Apxium Privacy Policy

Last Updated: November 26, 2021

Welcome to Onebox Holdings US LLC (“Apxium,” “we,” “our,” and “us”) and our Privacy Policy (“Privacy Policy”). We respect the privacy of and are committed to protecting the privacy of the users of our products and services.

The Apxium experience provides software solutions to help businesses manage debtors, improve cash flow and substantially enhance profitability through multiple and quantifiable efficiency gains. Apxium does not directly collect information from individuals. Apxium collects information from our clients, such as your business. This information is used to streamline essential accounting functions.

The purpose of this Privacy Policy is to inform you as to how Apxium handles your personal information when using any of our products, services, or applications (together, the “Services”) or when visiting or using our websites or Apxium mobile applications (collectively, “Site”).

Our processing of personal information will be undertaken consistent with the requirements of applicable privacy laws.  Whether we serve as the data controller or processor, we have implemented numerous technical and organizational measures to ensure the protection of personal information processed through the Site.  However, Internet-based data transmissions may in principle have security gaps, so please understand that absolute protection is not assured.

It is important that you read this Privacy Policy together with any other notice or policy that we may provide on certain occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements but is not intended to override those other notices or policies. If you do not agree with our policies and practices, your choice is not to use our Services or Site. By accessing or using the Site you agree to this Privacy Policy and consent to our data practices set forth herein.

Personal Information We Collect

Personal information is a broad term which includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (de-identified data). We collect personal information from our users and their customers. You provide us information about your customers via your computer, mobile device, or another access advice. Personal information we collect may include, but is not limited to:

·        First and last name,

·        Address (or general location),

·        E-mail address,

·        Phone number,

·        Demographic data, such as date of birth, etc.

·        Information associated with your account, including your username and password, your interests, preferences, or feedback,

·        Payment methods, including full bank account numbers or credit card numbers,

·        Financial information, such as amounts associated with account, external account details, or source of funds and related documentation, amounts associated with accounts,

·        Traffic data, such as IP address, domain service, browser type and version, time zone setting and location data, browser plug-in types and versions, etc.

·        Usage data, such as how you use the Site and related Services,

·        Etc.

We may also collect, use, and share information that has been anonymized or de-identified, including statistical or demographic data, for any purpose (“Aggregate Consumer Information”). For example, we may aggregate your data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Consumer Information with your personal information so that it can directly or indirectly identify you, we treat the combined data as Personal Information pursuant to applicable law.

If you refuse to provide Personal Information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, including the ability to offer or provide or continue to provide Services or other functionality.

How We Collect Your Personal Information

We use different methods to collect information from and about you including through:

Direct interactions. You may give us your data by directly interacting with us, including by filling in forms, by email, through the Apxium mobile application or otherwise. This includes personal information you provide when you:

●       visit the Site

●       apply for, access or attempt to access the Services

●       create or modify an account

●       subscribe to our publications

●       use any of the Services

●       request marketing to be sent to you

●       enter a competition, promotion or survey, including through social media channels

●       give us feedback or contact us

 

Automated technologies or interactions. As you interact with us via the Site, we will automatically collect data about your equipment, browsing actions, activity, and patterns. We collect this data by using cookies, server logs, and other similar technologies. We will also collect data about your usage of the Site and Services. We may also receive data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We also obtain information and data about you, including demographic data from third parties or publicly available sources. These sources may include:

●       fraud and crime prevention agencies

●       publicly available information

●       a credit reporting agency

●       an individual’s financial advisors

●       an individual’s representatives (i.e. legal advisors)

●       an individual’s employer

●       Etc.

