Privacy Notice for California Residents

This Privacy Notice for California Residents (Notice) is a part of the Newvoy Ltd. Privacy Policy and Terms of Service and applies, as do the terms of the Privacy Policy and Terms of Service, solely to visitors, users, and others who reside in the State of California ("consumers" or "you") in compliance with the California Consumer Privacy Act of 2018 (CCPA). Please read the Privacy Policy and Terms of Service in addition to this Notice. Newvoy Ltd. hereby adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) (effective January 1, 2020). Any terms defined in the CCPA have the same meaning when used in this Notice.

1. Information we collect

For the purposes of this Notice, "personal information" includes information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

Category	Categories of sources	Collected
A. Identifiers	Categories of sources: you personally, our Services, or our service providers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)	Categories of sources: you personally.	YES
C: Protected classification characteristics under California or federal law	Categories of sources: None.	NO
D: Commercial information	Categories of sources: our Services or our service providers.	YES
E: Biometric information	Categories of sources: None.	NO
F: Internet or other electronic network activity information	Categories of sources: our Services or our service providers.	YES
G: Geolocation data	Categories of sources: you personally, our Services, or our service providers.	YES
H: Audio, electronic, visual, thermal, olfactory, or similar information	Categories of sources: None.	NO
I: Professional or employment-related information	Categories of sources: None.	NO
J: Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)	Categories of sources: None.	NO
K: Inferences drawn from other personal information	Categories of sources: you personally, our Services or our service providers.	YES

Personal information does not include:

publicly available information from government records,
de-identified or aggregated consumer information,
information excluded from the CCPA's scope, including:

- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data,
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the personal information listed above directly from you when you submit it to us and indirectly from you (for example, through cookies or other tracking mechanisms). For more information about how we collect your personal information, see Section 2 of the Privacy Policy.

2. Disclosing personal information for business purposes

We may disclose your personal information for business purposes set forth in Section 2 and Section 3 of the Privacy Policy to third parties set forth in Section 4 of the Privacy Policy (service providers such as data aggregators, advertising networks, internet providers, data analytics providers, operating systems and platforms, social networks, and other third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you, etc.). When we disclose personal information for business purposes, we enter into a contract that describes the purpose of such information and requires the recipient to both keep that personal information confidential and not use it for any purpose except the execution of the contract. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

We have disclosed the following categories of personal information within the last twelve (12) months:

Category	Disclosed
A. Identifiers	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)	NO
C: Protected classification characteristics under California or federal law	NO
D: Commercial information	YES
E: Biometric information	NO
F: Internet or other electronic network activity information	YES
G: Geolocation data	YES
H: Audio, electronic, visual, thermal, olfactory, or similar information	NO
I: Professional or employment-related information	NO
J: Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)	NO
K: Inferences drawn from other personal information	NO

3. Selling personal information

Newvoy does not sell your personal information to third parties or otherwise except as set forth in Section 4 of our Privacy Policy. We do not sell personal information to third parties within the scope of the application of the CCPA.

4. California Residents' Individual Rights

The CCPA provides California residents with specific rights regarding their personal information.Concerning their personal information, California residents may exercise the rights described below.

Access and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose the following information to you:

the categories of personal information we have collected about you,
the categories of sources for the personal information we have collected about you,
our business or commercial purpose for collecting or selling this personal information,
the categories of third parties with whom we have shared this personal information,
the specific pieces of personal information we have collected about you (also referred to as a "data portability request"),
if we have sold or disclosed your personal information for business purposes, two separate lists disclosing (i) sales, identifying the personal information categories that each category of recipient has purchased; and (ii) disclosures for business purposes, identifying the personal information categories that each category of recipient has obtained.

Deletion Request Rights

You have the right to request that Newvoy delete your personal information, subject to certain ex-providers to delete your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise execute our contract with you,
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity (including fraudulent user-generated content such as product reviews), or prosecute those responsible for such activities,
debug products to identify and repair errors that impair existing intended functionality,
exercise a right provided by law,
comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.),
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the deletion of such information may likely render impossible or seriously impair the research's achievement of its goal(s) if you have previously provided informed consent,
enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us,
comply with a legal obligation,
make other internal and lawful uses of such information that are compatible with the context in which you provided it.

Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit and send us a verifiable consumer request by any form of communication listed in Section 6 of this Notice.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify that you are the person about whom we have collected Personal Information or an authorized representative.
Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.

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 that the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requester's identity or authority to make said request.

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 that the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verifications. Once we receive and confirm your verifiable consumer request and verify the requester's identity or authority to make the request, we will delete (and direct our service to delete) the data in question.

We do not disclose Social Security numbers, driver's license and government-issued ID numbers, financial account numbers, health insurance or medical identification numbers, account passwords, or security questions or answers.

Response Timing and Format

We will 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 by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with the request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically via email.

We will 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.

Opt-Out and Opt-In Rights

The CCPA requires businesses that sell personal information to allow residents the ability to opt-out of the selling of their information.

As stated above, Newvoy does not sell personal information.

Non-Discrimination Rights

We will not discriminate against you for exercising any of your CCPA 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.

5. Changes to the Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website's homepage.

6. Contact Information

If you have any questions or comments about this notice, our Privacy Policy, how we collect and use your personal information, or your choices and rights regarding such use or wish to exercise your rights under California law, please do not hesitate to contact us via your game account, via email: legal@newvoy.com