Privacy Policy

Last updated: May 4, 2021

You must be at least 18 years old to use www.kubyo.com (the “Site,” “Kubyo,” “Us,” and/or “We”). Kubyo’s owner, MGMS LLC, its parent, subsidiary, and affiliated companies, and each of their respective officers, directors, members, owners, employees, agents, and representatives are incorporated into and included in any reference to the Site, Kubyo, Us, and/or We herein.

We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on how and why We collect, store, use, and share your personal information when you use the Site and/or Our mobile application (the “Kubyo Mobile Application”) and/or the services made available through the Kubyo Mobile Application and/or the Site (the “Kubyo Services”). This Privacy Policy also explains your rights in relation to your personal information and how to contact Us.

Your use of the Site is governed by Our Terms. By accessing, using, and/or submitting information to the Site, you agree to this Privacy Policy and to Our Terms. Your use of the Kubyo Mobile Application is further governed by the Terms of Service.

1. Contact Information

If you have any questions or concerns regarding your privacy rights or Our Privacy Policy or practices, you may contact Us at support@kubyo.zendesk.com.

2. Personal Information We Collect About You

We obtain the categories of personal information listed in the chart below from the following categories of sources:

Directly from you; We collect any personal information which you submit directly to the Site and/or the Kubyo Mobile Application and/or the Kubyo Services.

To the extent that you register for an account, We collect information the following personal information which you provide on Our registration form: your U.S. mobile phone number, first name, last name, email address, address, state of residence, account type (personal or business), and profile image.
To the extent that you contact Us or request customer support, We collect the personal information that you submit, including your name and email address.
To the extent that you provide your details to receive payments earned through the Kubyo Services, We collect your ACH and/or Paypal account information.

Indirectly from you; for example, from observing your actions on the Site or the Kubyo Mobile Application thorough cookies and tracking pixels. A cookie is a small data text file, which is stored on your computer’s hard drive (if your web browser permits) that can later be retrieved to identify you to Us. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can later be retrieved to identify you to Us. Personal information that We store about you may be linked to the information stored in and obtained from cookies. Cookies make your use of the Site easier, make the Site run more smoothly, and help Us to maintain a secure Site. Tracking pixels (also known as web beacons, 1×1 pixels, or clear GIFs) are code requiring a call back to a server to render, and which deliver information to Us about your IP address and information from your browser.

To the extent you use the Site and/or the Kubyo Mobile Application and/or the Kubyo Services, cookies and tracking pixels are used to track your interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services, including clicks. Cookies and tracking pixels may collect information about you, such as your IP address, your last login, your browser type and version, device id, operating system, software and platform, your Internet service provider, geographic location, the area code and zip code associated with your server, time zone setting, the date and time of your visit, the time spent on the Site, referring and exit domain names and websites, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords, and clickstream data.
To the extent that you click on any promotional offers featured on the Site and/or the Kubyo Mobile Application and/or the Kubyo Services, we automatically collect information. We automatically collect information when an individual clicks on promotional offers which you share through the Kubyo Services, through the use of cookies and tracking pixels. We may receive compensation from third party advertisers and advertising network(s) based on the performance of the promotional offers which you share through the Kubyo Services. Third party cookies and tracking pixels may also be used to track the performance (sales and leads) of such shared promotional offers. We and Our third party advertisers and advertising network(s) automatically collect information on whether recipients of the shared promotional offer interacted with it. To the extent that an individual clicks on a promotional offer shared through the Kubyo Services, We and the applicable third party advertisers and advertising network(s) collect information on which link was clicked and whether any sales and/or leads were generated.

Tracking and How We Respond to Do Not Track Signals

You can instruct your web browser to refuse all cookies or to indicate when a cookie is being sent, by visiting the preferences or settings page of your web browser. In the event that your browser requests that We do not track you or store a cookie, unless otherwise required by law to honor the requests, We do not guarantee that We will honor such requests. Please note that We do not guarantee that the Site and/or the Kubyo Mobile Application and/or the Kubyo Services will work properly in the event that you elect to opt out of Our tracking or use of cookies.

