CCPA Notice
Supplemental Privacy Notice for California Residents
Last update on 9 January 2023
The California Consumer Privacy Act of 2018, as may be amended from time to time, including by the California Privacy Rights Act of 2020 (collectively, the “California Privacy Laws”), establish specific rights for you regarding your personal information and requires businesses to provide specific information on, and abide by certain responsibilities with respect to, how personal information is collected, used and disclosed.
This Supplemental Privacy Notice for California Residents (“Notice”) applies solely to individuals who are residents of the state of California and who use our Services (“consumers”, or “you”), and provides you information required by, and further specifies your rights and our responsibilities under, the California Privacy Laws. This Notice supplements the information contained in our Privacy Notice, which provides additional and more comprehensive information on how and why Yousician Ltd. (“our”, “us”, or “we”) collects and processes your personal information.
Unless otherwise expressly stated, any terms in this Notice shall have the same meaning as in our Privacy Notice or as otherwise defined under the California Privacy Laws.
1. HOW WE COLLECT AND USE PERSONAL INFORMATION
When we use the term “personal information” in this Notice we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. For additional information on our personal information collection, please refer to our Privacy Notice.
Depending on the Services you have used, in the last 12 months we have collected the following categories of personal information about you:
| Category of Personal Information | Sources |
| Identifiers, such as your name, alias, online identifier, IP address, email address, account name, device ID, advertising ID, or other similar identifiers that we may assign to your account. |
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| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your name. |
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| Commercial information, such as information regarding purchases you have made. |
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| Internet or other electronic network activity information, such as information regarding your interaction with our Services, including your progress in the app, and your interactions with ads we have inside and outside our Services. |
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| Geolocation data, such as your general location determined based on your IP Address. |
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| Financial Information
We use payment processors that are our service providers to process your payment transactions on our behalf. They have access to your credit card data, while we may only obtain access from our payment processors to limited card data (four last digits) occasionally to allow us to solve issues related to purchases. |
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| Sensitive Personal Information, such as your account access credentials sufficient to access your account with our Services (e.g. username and corresponding password). |
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We may use this personal information for the following business purposes referred to in the California Privacy Laws:
- auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- helping to ensure security and integrity, such as to detect security incidents, resist malicious, deceptive, fraudulent, or illegal actions, and potentially prosecuting those responsible for such actions, and to ensure the safety of our users and other natural persons;
- debugging to identify and repair errors in our Services;
- short-term, transient uses, including but not limited to non-personalized advertising;
- performing our Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, and processing payments;
- advertising and marketing services;
- internal research for technological development and demonstration; and
- activities to verify or maintain the quality and safety of our Services, and improving, upgrading, and enhancing our Services.
With respect to your sensitive personal information, we only use such information for the business purpose of performing our Services, such as setting up and maintaining your account in our Services, ensuring the security and integrity of your account and the Services, providing customer service, processing or fulfilling your orders and transactions, verifying your customer information, verifying or maintaining the quality and safety of our Services, and processing payments.
2. TO WHOM WE DISCLOSE AND HOW WE MAY SELL OR SHARE PERSONAL INFORMATION
As described in the “Who Can See Your Data” section of our Privacy Notice, we disclose information to a variety of recipients, such as our service providers and contractors, to achieve the business purposes described herein. The categories of personal information we disclose for a business purpose are listed in the table under Section 1, above.
We disclose personal information to, or allow access to personal information by, the following categories of recipients:
- Yousician group companies;
- Customer support platforms;
- Hosting service providers;
- Payment processors;
- Analytics partners;
- Third party account providers;
- Social media services; and
- Advertising partners.
Online Advertising
We let certain third party advertising partners collect certain categories of personal information identified above in Section 1 for online advertising purposes, including cross-context behavioral advertising. These third party businesses collect personal information directly from a device or browser through cookies or similar tracking technologies when a consumer visits or interacts with our websites, uses our apps or Services, or otherwise engages with us online. These third parties use your personal information to serve relevant ads inside our Services or outside our Services on other websites or mobile apps, to serve you personalized advertising based on your interests and behavior, and to carry out other services related to online advertising, such as analytics, reporting and attribution (meaning tracking the source of installs related to ads seen inside and outside the Services). These third parties may use collected personal information for their own purposes in accordance with their own privacy policies. Please see here for more information about how third parties use cookies and related technologies to collect information automatically on our websites, apps, Services and other online services. Because this disclosure of information can be interpreted as a “sale” or “sharing” of personal information, as defined in the California Privacy Laws, we provide you the possibility to opt-out from us selling or sharing your personal information with our advertising partners for this purpose. Please learn more about your opt-out right below under Section 4 of this Notice.