 

How Your Personal Information Is Used  

 

We will only use your Personal Information in accordance with applicable law and in accordance with this Privacy Policy. For the most part, we will use your Personal Information in the following ways:

●       To provide Services

●       When necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

●       To comply with a legal obligation

●       For business purposes and in accordance with this Privacy Policy

●       When you use our Services, our authorized partners may collect categories of personal information about you and use this data for their own purposes. This activity may qualify as a sale under the California Consumer Privacy Act (“CCPA”). Under the CCPA, you can make choices to allow or prevent such uses

 

Purposes for which we may use your Personal Information

We have set out below an illustrative example of the common ways we may use your Personal Information:

·        To provide the service on our platform, website, and customer support

·        To ensure accuracy of information provided by our users

·        To carry out and comply with legal and compliance obligations

·        To process and deliver the Services and any features and functionality

·        To prevent abuse of our Services, Site, and promotions

·        To manage our relationship with you which will include notifying you about certain changes to our terms or Privacy Policy, asking you to leave a review, take a survey or keeping you informed of our business and product development

·        To keep our records updated and to evaluate how customers use our products/services

·        To manage, process, collect and transfer payments, fees and charges, and to collect and recover payments owed to use

·        To ensure proper management of our payments, fees and charges and collection and recovery of payments owned to us

·        To manage risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, fraud and other background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and response to complaints and resolving them

·        To enable you to partake in a prize draw, competition or complete a survey

·        To gather market data for studying customers’ behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business

·        To administer and protect our business, the Site, and social media channels including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

·        To deliver relevant content and advertisements and promotional offers to you and measure or understand the effectiveness of the advertising we serve to you

·        To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

·        To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

·        To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

·        To make suggestions and recommendations to you about goods or services that may be of interest to you

·        To use the services of social media platforms or advertising platforms some of which will use the personal information they receive for their own purposes, including marketing purposes

·        To record voice calls and other conversations for compliance, quality assurance, and training purposes

Marketing

We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

Promotional offers from us

We may use your Personal Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you. You may receive marketing communications from us if you have requested information from us or used the Services and have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Further, you can let us know directly that you prefer not to receive any marketing messages by emailing [email protected].   

When you opt-out of receiving these marketing messages, this will not apply to service messages which are directly related to use of our Services (e.g. change in the terms and conditions or this Privacy Policy).

If you are a resident of Vermont or applicable law otherwise prohibits such activity, we will not share any creditworthiness information with affiliates without receiving your express consent.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Site may become inaccessible or not function properly. For more information about the cookies we use, please review the Cookie Preferences available on the Site.

Sale or transfer of business

We may need to process your Personal Information in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving all or a part of our shares, business or assets.

How We Share Your Personal Information

We may share your Personal Information with our third-party service providers, agents, subcontractors, and other associated organizations, our group companies and affiliates in order to complete tasks, provide the Services, and use of the Apxium mobile application to you on our behalf, and otherwise fulfill our obligations. When using third-party service providers, we request they respect the security of your Personal Information and treat it in accordance with the law.

We may share your Personal Information and other data you provide to us for the following purposes:

●       To verify your identity.

●       To detect and prevent fraud, money laundering, terrorist financing, and other financial crimes and illicit activities.

●       To facilitate the provision of services and relevant business operations to support our delivery of the Services and related aspects to you.

●       To improve our information, technology, and security systems including websites and mobile applications.

●       To provide customer service.

●       To promote our Services if you submit a product review or post content on public areas of our Services, or social media accounts.

●       To transfer our rights and duties under the relevant terms and conditions governing the use of any Services (to the extent allowed).

●       To comply, in our belief, with a legal request or to protect or enforce our rights, including to comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and to protect the rights, property, and safety of us or others.

●       To evaluate, effectuate, or otherwise transfer your personal information as part of a proposed or actual sale, merger, restructuring, transfer, or exchange of all or a portion of our assets to another company.

 

We may have disclosed the following categories of personal information to the following categories of third parties:

·        Companies and organizations that assist us in processing, verifying or refunding transactions or orders (e.g. mailing services, billing and debt recovery functions, marketing services, data analysis specialists, data processing organizations and loyalty program administrators)

·        Our suppliers

·        Our business associates for purposes directly related to purpose for which personal information was collected

·        Credit reporting agencies

·        Parties involved with our marketing efforts, including marketing for our products or services, as well as, parties involved in promotional competitions or events

·        Identity verification agencies

·        Fraud or crime prevention agencies

·        Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services

·        Any third party because of any restructure, sale or acquisition of our group or any affiliates

·        Regulatory and law enforcement authorities, where the law allows or requires us to do so

 

We disclose Personal Information to third parties only in accordance with applicable law. We will not sell or rent any of your personal information to third parties for their marketing purposes.

