Privacy Policy
Our commitment to privacy extends across all of our products. Read below for how we treat your information.
Last updated: January 20, 2022‍
This Privacy Policy relates to our information collection and use practices. In this Privacy Policy, we describe (i) what kinds of information we may obtain from and about you online, through your use of our Websites and apps at https://www.probablysomething.io, and https://app.lifeboat.fi (collectively, the “Websites” or “Sites”), (ii) how we may use and disclose that information, (iii) the steps we take to keep it secure your information, (iv) your choices regarding our use of your information, and (v) how you how can contact us if you have any questions about our privacy policy.
We strongly encourage you to read this Privacy Policy carefully before accessing and/or using our Websites or Services. Please note that by accessing our Sites or using our Services you assent to this Privacy Policy. If you do not agree to (or cannot comply) with all the terms of this Privacy Policy, then your choice is to not access or use any of our Sites or Services.
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Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on this page. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.Â
"Personal Information" “Personal Data” or “personal information” is information that can be used to trace or distinguish an individual's identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific person. This is information that can be used to personally identify you such as your name, address, email, and/or username.
“Non-personal Information” is information that is not personal or is information that was personal information, but which we modify and/or aggregate with other data to make it non-personal information.
Personal Information and Non-personal Information may be referred to in this Privacy Policy as “information”.
With that in mind, this Privacy Policy applies to information we collect:
- ~on our Sites.Â
- ~through your use of our Services.
- ~through our Social Media pages.
- ~in email, text, and other electronic messages between you, us or our Sites.
- ~when you register for any of our events or accounts.
- ~Through mobile and desktop applications your download from our Sites, which provide ~dedicated non-browser-based interactions between you and our Sites.
- ~Through our apps.
It does not apply to information collected by:
- ~any third party (including our affiliates and subsidiaries, if any), including through any application or content (including any advertising, if any) that may link to or be accessible from or on our Website.
This Privacy Policy is designed to describe to you:
- ~The type of information we collect and howÂ
- ~How we use your informationÂ
- ~With Whom We Share Your Information
- ~Your Choices and Rights to Your Information
- ~Other Sites and ServicesÂ
- ~SecurityÂ
- ~International data transferÂ
- ~Information of children under the age of 13
- ~Your California Privacy RightsÂ
- ~Changes to this Privacy Policy
- ~How to contact us
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Type of information we collect and how
1. Type of Information. We may collect both personal information and non-personal information from and about you when you visit our Websites, through use of our Services, or otherwise, including:Â Â
- ~communications that we exchange with you, including when you contact us with questions or feedback, post to our communications boards, through social media (including Discord, Twitter, etc.) or otherwise.
- ~when you create a profile on any of our Services or social media (including, by way of example, a Discord handle for use on our Discord channel), we collect the information that you may provide, such as your username and profile picture (collectively, the “Profile Information”).
- ~information about your business such as company name, company size, company type, if applicable to you, including your name, position, email address, and address (collectively, “business information”);Â
- ~Personal Information, by which you may be individually and personally identified, such as name, postal address, e-mail address, telephone number or other types of information by which you may be contacted online or offline;
- ~information that is about you, but individually does not identify you, such as geographic information, statistical or aggregated data to calculate the percentage of users in a particular zip code, and Website pages accessed, among others;Â
- ~information about your internet connection, the equipment and hardware that you use to access our Websites and usage details;
- ~aggregated usage data of our Sites, including form analysis data (such as time taken to complete a form), engagement rate, session replay, and mouse movements;Â
- ~we may receive personal information about you from third-party sources. For example, we may obtain your personal information from third parties such as publicly available sources and data providers;
- ~other data, not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
If you wish to opt out of this collection, please contact us at privacy@probablysomething.io.Â
2. Collection Methods.
- ~Information you provide to us.  The information we collect on or through our Websites may include:
- ~~Personal Information that you provide by filling in forms on our Sites. This includes information provided at the time you use our Websites, subscribe to our Services, sign up for any newsletters, if applicable, or request further information or Services. We may also ask you for information when you report a problem with any of our Sites.