3. RETENTION OF PERSONAL INFORMATION
We retain your personal information (including your sensitive personal information) for as long as your user account is active or upon receipt and compliance with your verifiable request to delete your personal information or as otherwise needed to provide the Services. You may end this relationship by deleting your account using the functionalities made available in our Services. We will then delete all your personal information (including your sensitive personal information) from our own and our service providers’ systems, including backups, within 30 days, unless otherwise permitted to retain the personal information under the California Privacy Laws. We also periodically review and delete or de-identify user accounts that have been inactive for five years or other information.
4. YOUR RIGHTS AND CHOICES
The California Privacy Laws grant California residents various rights concerning their personal information. When you submit a request to exercise your rights, we are required to verify that you are the consumer to whose personal information the request relates or that you are the person authorized to act on behalf of such consumer. If you use the automated tools provided in our Services, we will typically not need any additional information to verify your request. If you submit your request by other means (i.e. email), we may need to ask you for additional information to validate that you are the account holder or have the right to act on behalf of the account holder. In certain circumstances, we may decline a request to exercise the right to know, right to delete and right to correct, particularly where we are unable to verify your identity.
Right to know
You have the right to request that we disclose to you, upon verification of your identity, what categories of personal information we have over the past 12 months collected about you, from which categories of sources, for which purposes we have collected, sold or shared that information, and the categories of third parties to whom we have disclosed the information to. You also have the right to request a copy of the specific pieces of personal information we have collected about you. To learn what categories of personal information, from what sources, for which business purposes we disclose the personal information, and the categories of third parties to whom we disclose your personal information, please refer to Section 1 and 2 of this Notice. To learn how we “sell” or “share” your personal information within the meaning of the California Privacy Laws, please refer to “Online Advertising” in Section 2. To request a copy of your personal information, please use the automated tools in our Services. Alternatively, you can contact us by email at the email address stated under the section “Contact Us” of this Notice.
Right to request deletion
You have the right to request that we delete any personal information we have about you. For deleting your personal information, we encourage you to use the automated tools made available in our Services. Alternatively, you can contact us by email at the email address stated under the section “Contact Us” of this Notice. For more information, please refer to Section 7 of our Privacy Notice. Following receipt of your verifiable request, we will delete or de-identify your personal information from our records, notify our service providers and contractors to delete your personal information from their records, and notify all third parties to whom we have sold or shared your personal information to also do so, unless this proves impossible or involves a disproportionate effort. In connection with your request, we may maintain a confidential record of your request for the purposes of preventing your personal information from being sold, to comply with laws or for other purposes permitted by the California Privacy Laws.
We may have a lawful right to retain your information under the California Privacy Laws. For example, we may deny your request if retaining your personal information is reasonably necessary to help ensure security and integrity, or to comply with a legal obligation.
Right to opt out
You have the right to direct us to not sell or share your personal information, which, in our case, means that we shall no longer sell or share your identifiers and other personal information with our ad partners to make the ads you see inside and outside of our Services (as applicable) more relevant to you. To exercise your right to opt-out, please use the automated tool provided in our Services. The “Do Not Sell or Share My Personal Information” tab can be found in the app settings under the “privacy” or other similar heading.
Right to correct
You have the right to request us to correct any inaccurate personal information we may hold on you. For correcting your personal information, we encourage you to do so by editing your personal details on your profile if your personal information changes or happens to be incorrect. Alternatively, you can contact us by email at support@yousician.com. Following receipt of your verifiable request, we will use our reasonable efforts to correct the inaccurate personal information that we hold on you provided that such corrections would not be impossible, do not raise concerns over the accuracy or integrity of the information requested to be corrected, and do not create disproportionate effects on the Services.
Right to limit use and disclosure of sensitive personal information
You have the right, at any time, to direct us to limit the use or disclosure of your sensitive personal information to that use which is necessary to perform the Services or as otherwise permitted under the California Privacy Laws. We do not use or disclose your sensitive personal information for purposes other than as is necessary to perform the Services or in connection with the limited business purposes set out under Section 1 of this Notice. In the event that we use or disclose your sensitive personal information for purposes other than as described under this Section, or as otherwise permitted under the California Privacy Laws, we shall notify you of this fact and your right to direct us to limit the use or disclosure of your sensitive personal information.
Right to non-discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above.
5. CHANGES TO THIS NOTICE YOUR RIGHTS AND CHOICES
We reserve the right to amend this Notice at our discretion and at any time and may update it due to changes in our operations, in the processing of personal information, or changes under law. The date this Notice was last updated is identified at the top of this page. You are responsible for periodically visiting our website and this Notice to check for any changes.
6. CONTACT US
If you have any questions about this Notice, the ways we collect or use your personal information, your rights and choices regarding such use or if you wish to exercise your rights under the California Privacy Laws, you may contact us via email at privacy@yousician.com.