection of your personal information, are in place.

Delete Your Personal Data

You possess the privilege to delete your Personal Data or request our assistance in erasing the Personal Data we have gathered about you.

Our Service might grant you the capacity to remove particular information pertaining to you directly through the Service. You also have the option to modify, rectify, or delete your data at any time by visiting the settings section, which empowers you to manage your personal information. Alternatively, you can get in touch with us to request access to, rectify, or erase any personal data that you have provided to us.

Please be mindful that certain data may need to be retained by us when there exists a legal obligation or valid basis for doing so.

Disclosure of Your Personal Data

Business Transactions

In the event that the Company engages in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will furnish prior notice before your Personal Data is transferred and becomes subject to an altered Privacy Policy.

Law enforcement

In specific situations, the Company might be compelled to reveal your Personal Data as mandated by legal obligations or in response to lawful requests made by public authorities, such as a court or government agency.

Other legal requirements

The Company may reveal your Personal Data in the honest belief that such action is indispensable to:

• Fulfill a legal requirement

• Safeguard and uphold the rights or assets of the Company

• Avert or scrutinize potential misconduct linked to the Service

• Ensure the personal safety of Service Users or the general public

• Safeguard against legal liability

Security of Your Personal Data

The safeguarding of your Personal Data is a priority for us; however, please be aware that no method of Internet transmission or electronic storage is entirely infallible. Although we endeavor to employ commercially reasonable measures to protect your Personal Data, we cannot assure its absolute security.

Detailed Information on the Processing of Your Personal Data

We may engage third-party Service providers to monitor and assess the usage of our Service. Two of the Service providers we utilize are Google Analytics and Firebase, both offered by Google Inc.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

• Google Analytics
  Google Analytics is a web analytics service furnished by Google, which tracks and furnishes reports on website traffic. The information collected is employed to observe and analyze the usage of our Service and is shared with other Google services. Google may utilize this data to contextualize and tailor advertisements within its advertising network. You have the option to opt-out of specific Google Analytics features through your mobile device settings, like your device advertising preferences, or by adhering to the instructions outlined in Google's Privacy Policy: https://policies.google.com/privacy
  For further insights into Google's privacy practices, please explore the Google Privacy & Terms webpage: https://policies.google.com/privacy

• Firebase
  Firebase is an analytics service presented by Google Inc. You can exercise the choice to opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings, or by adhering to the instructions provided in Google's Privacy Policy:  https://policies.google.com/privacy
  We also recommend that you review Google's guidelines for data protection: https://support.google.com/analytics/answer/6004245
  For more details on the type of information Firebase collects, please visit the "How Google uses data when you use our partners' sites or apps" webpage: https://policies.google.com/technologies/partner-sites

Advertising

We may enlist the services of Service Providers to display advertisements to you, thereby aiding in the support and sustenance of our Service.

• Google AdSense & DoubleClick Cookie Google, acting as a third-party vendor, employs cookies to deliver ads on our Service. Google's utilization of the DoubleClick cookie empowers both Google and its partners to provide ads to our users grounded on their interactions with our Service or other websites across the Internet. To abstain from the application of the DoubleClick Cookie for interest-based advertising, you can visit the Google Ads Settings webpage: http://www.google.com/ads/preferences/

• AdMob by Google AdMob by Google is a service supplied by Google Inc. To opt-out of the AdMob by Google service, please follow the guidelines set forth by Google: https://support.google.com/ads/answer/2662922?hl=en For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: https://policies.google.com/technologies/partner-sites or visit the Privacy Policy of Google: https://policies.google.com/privacy

• AppLovin AppLovin is offered by the AppLovin Corporation. If you wish to opt-out of the AppLovin service, please visit the AppLovin Opt-out page: https://www.applovin.com/optout For further information regarding AppLovin, we encourage you to visit the AppLovin Privacy Policy page: https://www.applovin.com/privacy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Apple Store In-App Payments Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

Behavioral Remarketing

The Company employs remarketing services to present you with advertisements after you've accessed or visited our Service. We, along with our third-party partners, utilize cookies and non-cookie technologies to facilitate the identification of your Device and gain insights into how you interact with our Service. This aids us in enhancing our Service to align with your interests and in delivering advertisements that are more likely to pique your interest.