- ~~Records and copies of your correspondence (including email addresses), if you contact us or sign up for our Services, waitlists, social media channels access, etc.
- ~~Your responses to surveys that we might ask you to complete for research purposes.
- ~~Details of any transactions you carry out through our Websites and of the fulfillment of your orders, if any.Â
- ~~Your search queries on our Websites.
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- ~Automatic data collection. We will directly collect analytics or use third-party analytics tools to help us determine the usage and traffic trends of our Websites. These tools collect information directly from your browser that assists us in improving our Websites and Services. As you navigate through and interact with our Sites, we may use these automatic data collection technologies to collect certain information about you. The information we collect automatically about you may include Personal Information, and/or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This helps us to improve our Sites and to deliver better Services and a more personalized experience to you while also enabling us to:
- ~~Estimate our audience size and usage patterns.
- ~~Estimate advisable times to publish content.
- ~~Estimate suggested amount of marketing funds, during a certain period, to spend on Twitter, Facebook, LinkedIn and other platforms for advertising.
- ~~Store information about your preferences, allowing us to customize our Websites according to your individual interests.
- ~~Speed up your searches.
- ~~Recognize you when you return to our Websites.
We may use certain technologies and other third party tools to process analytics information and develop our Services. Some analytic partners include:
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- ~Google Analytics – please visit Google Analytics' Privacy Policy for more information and to learn how to opt-out of their use of your information.
- ~Discord - please visit Discord's Privacy Policyfor more information and to learn how they use of your information and adjust any privacy settings.
- ~Twitter - please visit Twitter's Privacy Policy for more information on how Twitter will use your information and how to adjust your privacy settings.
- ~Open Sea – please visit for more information on how Open Sea will use your information and how to adjust your privacy settings.
- ~Other Social Media Platforms – Our Services may contain social media buttons such as Discord, Twitter, etc. (that may contain features such as the “share” button widget or other interactive programs). These features may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the widget to function properly. Your interactions with these other social media platforms are governed by the privacy policy of the company providing such social media platform.
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Our use of these technologies can be for operational necessity, for performance-related issues, for functionality related issues, or advertising or targeting related issues.
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- ~Operational Necessity – includes technologies that allow you to access our Sites, Services, applications and tools that are required for us to identify irregular Site behavior, fraudulent activity, improve our security, or that you use to make use of our functionalities.
- ~Performance Related Issues – we may use these technologies to analyze the performance of our Sites and Services, which may include analytics that may help us understand how you and others use our Sites and Services. For example, we may track your activity on our Sites.Â
- ~Functionality Related Issues – we may use technologies that allow us to provide you with enhanced functionality when you acces our Sites and Services. For example, this may include identifying you when you log in to our Services or keeping track of your past viewed items.
- ~Advertising or Target Related Content – we may use first or third party technologies to deliver content, including advertisements or curated content related to your interests, when you access our Services.
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3. Third-parties. Our service providers, and our business partners, may also automatically log information about you, your computer or mobile devices, your interaction over time with our Services, our communications, and other online services, such as:
- ~Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for any potential future advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
- ~Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our Websites or Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
4. Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. Cookies are small packets of data that a website stores on your computer or mobile device’s hard drive so that it will “remember” information about your visits. We use session cookies, which expire once you close your web browser, to help us collect information and to enhance your experience. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your internet browser’s documentation for information on how to do this and how to delete persistent cookies.
5. Web Beacons. Pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have clicked certain links or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). This information allows us to have more accurate reporting and improvement of our Websites and Services.
6. Log File Information. Â Log file information is information that is automatically reported by your browser or mobile device every time you access our Websites. Â When you use our Websites, our servers automatically record certain log file information. These server logs may contain anonymous information about you such as details of your visits to our Websites, including traffic data, location data, logs, number of clicks and how you interact with other links and other communication data and the resources that you access and use on our Websites. Â It may also include information about your computer and internet connection, including your IP address, operating system, and browser type. Basically, whenever your load a webpage from us, your browser sends us information about it and your interactions with our Websites.
