I. Notice of Collection and Use of Personal Information

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.

Categories of Personal Information

The types of Personal Information we collect about you depends on your interactions with us and your use of the Services. In the past twelve (12) months, we collected the below categories of Personal Information from our users:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.

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

• Characteristics of protected classifications under California or federal law.

• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• 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.

• Geolocation information.

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

• Professional or employment-related information.

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

Use of Personal Information

We collect and process your Personal Information for the following business and commercial purposes:

• To provide you with information, products or services that you request from us.

• To contact you via email or text message with alerts and other notices concerning the Services or Community activities that may be of interest to you.

• For market research conducted on behalf of a My⁠-⁠Take Client.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

• To improve the Site and present its contents to you.

• For testing, research, analysis and product development.

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

• As necessary or appropriate to protect the rights, property or safety of us, our Clients or others.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.

Sources of Personal Information

Directly from you	We collect Personal Information when you provide it to us directly, such as when registering for a Community or visiting our Site, when interacting with community activities, or through interactions with an employee regarding support.
Indirectly from you	We may collect Personal Information including, but not limited to geolocation (when using mobile applications), IP address, cookies and device ID through logging and analytics tools, cookies, pixel tags, and as a result of your use of and access to the Services.
Obtained from government entities	We may obtain Personal Information from public records maintained by various government entities.

Sharing of Personal Information

We share Personal Information with the following categories of parties:

• Our service providers.

• Our business collaborators (Clients or other third parties) who work with My⁠-⁠Take and who have entered into confidentiality agreements with us.

• Government agencies or regulations when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.

In addition, we may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal Information we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

In the past twelve (12) months, we shared for a business purpose the following categories of Personal Information with the following categories of third parties:

• Identifiers (e.g. username): Our business collaborators and other Members

• Identifiers (e.g. name, email address, ZIP code, IP address): Our business collaborators

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)): Our business collaborators

• Characteristics of protected classifications under California or federal law: Our business collaborators

• Commercial information: Our business collaborators

• Audio, electronic, visual, thermal, olfactory, or similar information: Our business collaborators

We do not and will not knowingly sell the Personal Information of minors under the age of 18 without affirmative authorization.

II. Your California Privacy Rights

California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose Personal Information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

The CCPA provides California residents with the following rights:

1. Right to Know: You have the right to request that we disclose certain information to you about the Personal Information we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:

• The categories of Personal Information collected about you;

• The categories of sources from which we collected your Personal Information

• The categories of Personal Information that we have sold or disclosed about you for a business purpose;

• The categories of third parties to whom your Personal Information was sold or disclosed for a business purpose;

• Our business or commercial purpose for collecting or selling your Personal Information; and

• The specific pieces of Personal Information we have collected about you.

2. Data Portability: You have the right to request a copy of Personal Information we have collected and maintained about you in the past 12 months.
3. Right to Deletion: You have the right to request that we delete the Personal Information we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

• Debug to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

• Comply with a legal obligation

• Otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

4. Right to Opt-Out/In: You have the right to opt-out of the sale of your Personal Information. You also have the right to opt-in to the sale of Personal Information. Please see the “Notice of Right to Opt-Out” by clicking on this “Do Not Sell My Personal Information” [Insert internal hyperlink to “Notice of Right to Opt-Out” section] link for more information about your opt-out/in rights.
5. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

III. Submitting A Verified Consumer Request

To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. To exercise your California privacy rights described above, please submit a verifiable request to us by:

• Sending an email to privacy@my-take.com.

• Visiting our CCPA Rights Request Form.

• Submitting a request through your Community.

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

When you submit your request, we will take steps to attempt to verify your identity with your first and last name, username, and email address. We will seek to match the information in your request to the Personal Information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you are registered customer, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your Personal Information, we will only complete your request where we are satisfied that we have verified your identity to a reasonably degree of certainty. We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request on your behalf, we require that the agent send an email to privacy@my-take.com with proof that you gave the agent signed permission to submit the request. We also require that you email privacy@my-take.com to confirm that the agent is permitted to submit the request on your behalf.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require to create an account with us. However, if you do have an existing login, we will require you to log in to submit a request. We will only use Personal Information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

We will acknowledge receipt of the request within ten (10) days of its receipt. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

IV. Sale of Personal Information

While we do not sell your Personal Information to marketers for monetary compensation, the CCPA defines the terms “sell” and “sale” very broadly, such that some of our research-related activities might fall within the definition of “sale” under certain circumstances. In the past twelve (12) months, we have sold the following categories of Personal Information to the following categories of third parties:

• Identifiers (e.g. name, contact information, username, email address): Our business collaborators

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)): Our business collaborators

• Characteristics of protected classifications under California or federal law: Our business collaborators

• Commercial information: Our business collaborators

• Audio, electronic, visual, thermal, olfactory, or similar information: Our business collaborators

We “sell” your Personal Information for the following business or commercial purposes:

• Providing, predicting, or performing, including maintaining or servicing accounts, providing customer service, and verifying customer information.

• Marketing the Services to you, including sending you messages about the Services, which may include rewards, events, and special offers.

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

• Debugging to identify and repair errors that impair existing intended functionality.

• Undertaking internal research for technological development and demonstration.

• Undertaking activities to verify or maintain the quality or safety of the Services or devices owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Services or devices owned, manufactured, manufactured for, or controlled by us.

Notice of Right to Opt-Out

Please see our “Notice of Right to Opt-Out” on our “Do Not Sell My Personal Information” page for more information about your opt-out rights.

If you are a California resident, you have the right to opt-out of the sale of your Personal Information to third parties. To exercise this right, please click “Do Not Sell My Personal Information” and submit the form, or email privacy@my-take.com.

Do Not Track

We currently do not use any tracking technologies and do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

V. Modifications and Updates to this California Notice

This California Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right to amend this California Notice at our discretion and at any time. When we make changes to this California Notice, we will give you notice of such changes by posting the revised policy on this Site, in links in the Communities and where appropriate, by other means. Your continued use of the Services following our posting of any revised California Notice will constitute your acknowledgement of the amended California Notice.

VI. Contact Information and Assistance

If you have any questions or comments about this California Notice, the ways in which we collect and use your Personal Information, or your choices and rights regarding such use, please email us at privacy@my-take.com or by mail using the address below:

My⁠-⁠Take
Attn: Privacy Officer
2000 West Park Drive, Suite 240
Westborough, MA 01581