These third-party partners collect, retain, employ, process, and transmit information pertaining to your engagement with our Service, all in accordance with their respective Privacy Policies. This endeavor serves to empower us in the following ways:

• Measure and analyze traffic and browsing patterns on our service.

• Display advertisements for our products and/or services to you on third-party websites or applications.

• Assess and analyze the effectiveness of our advertising campaigns.

Certain third-party vendors may utilize non-cookie technologies that might not be affected by browser settings designed to block cookies. Your browser might not provide the option to block such technologies. To reject the collection and utilization of information for the purpose of serving you interest-based advertising, you can make use of the following third-party tools:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You can opt out of personalized advertising by utilizing privacy features on your mobile device, like "Limit Ad Tracking" on iOS or "Opt Out of Ads Personalization" on Android. Check your mobile device's Help system for further guidance.

We may share information, such as hashed email addresses (if available) or other online identifiers collected from our Service, with these third-party vendors. This enables our third-party vendors to recognize you and display ads across various devices and web browsers. For more information on the technologies used by these third-party vendors and their cross-device capabilities, please consult the Privacy Policy of each of the vendors listed below.

The third-party vendors we employ are as follows:

• Google Ads (AdWords) The remarketing service Google Ads (AdWords) is supplied by Google Inc. You can opt out of Google Analytics for Display Advertising and customize Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. The Google Analytics Opt-out Browser Add-on allows visitors to prevent their data from being collected and used by Google Analytics. For more information on Google's privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

  • Facebook Facebook remarketing service is offered by Facebook Inc. You can find more information about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266 To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company is willing to assist in clarifying the specific legal basis that governs the processing, particularly regarding whether the provision of Personal Data is a statutory or contractual obligation or a requirement essential for entering into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You can exercise Your rights of access, rectification, erasure, and objection by reaching out to Us. Kindly be aware that We may request verification of Your identity before addressing such requests. We will make every effort to respond promptly when You submit a request.

Additionally, if You are in the European Economic Area (EEA), You have the right to lodge a complaint with a Data Protection Authority about Our collection and use of Your Personal Data. For more details, please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This California residents' privacy notice complements the details found in Our Privacy Policy and is exclusively relevant to individuals living in the State of California, including all visitors, users, and other residents of this state.

Categories of Personal Information Collected

We gather data that can directly or indirectly identify, be linked to, or relate to a specific Consumer or Device. Below is a compilation of personal information categories that we may have collected from California residents over the past twelve (12) months.

Please be aware that the categories and instances listed in the following section adhere to the CCPA/CPRA definitions. This does not imply that we have collected every example within each category. Instead, it reflects our sincere belief, to the best of our knowledge, that some information from each relevant category may have been collected. For instance, specific categories of personal information would only be gathered if you provided such information directly to us.

• Category A: Identifiers.
  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.
  Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  Collected: No.

• Category D: Commercial information.
  Examples: Records and history of products or services purchased or considered.
  Collected: Yes.

• Category E: Biometric information.
  Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
  Collected: No.

• Category F: Internet or other similar network activity.
  Examples: Interaction with our Service or advertisement.
  Collected: Yes.

• Category G: Geolocation data.
  Examples: Approximate physical location.
  Collected: No.

• Category H: Sensory data.
  Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
  Collected: No.

• Category I: Professional or employment-related information.
  Examples: Current or past job history or performance evaluations.
  Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
  Collected: No.

• Category K: Inferences drawn from other personal information.
  Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  Collected: No.

• Category L: Sensitive personal information.
  Examples: Account login and password information, geolocation data.
  Collected: Yes.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA/CPRA's scope, such as:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

• We obtain the personal information categories outlined above from the following sources

• Directly from You. This includes information gathered from the forms You complete on our Service, preferences You convey or provide while using our Service, or details obtained from Your transactions on our Service.

• Indirectly from You. This involves data collected through the observation of Your interactions and activity on our Service.

• Automatically from You. For instance, this information is collected through cookies placed on Your Device, either by us or our Service Providers, as You navigate through our Service.