7. Other Sources.  We may obtain information about your from other souces, including third-party services or organizations. For example, if you use an app store or a social networking site’s application to access our Services we may collect information about you from the third-party application that you have made available through your privacy settings.
8. Third-Party Use of Cookies and Other Tracking Technologies. Â Our Websites may contain links to other websites. Â If you click on a third-party link, you will be directed to that website. These external websites are not controlled by us. Â Therefore, we strongly encourage you to review the privacy policy of those websites. Â We are not responsible for the content or privacy practices of any linked websites we do not control. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services.
Please note that some content or applications, including advertisements, if any, on our Websites are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.Â
We do not control these third parties’ tracking technologies or how they may be used. This Privacy Policy does not apply to those websites, which may have their own privacy policies and notices. We encourage you to read the privacy policies of those websites to understand how they may collect and use your Personal Information. Â
If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices.
For more information on how we use cookies and other technologies and how you can control them, please read our Cookie Policy [link].
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How we use your information
We use the information that we collect about you or that you provide to us for the business purposes described above and which we describe in more detail below:
- ~Service delivery. We use your information to:Â
- ~~provide, operate, and improve our Services and our business.
- ~~communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.Â
- ~~understand your needs and interests, and to personalize your experience with our Services and our communications.Â
- ~~provide support for our Service, and respond to your requests, questions and/or feedback.
- ~~To present and improve our Website and Services to you.
- ~~To provide you with information, products, or services that you may request from us.
- ~~To fulfill any other purpose for which you provide it.
- ~~To access third-party services and networks on your behalf.
- ~~To provide you with periodic printed or e-mail communications about new products and services or upcoming events.
- ~~To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection, if applicable.
- ~~To notify you about changes to our Website or any products or Services we offer or provide.
- ~~To allow you to participate in interactive features on our Websites.
- ~~To promote and advertise our Websites and Services. For example, we may use the information collected from you for the purpose of sending you direct promotional marketing emails or messages to show you information about our Services that may be of interest to you, and other promotional materials and events. You may also object at any time to processing of your Personal Information for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to privacy@probablysomething.io.
- ~~To enforce our Terms of Use [INSERT LINK HERE].
- ~~To contact you as requested by you or otherwise approved by you.
- ~~To operate our business, which may include analyzing our performance, meeting our legal obligations, developing our workforce, and doing research. Â
- ~~Verification of your authority to access our Sites.
- ~~To administer or provide customer support for our Sites, as reasonably necessary.
- ~~To send you information you requested or "opted-in" to receive.
- ~~To contact you in the event of an emergency.
- ~~To evaluate your qualifications for employment and contact you, as appropriate, for employment opportunities.
- ~~To support human resource functions including employee administration and analysis of hiring and recruitment processes.
- ~~To identify, prevent, and protect against cybersecurity and other security events, espionage, fraud, unlawful activity, claims, and other liabilities.
- ~~To comply with and enforce applicable legal requirements and standards consistent with industry practices and our policies.
- ~~For any other purpose with your consent.
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- ~Research and development. We may use your Personal Information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you.Â
- ~Compliance and protection. We may use your Personal Information to:Â
- ~~comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;Â
- ~~protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);Â
- ~~audit our internal processes for compliance with legal and contractual requirements and internal policies;
- ~~enforce the terms and conditions that govern the Service; andÂ
- ~~prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
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- ~Other Purposes. We may also use your information as permitted by applicable law or as you may request.
- ~~De-identified and aggregated information. We may use personal information and other information about you to create anonmyzed and/or de-identified aggregated information, such as de-identified demographic information, de-identified location information, device information or any other analysis information we create.
- ~~Share Content with Friends, Family, Colleagues. We may provide functionalities allowing you to provide information about your family, friends or colleagues through a referral program, which may allow you to forward or share our content, such as an email inviting your friend, family or colleague to use our Services. Please only share contact information with us of people with whom you have a relationship (e.g. relative, co-worker, neighbor, etc.) Â
- ~~Consent. We may use your personal information for other purposes that are disclosed to you at the time your provide your information or with your consent.