Categories of Personal Information We Collect

We collect, use and are responsible for certain personal information about you, that identifies, relates to, describes, is reasonably capable of being associated with you, or that which could reasonably be linked, directly or indirectly, with a particular consumer or household. We collect, and have collected personal information about Our visitors within the preceding 12 months in the following categories:

Categories of Personal Information	Collected?	Categories of Sources from Which PI is Collected	Business or Commercial Purpose for Which Each Category Will be Used
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers	Yes	Site; Kubyo Mobile Application	- Provide you with the ability to access and interact with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Track access and interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services and/or the performance of the shared promotional offers (counting sales and leads derived from shared promotional offers); - Fulfill your requests submitted; - Personalize and improve the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Site, Kubyo Mobile Application, and Kubyo Services functionality - Advertising/marketing; - Internal database; - Analytics; - Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; - Debug to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Process and make payments to Our users; and - Legal compliance
Any categories of personal information described in subdivision (e) of Section 1798.80	Yes	Site; Kubyo Mobile Application	- Provide you with the ability to access and interact with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Track access and interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services and/or the performance of the shared promotional offers (counting sales and leads derived from shared promotional offers); - Fulfill your requests submitted; - Personalize and improve the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Site, Kubyo Mobile Application, and Kubyo Services functionality; - Advertising/marketing; - Internal database; - Analytics; - Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; - Debug to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Process and make payments to Our users; and - Legal compliance
Characteristics of protected classifications under California or federal law	No	N/A	N/A
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Yes	Site; Kubyo Mobile Application	- Provide you with the ability to access and interact with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Track access and interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services and/or the performance of the shared promotional offers (counting sales and leads derived from shared promotional offers); - Fulfill your requests submitted; - Personalize and improve the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Site, Kubyo Mobile Application, and Kubyo Services functionality; - Advertising/marketing; - Internal database; - Analytics; - Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; - Debug to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Process and make payments to Our users; and - Legal compliance
Biometric information	No	N/A	N/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement	Yes	Site; Kubyo Mobile Application	- Provide you with the ability to access and interact with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Track access and interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services and/or the performance of the shared promotional offers (counting sales and leads derived from shared promotional offers); - Fulfill your requests submitted; - Personalize and improve the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Site, Kubyo Mobile Application, and Kubyo Services functionality; - Advertising/marketing; - Internal database; - Analytics; - Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; - Debug to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Process and make payments to Our users; and - Legal compliance
Geolocation information	Yes	Site; Kubyo Mobile Application	- Provide you with the ability to access and interact with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Track access and interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services and/or the performance of the shared promotional offers (counting sales and leads derived from shared promotional offers); - Fulfill your requests submitted; - Personalize and improve the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Site, Kubyo Mobile Application, and Kubyo Services functionality; - Advertising/marketing; - Internal database; - Analytics; - Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; - Debug to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Process and make payments to Our users; and - Legal compliance
Audio, electronic, visual, thermal, olfactory, or similar information	No	N/A	N/A
Professional or employment-related information	No	N/A	N/A
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)	No	N/A	N/A
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Site; Kubyo Mobile Application	- Provide you with the ability to access and interact with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Track access and interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services and/or the performance of the shared promotional offers (counting sales and leads derived from shared promotional offers); - Fulfill your requests submitted; - Personalize and improve the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Site, Kubyo Mobile Application, and Kubyo Services functionality; - Advertising/marketing; - Internal database; - Analytics; - Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; - Debug to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; - Process and make payments to Our users; and - Legal compliance

As noted in the above chart, We collect the above personal information directly from you via the Site and/or the Kubyo Mobile Application (and/or in connection with the Kubyo Services), and from your interactions with the Site and/or the Kubyo Mobile Application (and/or in connection with the Kubyo Services), including any personal information which you provide to Us directly or indirectly.

3. How We Use Collected Personal Information

Providing the Site and/or the Kubyo Mobile Application and/or the Kubyo Services: We use the personal information We gather on the Site and/or the Kubyo Mobile Application and/or the Kubyo Services to allow individuals to access and interact with the Site and/or the Kubyo Mobile Application and/or to use the Kubyo Services. We display third party promotional offers on the Site and/or the Kubyo Mobile Application and/or the Kubyo Services. We use the information collected through the Site and/or the Kubyo Mobile Application and/or the Kubyo Services to track your access and interaction with the Site and/or the Kubyo Mobile Application and/or the Kubyo Services. We also use the information collected through the Site and/or the Kubyo Mobile Application and/or the Kubyo Services to track the performance of the third party promotional offers featured on the Site and/or the Kubyo Mobile Application and/or the Kubyo Services, which You share with others, including clicks/conversions/leads, and counting sales derived from shared promotional offers. As noted below, tracking performance of shared third party promotional offers requires the sharing of personal information with our third party advertisers and advertising network(s), including clicks/conversions/sales/leads, and counting sales derived from shared promotional offers. Personal information is used to calculate payments earned through shared third party promotional offers and to process and initiate payments earned through the Kubyo Services. We also use information collected through the Site to fulfill any requests which you submit to Us; to personalize and improve the Site and/or Kubyo Mobile Application and/or the Kubyo Services and functionality of the same; for advertising/marketing purposes; to supplement Our internal database; to perform analytic and statistically analyze and monitor use of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; to improve the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; and to detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; and to debug, to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services; and to process and make payments to Our users.