• From Service Providers. This category encompasses data acquired from third-party vendors who assist in various aspects of our Service, such as monitoring and analyzing Service usage, delivering advertisements, providing targeted advertising, handling payment processing, and other services used to deliver the Service to You.eted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may utilize or reveal the personal information we gather for "business purposes" or "commercial purposes" (as outlined in the CCPA/CPRA). Such purposes may encompass the following instances:

• Operating our Service and delivering Our Service to You.

• Providing You with support, addressing Your inquiries, investigating and resolving concerns, and enhancing the quality of our Service.

• Meeting the specific purpose for which You provided the information. For instance, if You shared Your contact details to inquire about our Service, we will use that information to respond to Your inquiry. In case You provided personal information for a product or service purchase, we will use it for payment processing and delivery facilitation.

• Complying with law enforcement requests and abiding by applicable laws, court orders, or government regulations.

• Adhering to the descriptions provided to You when collecting Your personal information or as stipulated in the CCPA/CPRA.

• Utilizing personal information for internal administrative and auditing functions.

• Detecting security incidents and safeguarding against malicious, deceptive, fraudulent, or unlawful activities, including, when necessary, pursuing legal action against those responsible for such actions.

• Other one-time uses as necessary.

Please be aware that the aforementioned examples are meant for illustration and are not intended to cover every possible scenario. For a comprehensive understanding of how we utilize this information, please consult the "Use of Your Personal Data" section.

If we choose to gather additional personal information categories or employ the collected personal information for substantially distinct, unrelated, or incompatible purposes, we will revise and update this Privacy Policy accordingly.

Disclosure of Personal Information

We may have used or disclosed, and may continue to use or disclose, the following categories of personal information for business or commercial purposes, both presently and within the last twelve (12) months:

• Category A: Identifiers

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

• Category D: Commercial information

• Category F: Internet or other similar network activity

Please be aware that these categories align with the definitions provided by the CCPA/CPRA. It's important to note that this does not imply that every example within each category has been disclosed, but rather represents our sincere belief, to the best of our knowledge, that some information from each relevant category may have been disclosed.

Whenever we disclose personal information for a business or commercial purpose, we engage in a contractual agreement that specifies the purpose and obliges the recipient to maintain the confidentiality of that personal information and restrict its use solely to fulfill the terms of the contract.

Share of Personal Information

We may disclose, and have disclosed in the preceding twelve (12) months, the personal information falling within the aforementioned categories to the subsequent categories of third parties:

• Service Providers

• Payment processors

• Our affiliates

• Our business partners

• Third-party vendors to whom You or Your authorized representatives grant Us permission to share Your personal information in connection with the products or services We offer to You.

Sale of Personal Information

As per the CCPA/CPRA definitions, "sell" and "sale" encompass actions such as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise conveying, whether verbally, in writing, electronically, or through other means, a Consumer's personal information by the Business to a third party in exchange for valuable consideration. It's important to note that this consideration can take various forms, not limited to monetary benefits.

We do not engage in the conventional understanding of selling personal information. However, we do permit Service Providers to utilize Your personal information for the business purposes outlined in Our Privacy Policy. These purposes may encompass activities such as advertising, marketing, and analytics, which may be considered a sale under the CCPA/CPRA.

We may have sold, and may continue to sell, the following categories of personal information within the last twelve (12) months:

• Category A: Identifiers

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

• Category D: Commercial information

• Category F: Internet or other similar network activity

Please be aware that the categories listed above adhere to the definitions set forth by the CCPA/CPRA. It's essential to understand that not every instance within each category has necessarily been exchanged for value, but it signifies our genuine belief, to the best of our knowledge, that some information from each relevant category may have been shared in exchange for value.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from individuals under the age of 16 via our Service. However, it's worth noting that certain third-party websites to which we provide links may have their own policies regarding the collection of information from minors. We strongly recommend that parents and legal guardians closely supervise their children's online activities and instruct them never to share personal information on other websites without obtaining proper permission.

For consumers whom we are aware are under 16 years of age, we do not sell their personal information, unless we receive explicit authorization (referred to as the "right to opt-in") from either the consumer between 13 and 16 years old or their parent or guardian if the consumer is under 13 years old. Consumers who opt-in to the sale of personal information retain the right to opt-out of such sales at any time. To exercise this opt-out right, You (or Your authorized representative) can contact Us to submit a request.