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With whom do we share your information?
We may share your information with third party service providers for the purpose of administering and providing our Services to you. We restrict access to your information to authorized employees and staff and we do not share your information with third parties, except in the circumstances explained below. We share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.Â
- ~Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics). For example, we may use Google Analytics to collect and process analytics information on our Services.Â
- ~Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.Â
- ~Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Probably Something (including, in connection with a bankruptcy or similar proceedings).
Our employees and authorized contractors may need to access information about you when they require this to perform their jobs. For example, a customer support representative would need access to your account to validate your identity and respond to your question or request; our email communications team would need access to your contact information to ensure this information is sent correctly and any unsubscribe requests are properly managed; and our security staff would need to review information to investigate attempted denial of service attacks, fraudulent account activity, or other attempts to compromise our Services. Â All our employees and contractors are required to agree to maintain the confidentiality and to protect the privacy of your personal information.
In addition, we may be required to disclose information about you if we believe it is necessary to investigate, prevent, or take action: (a) against illegal activities, fraud, situations involving potential threats to our rights or property (or to the rights or property of those who use our Services), or to protect the personal safety of any person; or (b) regarding situations that involve the security of our Services, abuse of the Services infrastructure, or the Internet in general (such as voluminous spamming, or denial of service attacks).Â
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Your choices and rights about your personal informationÂ
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information. You have the following choices with respect to your personal information.Â
- ~Cookies. Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device.  You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please be aware that if you disable cookies and/or other tracking tools, then some parts of our Sites may not be accessible, may not function properly, or may decrease your user experience. For information about cookies employed by our Services and how you can control them, see our Cookie Policy [Insert link]. Â
- ~Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.Â
- ~Marketing or Promotional Materials. We currently do not engage in any marketing. However, if this changes in the future, and if you do not wish to have your email address/contact information used by us to promote our own, or third parties’ products or services, you can opt-out by contacting us at privacy@probablysomething.io. You may also instruct us to not contact you in the future with respect to our newsletters, promotional material’s, if any, etc. You may exercise your rights under this unsubscribe procedure by following the procedure outlined in the below paragraph titled “How to Contact Us”.
- ~Declining to provide information. We aim to collect as little personal information as possible to provide you with our Services. We will inform you at the time of collection what information is necessary for us to provide our Services to you. We may, however, be unable to provide other services, such as customer support, without you providing your personal information to us.
- ~Rights About Your Personal Information. Some countries have laws regarding your personal information. In some circumstances, users in the European Economic Area (EEA) have a right to (a) request a copy of their information (b) request that we correct inaccuracies relating to their personal information (c) request that their information be deleted, or request access (d) request a structured electronic version of their personal information and (e) object to use of their information. Should you wish to make a request in respect of your personal information please contact us at privacy@probablysomething.io. You may also have the right to object to our processing of your personal information and to send you marketing, if any, and we will stop processing data for that purpose. Please see the paragraph above - Your Choices and Rights About Your Personal Information – Marketing or Promotional Materials for instructions on opting out. In some circumstances we will not be able to comply with your request regarding your personal information. If we are unable to remove any of your personal information, we will let you know why we cannot.
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Other sites and services
As noted above, our Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.
We also do not control third parties’ collection or use of your personal information, or otherwise, to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative, the European Digital Advertising Alliance and the Digital Advertising Alliance of Canada .
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Security
We have put in place physical, electronic, and managerial procedures to safeguard your personal information and help prevent unauthorized access, to maintain data security, and to correctly use the data we collect. We attempt to collect as little personal information as possible to provide you with our Services. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. We cannot guarantee you that the information we collect will never be used or disclosed in a manner that is inconsistent with this Privacy Policy. Â
Please note that, although we maintain safeguards to protect your Personal Information, no Internet system is 100% secure and, therefore, we cannot and do not guarantee the security of information transmitted to us. You use our Services and Sites at your own risk. By accessing our Sites or Services, or providing us with your personal information, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach we will attempt to notify you electronically by posting a notice on our Sites, by mail, or by email.