We may share the personal information collected through your use of the Site with Our third party advertisers and advertising network(s). We and Our third party advertisers and advertising network(s) may collect and use personal information about you obtained through cookies and tracking pixels implemented on the Site, to track the performance of a particular promotional offer which You share with others through the Kubyo Services. We and Our third party advertiser and/or advertising network(s) automatically collect information when an individual clicks on a link contained in the shared promotional offer, through the use of cookies and tracking pixels. As noted above, in the event that your web browser requests that We do not track you or store a cookie, unless otherwise required by law to do so, We do not guarantee that We will honor such requests.

Telemarketing, SMS, and Email: We may use the personal information which you submit through the Site in connection with your request to sign up for the Kubyo Services, to process and fulfill your request and account registration, even if your telephone number or cell phone number is listed on a state, federal, or corporate “Do Not Call” list and/or Do Not Email registry.

In connection with your submission of your application for an account for the Kubyo Services, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR § 310 et seq.), as amended from time to time and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commissions Do-Not-Call List, and/or on applicable state do-not-call lists, you agree to be contacted via telemarketing in accordance with such and applicable federal and state do-not-call regulations. You also understand and agree that We may contact you by telephone (including through automated calling or on a recorded line), email, or regular mail based on the information you provided to Us in order to process and fulfill your request, even if you have opted into a state, federal, or corporate “Do Not Call” list and/or Do Not Email registry. We may use your personal information to process your application for an account and in connection with the Kubyo Services.

This site is compliant with the Telephone Consumer Protection Act (47 U.S.C. § 227), as implemented by the Federal Communications Commission. To the extent that you enter your phone number and sign up for the Kubyo Services, you agree that you are 18+ years old, and that you have read and agree to the Privacy Policy, Terms, and Terms of Service and provide your electronic signature expressly consent to the transfer of your personal information and to receive communications from Us and our representatives via email, phone, and/or text at the provided U.S. mobile phone number or email address. You understand that there may be a charge by your wireless carrier for such communications. You understand these communications may be generated using an autodialer and may contain pre-recorded messages and that your consent is not a condition to utilize the Kubyo Services. You understand that your authorization overrides any previous registrations on a federal or state Do Not Call registry.

Information Collected From Third Parties: As noted above in the chart, in addition to collecting personal information through the Site and/or the Kubyo Mobile Application and/or the Kubyo Services, We also collect personal information through third party advertisers and advertising network(s). We may receive compensation from third party advertisers and advertising network(s) based on the performance of the promotional offers which you share through the Kubyo Services. Third party cookies and tracking pixels may also be used to track the performance (sales and leads) of such shared promotional offers. We and Our third party advertisers and advertising network(s) automatically collect information on whether recipients of the shared promotional offer interacted with it. To the extent that an individual clicks on a promotional offer shared through the Kubyo Services, We and the applicable third party advertisers and advertising network(s) collect information on which link was clicked and whether any sales and/or leads were generated. To the extent that you are eligible to receive $300 or more from the Kubyo Services, your W9 tax information is collected by our third party payment processor’s platform.

4. With Whom Do We Share Your Information

We may share personal information in all of the above categories internally with Our parent company and any subsidiary and affiliated companies. We may also share personal information in all of the above categories with Our third party advertisers and advertising network(s), and third party service providers, including Our payment processor service provider. We may also share personal information in all of the above categories with Our third party service providers who provide the platforms and app stores through which the Kubyo Mobile Application is made available, namely, Apple Platforms & Services and Google Platforms & Services. All data collected through the Site, including personal information collected through the Kubyo Mobile Application, and the Kubyo Services, are stored on the Amazon Web Services cloud server. We also disclose personal information in all of the above categories to Our third party service providers to provide Our users with the capabilities to share promotional offers with individual recipients through various channels; to track and report the performance of the promotional offers which Our users share with others (counting sales and leads derived from shared promotional offers); to process and make payments to Our users; and to provide customer support.

We may also share the information in the following category: “commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies”, with individuals who have registered to use the Kubyo Services for the purpose of tracking the performance of the promotional offers which they have shared with others, and calculating payments earned through the Kubyo Services.

Also, on occasion, We may be required by law enforcement or judicial authorities to provide personal information to the appropriate governmental authorities. In the event of a merger, acquisition, or sale of Our business, your personal information may also be transferred. In the event We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or Our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such personal information in a transaction approved by the court.

