Effective Date: March 20, 2020

This California Privacy Policy is hereby incorporated into Connectify’s Privacy Policy. This California Privacy Policy is directed only to California residents, California households, and all owners of devices that are registered in California. The purpose of this California Privacy Policy is to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended. All terms that appear in this California Privacy Policy have the same meaning as they have in the CCPA.

Via our websites, our apps, and our software, we collect the following “Personal Information” as described in the CCPA:

CATEGORY	COLLECTED
Identifiers	YES*
Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e)).	YES*
Protected classification characteristics under California or federal law	NO
Commercial information	NO
Biometric information	NO
Internet or other similar network activity	NO
Geolocation data	NO
Sensory data	NO
Professional or employment-related information	NO
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	NO
Inferences drawn from other personal information	NO

* Connectify only collects name and email address (paying customers and support) and IP address.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, if you subscribe to our services or request support.
• Indirectly from you. For example, through information we collect from you while providing services to you.
• Directly and indirectly from activity on our website (www.speedify.com). For example, from submission through our website or website usage information.

We may use or disclose the information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to purchase a service, we will use that information to provide you with the service that you purchased. If you provide your personal information to request support, we will use that personal information to provide you with the support that you requested.
• To create, maintain, and delete your account with us.
• To provide you with alerts concerning our services.
• To help maintain the safety, security, and integrity of our website, services, other technology assets, us, our clients, our business, and others.
• For testing, research, analysis, and product development, including to develop and improve our services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We do not share your personal information with any third party. Your credit card payment is processed by Fastspring, and their privacy policy may be found here. You provide your personal information directly to Fastspring, and the only personal information Fastspring shares with us is your name and email address.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information 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. We will provide that information to you only upon receipt of a verifiable consumer request. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list disclosing the disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collect from you and retained in our databases, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service 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:

1. Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (Cal. Penal Code § 1546 seq.) of Title 12 of Part 2 of the Penal Code.
3. Comply with a legal obligation.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending an E-mail to [email protected]

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 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.

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 you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (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 you electronically. If you do not have an account with us, we will deliver our written response by e-mail.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable request 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.

Additional Rights

We will inform you of the categories of personal information that we collect and the purposes for which the categories of personal information will be used. We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you with notice consistent with section 1798.100 of the CCPA.

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.

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 post the updated Notice on the Websites and update the Notice’s effective date. Your continued use of our Website and/or our software following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this Notice, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: [email protected]