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International data transfers
Our Services and Websites are operated by us from the United States of America and are not intended to be subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our products, Services or Websites you consent to the transfer of your information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country or local law.
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Data retention
We will retain your information for as long as necessary to fulfill the purposes we have outlined in this Privacy Policy, unless a longer period is required or permitted by law.Â
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Protecting the privacy of children under the age of 13
Our Websites are designed for and directed for use by persons over the age of 18 years and should only be accessed by individuals who are at least 18 years old and are using our Websites, products, or Services. Our Sites and Services are not intended for use by anyone under the age of 18 years of age.Â
If we learn that we have collected personal information through our Services from a child under the age of 13 years, without the consent of the child’s parent or guardian as required by law, we will delete it. We do not knowingly or intentionally collect or maintain personal information from children under the age of 13 years. If you are under the age of 13, do not use or provide any information on our Websites, mobile applications or on or through any of their features, make any purchases through our Websites, use any of the interactive or public comment features of our Websites or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If you believe we might have mistakenly collected personal information from someone not allowed to use our Websites, products or Services please contact us at privacy@probablysomething.io. We will delete such information immediately, unless we are legally required to keep it.
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Specific provisions for california residents
This section of our Privacy Policy applies to you if you are a California resident. Certain terms used in this section have the meanings given to them in the California Consumer Privacy Act of 2018 (“CCPA”). As required by the CCPA, our Privacy Policy describes the categories of personal data collected, processed, and disclosed by us, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed. Â
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Categories of Personal Information We Collect (for information we have collected please refer to the section of this Policy titled - “Type of Information We Collect and How”).
- ~Identifiers (e.g. name, mailing address, email address, phone number, credit/debit card number);
- ~Characteristics of protected classifications (e.g., gender, age);
- ~Commercial information (e.g., products or Services purchased, purchase history);
- ~Inferences drawn from any of the above to create a profile about you (e.g., preferences or characteristics)
- ~Internet or other electronic network activity (e.g., browse or search history);
- ~Geolocation data (e.g., latitude or longitude);
- ~Other information that identifies or can be reasonably associated with you.
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Use of Categories of Personal InformationÂ
We may disclose the categories of Personal Information identified above for our operational purposes where the use is reasonably necessary and proportionate to achieve the operational purpose for which it was collected or processed, or for another compatible operational purpose.
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Categories of Sources from which we will have collected Personal Information about you (for more information, see the sections of this Privacy Policy titled – “Type of Information We Collect and How”).
- ~Consumer Directly (e.g., probablysomething.io, mobile, customer relations)
- ~Advertising Networks (e.g., Google)
- ~Data analytics providers (e.g., Google Analytics)
- ~Government Entities (e.g., IRS)
- ~Social networks (e.g., Discord, Twitter)
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Business or Commercial purposes for which we will have collected or sold Personal Information about you in the prior 12 months (for more information, see sections of this Privacy Policy titled - “Type of Information We Collect and How” and “How We Use Your Information”).
- ~Performing Services, including maintaining or servicing our Sites and customer accounts, providing customer service, verifying customer information, providing or engaging in
- ~ advertising or marketing services, providing analytics services, or providing similar services;Â Â
- ~Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;Â
- ~Debugging to identify and repair errors that impair existing intended functionality;
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Categories of Personal Information sold (as defined under California law)
- ~Internet or other electronic network activity (e.g., “cookies” or other tracking tags)
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Categories of Personal Information we may have disclosed for a business purpose in the preceding 12 months
- ~Identifiers (e.g., name, mailing address, email address, phone number, credit/debit card number)
- ~Characteristics of protected classifications (e.g., gender, age)
- ~Commercial information (e.g., products or services purchased, purchase history)
- ~Internet or other electronic network activity (e.g., browse or search history)
- ~Professional or employment related information
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We may disclose the above listed categories of personal information to third parties for business purposes as described above under the Section titled “With Whom Do We Share Your Information?” in this Privacy Policy. In a preceding twelve (12) month period, we will have disclosed all the categories of personal information detailed above for business purposes.