If you have reason to believe that a child under the age of 13 (or 16) has provided Us with their personal information, please get in touch with us, providing sufficient details to enable us to promptly delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA grants specific rights to California residents regarding their personal information. If you are a California resident, you have the following rights:

• The right to notice. You possess the entitlement to receive information regarding the categories of Personal Data under collection and the purposes for which this Personal Data is being utilized.

• The right to know/access. In accordance with the CCPA/CPRA, you are granted the right to request that we provide you with information regarding our collection, utilization, sale, disclosure for business purposes, and sharing of personal information. Upon receipt and verification of your request, we will furnish you with the following details:

  • The categories of personal information We collected about You

  • The categories of sources for the personal information We collected about You

  • Our business or commercial purposes for collecting or selling that personal information

  • The categories of third parties with whom We share that personal information

  • The specific pieces of personal information We collected about You

  • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:

    • The categories of personal information categories sold

    • The categories of personal information categories disclosed

• The right to say no to the sale or sharing of Personal Data (opt-out). You are entitled to instruct us not to sell your personal information. To initiate an opt-out request, please refer to the "Do Not Sell My Personal Information" section or get in touch with us.

• The right to correct Personal Data. You possess the right to amend or rectify any inaccurate personal information about yourself that we have collected. Upon receiving and confirming your request, we will make commercially reasonable efforts to rectify your personal information, and we will instruct our Service Providers to do the same unless an exception applies.

• The right to limit use and disclosure of sensitive Personal Data. You are granted the right to request restrictions on the use or disclosure of specific sensitive personal information that we have gathered about you, except in cases where exceptions apply. To make such a request, please consult the "Limit the Use or Disclosure of My Sensitive Personal Information" section or reach out to us directly.

• The right to delete Personal Data. You have the privilege to request the erasure of your Personal Data under specific circumstances, with exceptions in place. Once we receive and validate your request, we will expunge your personal information from our records and instruct our Service Providers to do the same, except when exceptions are applicable. We may refuse your deletion request if retaining the information is essential for us or our Service Providers to:

  • • Complete the transaction for which we collected your personal information, provide a good or service that you specifically requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or perform our contractual obligations to you.

    • Detect and address security incidents, protect against malicious, deceptive, fraudulent, or unlawful activities, or pursue those responsible for such actions.

    • Debug products to identify and rectify errors that hinder the intended functionality.

    • Uphold the principles of free speech, safeguard the rights of another consumer to exercise their free speech, or exercise any other rights granted by law.

    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).

    • Engage in public or peer-reviewed scientific, historical, or statistical research that serves the public interest while adhering to all relevant ethics and privacy regulations. In such cases, if you have previously given informed consent, the deletion of information might compromise or significantly impair the research's attainment.

    • Enable internal usage consistent with consumer expectations based on your relationship with us.

    • Fulfill a legal obligation.

    • Execute other internal and lawful purposes that are compatible with the context in which you provided the information.

• The right not to be discriminated against. You retain the right not to face discrimination for exercising any of your consumer rights, which includes:

  • Denying goods or services to You

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

  • Providing a different level or quality of goods or services to You

  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

For further details on how to opt out and restrict the use of sensitive information collected, please refer to the "Do Not Sell My Personal Information" section and the "Limit the Use or Disclosure of My Sensitive Personal Information" section.

Moreover, if you are a California resident seeking to exercise any of your rights under the CCPA/CPRA, you can contact us at:

• By email: feedback@drayfieldlabs.com

• By visiting this page on our website: www.drayfieldlabs.com

A verifiable request concerning your personal information can only be made by you or by an individual registered with the California Secretary of State whom you have authorized to act on your behalf. To ensure that your request to us is processed, it must:

• Furnish enough information to enable us to reasonably authenticate that you are the individual for whom we have collected personal information or an authorized representative.

• Outline your request in enough detail to ensure that we can accurately comprehend, assess, and respond to it effectively.

We cannot respond to Your request or provide You with the required information if We cannot:

• Verify Your identity or authority to make the request

• And confirm that the personal information relates to You

We will provide the necessary information at no cost to you within 45 days of receiving your verifiable request. In cases where it is reasonably necessary and with prior notice, we may extend the timeframe for providing the required information by an additional 45 days.