5. Transfer, Processing, and Storage of Information

Your personal information may be transferred to, processed, and stored outside of your state, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States, please note that the personal information We collect through the Site and/or the Kubyo Mobile Application and/or the Kubyo Services may be processed in and outside of the United States. We will take all the steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and that no transfer takes place to an organization or a country unless there are adequate controls in place including the security of your data. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

6. Security

The security of your data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, We cannot guarantee its absolute security. As a result, you acknowledge that there are security and privacy limitations of the Internet which are beyond Our control; the security, integrity and privacy of any and all information and data exchanged between you and Us through this Site and/or the Kubyo Mobile Application and/or the Kubyo Services cannot be guaranteed; and any such information and data may be viewed or tampered with in transit by a third party. We make no warranty, express, implied, or otherwise, regarding the security of the Site and/or the Kubyo Mobile Application and/or the Kubyo Services and your personal information.

7. Third Party Links and Offers

The Site, Kubyo Mobile Application, and the Kubyo Services contain links to third party promotional offers and to their corresponding websites. We are not responsible for the privacy practices or the content of any such third parties. This Privacy Policy only addresses Our use and disclosure of information which We collect from you. Any third party websites which are accessible through Our Site, Kubyo Mobile Application, and the Kubyo Services and the companies to whom your information is transferred, have their own privacy policies and data collection, use and disclosure practices. Please consult each third party website’s privacy policy. We are not responsible for the policies or practices of third parties or their sites. Additionally, third party advertisers and advertising network(s) may collect personal information about you when you share featured promotional offers, or when individual recipients interact with the shared promotional offers, through the use of cookies and tracking pixels. We cannot control this collection of such personal information. You should contact these third parties directly if you have any questions about their use of the personal information that they collect. Any sharing of offers through third party platforms shall be in compliance with such third party platforms’ terms of service.

8. Children

You must be an adult of 18 years or older to use the Site. We do not target the Site to children. Consistent with the federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), We will never knowingly collect personal information from anyone under the age of 13 without requesting parental consent. If you are aware that your minor child under the age of 13 has provided Us with personal information, please contact Us.

9. California Residents – Your Privacy Rights

California Rights Under Shine the Light

Under California’s Shine the Light law (California Civil Code Section 1789.83), California residents have the right to request, once a year, information on the types of personal information that We have shared with third parties for their direct marketing purposes during the immediately preceding calendar year; and the names and addresses of third parties with whom We have shared the personal information. You have agreed to allow Us to share information with third parties for their direct marketing purposes until you request to opt-out of such sharing. California customers may request further information about Our compliance with this law by contacting Us via email at support@kubyo.zendesk.com. Please note that We are only required to respond to one request per customer each year, and We are not required to respond to requests made by means other than through this email address

California Rights Under the CCPA

In addition, if you are a California resident under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations, your use of the Site is subject to the California Consumer Privacy Act (“CCPA”), and all final, implementing regulations. Under the CCPA, up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. Information regarding Our collection and disclosure practices are detailed herein, in addition to instructions on how to exercise your rights regarding your personal information.

What Personal Information Do We Collect?

We collect, use, and are responsible for certain personal information about you, that identifies, relates to, describes, is reasonably capable of being associated with you, or that which could reasonably be linked, directly or indirectly, with a particular consumer or household. Information on the personal information that We collect, and have collected about Our visitors within the preceding 12 months are detailed above under the “Personal Information We Collect About You” heading.

What Personal Information Do We Disclose

Within the preceding 12 months, we have disclosed personal information to the third parties identified under the “With Whom Do We Share Your Information” heading above. Namely, We disclose personal information in all of the above categories to Our third party advertisers and advertising network(s) for the purpose of tracking the performance of the promotional offers which Our users have shared with others (counting sales and leads derived from shared promotional offers), and calculating payments earned through the Kubyo Services.

We also disclose personal information in all of the above categories to Our third party service providers who provide the platforms and app stores through which the Kubyo Mobile Application is made available, namely, Apple Platforms & Services and Google Platforms & Services. All data collected through the Site, including personal information collected through the Kubyo Mobile Application, and the Kubyo Services, are stored on the Amazon Web Services cloud server. We also disclose personal information in all of the above categories to Our third party service providers to provide Our users with the capabilities to share offers with individual recipients through various channels; to track and report the performance of the promotional offers which Our users share with others (counting sales and leads derived from shared promotional offers); to process and make payments to Our users; and to provide customer support.