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As previously noted in this Privacy Policy, we do not “sell” (as such term is defined in the CCPA) your Personal Information. California residents may opt out of “sales” of their personal information by contact ing us at privacy@probablysomething.io.
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You Have the Following Rights under the CCPA:
- ~Right to request, twice in a 12 month period, access to the personal information we have collected about you over the past 12 months, including: (i) the categories of personal information we collect about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) the categories of third parties with whom we have shared your personal information; (v) the specific pieces of personal information that we have collected about you.
- ~Right to request that we delete personal information we have collected from you, except information we are required to retain by law, regulation or to protect the safety, security, and integrity of Probably Something.
- ~Right to request that we rectify inaccurate information about you. By visiting your Site account settings, you can correct and change certain personal information associated with your account.
- ~Right to restrict processing. In certain instances where we may process your personal information, you may have the right to restrict or limit the ways in which we use your personal information.
- ~Right not to be discriminated against for exercising your rights under the CCPA.
- ~You also have a right to submit your request via an authorized agent. If you use an authorized agent to submit a request to access or delete your personal information on your behalf, the authorized agent must: (1) be a person or business entity registered with the California Secretary of State to conduct business in California; (2) provide proof of such registration; and (3) provide documentation or other proof indicating that they are authorized to act on your behalf. We may also require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.Â
- ~Right to opt-out
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Do Not Sell My Personal Information
When you use our Sites, certain vendors and contractors may be authorized to collect cookies and similar technologies and may use this data for their own purposes. This activity may qualify as a “sale” under the CCPA. You can make choices to allow or prevent such uses. To opt-out of Probably Something making information relating to cookies, and similar technologies, available to third parties for their own purposes, you may use this [INSERT LINK] to opt-out of Probably Something making information relating to cookies, and similar technologies, available to such third parties. To opt-out click the “Decline Cookies” button. Â
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California Online Privacy Protection Act Notice Concerning Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please click here.
Some of our third party partners, such as web analytics companies, may collect information about you and your online activities over time and across our Services and other online properties. These third parties may not change their online tracking policies in response to DNT settings in your web browser and we do not obligate these partners to honor DNT settings. We may utilize Google Analytics for our web analytics and you can opt-out of your usage data being included in our Google Analytics reports by visiting Google Analytics Opt-Out.Â
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Nevada privacy rights
Nevada users have the right to instruct us not to sell their personal information. As stated in this Privacy Policy, we do not rent, trade, or sell personal information of Nevada consumers as those terms are defined under the law. In the event we choose to do so in the future, we will update this online Privacy Policy to provide an opportunity for Nevada consumers to be verified and exercise their opt-out rights under that law.
Information for users outside of the united states
In this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR. “Personal Data” generally means information that can be used to identify a person, and “processing” generally refers to actions that can be performed on data such as its collection, use, storage, or disclosure.
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined in this section.
If you are visiting our Websites from outside of the United States, please be aware that the information we obtain about you will be processed in the United States or in other jurisdictions. By using our Websites, you agree that any Personal Data which you provide will be treated in accordance with the laws of the United States. In addition, you acknowledge and consent to the international transfer and processing of your Personal Data as described in this Privacy Policy. Please know that the data protection laws and regulations that apply to your Personal Data transferred to the United States or to other countries may be different from the laws in your country of residence.
Where applicable, this section is intended to supplement, and not replace, our Privacy Policy. If there are any conflicts between this section and the other parts of our Privacy Policy, then the policy or portion that is more protective of your Personal Data will control to the extent of such conflict.
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- ~Our Contact Information
Please contact privacy@probablysomething.io for any questions, complaints, or requests regarding this section and include in the subject line “GDPR Request”.
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- ~Types of Personal Data We Collect
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We currently collect and otherwise process the kinds of Personal Data listed above in the Privacy Policy.
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- ~How We Get Your Personal Data and Why We Have It
We receive your Personal Data in the ways and for the purposes listed above in this Privacy Policy. Under the GDPR, the lawful bases we rely on for processing this information are:
- ~~Your consent. You can remove your consent at any time. You can do this by contacting us via email at privacy@probablysomething.io with the subject line “GDPR Request”.