Any disclosures we furnish will pertain solely to the 12-month period preceding the receipt of the verifiable request

Regarding data portability requests, we will choose a format for delivering your personal information that is easily usable and should enable you to transmit the information from one entity to another without obstacles.

Do Not Sell My Personal Information

As outlined in the CCPA/CPRA, "sell" and "sale" encompass activities like selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise conveying, whether verbally, in writing, electronically, or through other means, a Consumer's personal information by the Business to a third party in exchange for valuable consideration. It's important to note that this consideration can take various forms, not limited to monetary benefits.

We do not engage in the conventional understanding of selling personal information. However, we do allow Service Providers to use your personal information for the business purposes described in Our Privacy Policy, such as activities related to advertising, marketing, and analytics. These actions may be considered a sale under the CCPA/CPRA.

You possess the right to opt-out of the sale of your personal information. Once we receive and validate a verifiable consumer request from you, we will cease the sale of your personal information. To exercise your right to opt-out, please contact us.

The Service Providers we collaborate with (such as our analytics or advertising partners) may utilize technology on the Service that, as per the CCPA/CPRA, qualifies as selling personal information. If you wish to opt out of the use of your personal information for interest-based advertising and these potential sales under CCPA/CPRA, you can do so by following the provided instructions.

Please keep in mind that any opt-out is browser-specific. You may need to opt out on each browser you use.

Website

If relevant, you can click on buttons like "Privacy Preferences," "Update Privacy Preferences," or "Do Not Sell My Personal Information" that are provided on the Service. These buttons will enable you to assess your privacy preferences and opt out of cookies and other technologies that we may employ. Please be aware that you should opt out separately on each browser you use to access the Service.

Moreover, you have the option to opt out of receiving personalized ads delivered by our Service Providers by adhering to the instructions offered on the Service:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Opting out will set a browser-specific cookie on your computer. This cookie is unique to the browser you use to opt out. If you switch to a different browser or delete the cookies stored by your current browser, you will need to perform the opt-out process once more.

Mobile Devices

Your mobile device might offer you the option to opt out of using information about the apps you utilize to deliver targeted ads based on your interests.

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

• "Limit Ad Tracking" on iOS devices

You can also halt the collection of location information from your mobile device by adjusting the settings or preferences on your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If you are a resident of California, you have the privilege to restrict the utilization and divulgence of your sensitive personal information to the extent that is required to deliver services or provide goods that an ordinary consumer requesting such services or goods would reasonably anticipate.

We gather, employ, and reveal sensitive personal information in a manner essential for delivering the Service. For further insights into how we employ your personal information, please refer to the "Use of Your Personal Data" section or reach out to us directly.

Children's Privacy

Our Service is not intended for individuals under the age of 13, and we do not intentionally gather personally identifiable information from anyone under 13 years old. If you are a parent or guardian and become aware that your child has provided us with Personal Data, please get in touch with us. In the event we discover that we have unintentionally collected Personal Data from an individual under 13 years of age without appropriate parental consent, we will take the necessary measures to delete that information from our servers.

In cases where we need to rely on consent as the legal basis for processing your information, and your country mandates parental consent, we will require consent from your parent before collecting and using that information.

Links to Other Websites

Our Service may include links to websites that are operated by third parties, not us. Clicking on a third-party link will take you to the website of that third party. We highly recommend that you carefully review the Privacy Policy of each website you visit.

We lack control over, and do not assume responsibility for, the content, privacy policies, or practices of any third-party websites or services.

Changes to this Privacy Policy

We may periodically update our Privacy Policy. Changes will be communicated by posting the revised Privacy Policy on this page. Additionally, we will inform you via email and/or provide a noticeable notice on our Service before the modifications take effect, and we will update the "Last updated" date at the beginning of this Privacy Policy.

We recommend that you regularly review this Privacy Policy to stay informed of any adjustments. Changes to this Privacy Policy become effective when they are posted on this page.

Contact Us

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

• By email: feedback@drayfieldlabs.com

• By visiting this page on our website: www.drayfieldlabs.com