We may also disclose your personal information in any of the above categories if legally required to do so, in Our sole discretion, pursuant to a request from a governmental entity, or if We believe in good faith that such action is necessary to (a) conform to legal requirements or comply with legal process; (b) protect Our rights or property, or Our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public. Also, in the event that We, or substantially all of Our assets, are acquired, personal information in all of the above categories may be included within the transferred assets. In the event We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or Our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such personal information in all of the above categories in a transaction approved by the court.

What Personal Information Do We Sell?

We disclose for a business purpose and sell personal information in all of the above categories to Our third party advertisers and advertising network(s). Also, in the event that We, or substantially all of Our assets, are acquired, such personal information may be included within the transferred assets. In the event We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or Our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.

Your Right to Request to Know and How to Submit a Verified Request to Know

A “request to know” is a request related to the personal information that a business has about such consumer. It may include a request for any or all of the following from Us:

1. specific pieces of personal information that We have collected about you;
2. categories of personal information that We have collected about you;
3. categories of sources from which the personal information was collected;
4. categories of personal information that We have sold or disclosed for a business purpose about you;
5. categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
6. the business or commercial purpose for collecting or selling personal information.

The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.

To submit a request to know, please email Us at support@kubyo.zendesk.com. To process your request, We may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within Our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, We may require that the authorized agent provide proof that the consumer gave them signed permission to submit the request. In addition, We may also require that the consumer directly verify their identity and directly confirm that they provided the authorized agent permission to submit the request on their behalf. The information which is submitted in conjunction with the request to know will be used for the express purposes of verification and providing responsive information to the request, if required.

Your Right to Request Deletion and How to Submit a Verified Request to Delete

You have the right to request the deletion of any personal information which We have collected about you. To submit a verifiable request to delete, please click here: email Us at support@kubyo.zendesk.com, or contact Us via the Site by clicking on “Contact Us” and submitting your message. To process your request, We may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within Our data records. If you elect to use an authorized agent to exercise your right to submit a request for deletion, We may require that the authorized agent provide proof that the consumer gave them signed permission to submit the request. In addition, We may also require that the consumer directly verify their identity and directly confirm that they provided the authorized agent permission to submit the request on their behalf. The information which you submit in conjunction with your request to delete will be used for the express purposes of verification and fulfilling your request, if required. The information which is submitted in conjunction with the request to delete will be used for the express purposes of verification and fulfilling the request, if required.

We may utilize a two-step process for online requests to delete, whereby you first submit your request to delete, and second, you separately confirm that you want your personal information deleted.

To the extent that your personal information is necessary for Us to maintain for a reason delineated in Cal. Civ. Code § 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, We are not required to comply with your request for deletion. For instance, We are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from Us. If We are unable to verify your request, We will notify you as well.

Your Right to Opt-Out of the Sale of Personal Information and How to Submit a Verified Request to Opt-Out

You have the right to opt-out of the sale of your personal information. You have the right to direct a business that sells (or may in the future sell) your personal information to stop selling your personal information, and to refrain from doing so in the future.

Our Site features a “Do Not Sell My Personal Information” link, which you can click to submit your request to opt-out of the sale of your personal information. You may also email Us at support@kubyo.zendesk.com to submit your request to opt-out of the sale of your personal information. In conjunction with your request, We may request that you provide your first name, last name, a California address, and email address to verify and process your request. The information which you provide will be used to verify your request and to attempt to identify you within Our data records. If you elect to use an authorized agent to exercise your right to submit a request to opt-out of the sale of your personal information, We may require that the authorized agent provide proof of your signed permission demonstrating that the authorized agent has been authorized to act on your behalf. The information which is submitted in conjunction with the request to opt-out will be used for the express purposes of verification and complying with the opt-out request, if required.

Your Right to Non-Discrimination for the Exercise of Your Privacy Rights

California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. However, a business may offer a financial incentive or price or service difference if it is reasonably related to the value of the consumer’s data. A business shall notify consumers of any financial incentive or price or service difference.

10. Changes

This Privacy Policy was published and last updated as of the date noted above. We may update this Privacy Policy from time to time by updating this posting. Changes to this Privacy Policy are effective when they are posted. You acknowledge and agree that it is your responsibility to review this Site and this Privacy Policy periodically and to be aware of any modifications. Your use of the Site after such modifications will constitute your acknowledgment of the modified Privacy Policy; and agreement to abide and be bound by the modified Privacy Policy.

11. Do You Need Extra Help?

If you have a disability which interferes with your ability to access this Privacy Policy, We can make accommodations to present the policy in an alternative format to assist you. If you would like to receive this Privacy Policy in another format that is accessible to your needs (for example: audio, large print, etc.) please contact Us