- ~~We have a contractual obligation. We process Personal Data as necessary to provide our Services to you in accordance with the Terms of Use.
- ~~We have a legitimate interest. We handle Personal Data on the ground that it furthers our legitimate interests in commercial activities in ways the do not override the fundamental rights and freedoms of affected individuals such as: (i) protecting our business, personnel and property, (ii) customer service, (iii) marketing, (iv) analyzing and improving our business and (v) providing protection of Personal Data.
- ~~Information Security. We process Personal Data, and the information collected through cookies, and when you use our Services to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking Services usage, combating distributed denial-of-service (DDOS) or other attacks, and removing or defending against malicious individuals or programs.
- ~~Services Operation and Improvement. We process server log information and information collected through cookies pursuant to our legitimate interest in operating and improving our Services.
- ~~Audience Measurement and Retargeting. Pursuant to a user’s consent, we use analytics cookies, and collect identifiers through such cookies, for purposes of audience measurement, analytics, audience reaction to our Services, and creating relevant user experiences.
- ~~General Business Development and Management. We process Personal Data pursuant to our legitimate interest in creating and managing our business relationships with European Individuals, including without limitation:
- ~~~To respond to inquiries from European individuals;
- ~~~To provide European Individuals with information about our products and services; and
- ~~~To assist European Individuals with any issues while using our Services.
- ~~Direct Marketing.  We currently do not send out email marketing. However, we may in the future send email marketing to European individuals pursuant to their consent. When you use our Services, email marketing may be sent to you pursuant to our legitimate interest in sending marketing communications to you in the context of such engagement.Â
- ~~Protection of Rights: We may also disclose Personal Data to respond to claims of violation of third party rights or to enforce and protect our rights.Â
- ~~We have a legal obligation: We may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
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- ~How We Store Your Personal Data
We use commercially reasonable administrative, technical, and physical safeguards to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, for which we consider the nature of the Personal Data, its processing, and the threats posed to it. Unfortunately, no data transmission or storage system can be guaranteed to be always secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us via email at privacy@probablysomething.io.
We retain your Personal Data for as long as needed to fulfill the purposes for which we obtained it, as further described in this Privacy Policy. We will only keep your Personal Data for as long as allowed or required by law.Â
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- ~Your Rights as European Users and Data Subjects
Under data protection law, you have rights, which include:
- ~~Right of access: You have the right to ask us for copies of your Personal Data.
- ~~Right to rectification: You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- ~~Right to erasure: You have the right to ask us to erase your Personal Data in certain circumstances.
- ~~Right to restriction of processing: You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.
- ~~Right to object to processing: You have the right to object to the processing of your Personal Data in certain circumstances.
- ~~~Right to data portability: You have the right to ask that we transfer the Personal Data you gave us to another organization, or to you, in certain circumstances.
- ~~Right to withdraw consent: You have the right to withdraw your consent where consent is used as the legal basis for processing your Personal Data.
- ~~Objecting to Legitimate Interest/Direct Marketing: You may object to Personal Data processed pursuant to our legitimate interest. In such case, we will no longer process your Personal Data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your Personal Data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to privacy@probablysomething.io with the subject line “GDPR Request”. In such case, your Personal Data will no longer be used for that purpose.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at privacy@probablysomething.io with the subject line “GDPR Request” if you wish to make a request.
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- ~How To Complain
If you have any concerns about our use of your Personal Data, you can make a complaint to us at privacy@probablysomething.io with the subject line “GDPR Request”.
You also have the right to lodge a complaint about the processing of your Personal Data with a supervisory authority of the European state where you work or live or where any alleged infringement of data protection laws occurred. A list of most of the supervisory authorities can be found here:http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
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- ~Corporate restructuring
In the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all our assets, the information that we have collected, including Personal Data, may be transferred to the surviving, or acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such Personal Data as set forth in this section.
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How to contact usÂ
Email: privacy@probablysomething.io
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