Third Party Links

The Site contains links to or embedded content from third party web services. A link to or embedded content from a non-Apxium web service does not mean that we endorse that web service, the quality or accuracy of information presented on the web service or the persons or entities associated with the web service. If you decide to visit a third party web service, you are subject to the privacy policy of the third party web service as applicable and we are not responsible for the policies and practices of the third party web service.  We encourage you to ask questions before you disclose your information to others.

You may have arrived at the Site from, or began your use of the Site at, a third party web service, including a third party web service that links to Apxium or embeds Apxium content. The presence of such links or content on third party web services does not mean that we endorse that web service, the quality or accuracy of information presented on the non-Apxium web service or the persons or entities associated with the non-Apxium web service.  You may be subject to the privacy policy of the third party web service as applicable and we are not responsible for the policies and practices of the third party web services. In addition, the policies and practices of third parties do not apply to your information, including personal information, obtained pursuant to this Privacy Policy.

How We Secure Your Personal Information

While there is an inherent risk in any information being shared over the internet, we have put in place commercially reasonable security measures to prevent your Personal Information from being accidentally lost, used, damaged, or accessed in an unauthorized or unlawful way, altered, or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your Personal Information on our instructions. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse such as by maintaining the confidentiality of your Personal Information.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a qualifying breach when required.

 

Personal Information Retention

How long will you use my personal information for?

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Here are some exemplary factors which we usually consider when determining how long we need to retain your Personal Information and data:

●       in the event of a complaint;

●       if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims, the respective personal information (e.g., email addresses and content, chats, letters) will be kept in accordance with the statutory limitation period applicable following the end of our relationship;

●       to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal information, including relevant sanctions regimes:

o   under the Bank Secrecy Act and its related statutes we are obliged to retain your Personal Information for a period of at least 5 years after the end of our relationship;

o   information needed for audit purposes;

●       in accordance with relevant industry standards or guidelines;

●       in accordance with our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer’s personal information for the time of the promotion and for a certain period after its end to prevent the appearance of abusive behavior.

 

Please note that under certain conditions, you can ask us to delete your Personal Information.

 

Your Legal Rights

Under certain circumstances, you may have certain rights in relation to your Personal Information:

●       Right to know about Personal Information collected, and how it is used and disclosed.

●       Right to request correction of certain Personal Information.

●       Right to request deletion of certain Personal Information.

●       Right to opt-out of the sharing of certain Personal Information.

 

If you wish to exercise any of the rights set out above or if you want to raise a question or a concern about our privacy policy and practices, please contact our Data Protection Officer at [email protected], at our toll-free telephone number, +1-206-886-0504, or via mail at:

Onebox Holdings US LLC

300 Lenora Street

PMB 1643

Seattle, WA 98121

 

When allowed by applicable law and required, we will take steps to disclose and deliver to you, free of charge, your Personal Information accordingly. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you are a Californian resident, you also have the right to know about Personal Information sold. In addition, you may also opt-out of the sale of your personal information.

If you are a Californian resident, please also note that there are some exceptions related to your Personal Information that is subject to Gramm-Leach-Bliley Act. Information we collect for the purposes of complying with these financial regulations is not covered by CCPA (and therefore may not be subject to deletion requests). Due to the different scope of the regulations, some of your Personal Information we collect could still be subject to the CCPA.

Non-Discrimination

You will not receive a discriminatory treatment if you choose to exercise any of the rights conferred to you above.

If you want to make a request under the CCPA through a natural person or a business entity authorized to act on your behalf, please beforehand contact us and in a timely manner we will provide you with a reply on how to designate such a person.

Children’s Privacy

Apxium respects the privacy of children, and we are committed to complying with the Children’s Online Privacy Protection Act (herein called “COPPA”). We do not knowingly collect Personal Information from children under the age of thirteen (13). If you are a parent or guardian and you are aware that your child under the age of 13 has provided us with personally identifiable information, please contact us.  If we become aware that we have collected personally identifiable information from children without verification of parental consent, we take steps to remove that information from our servers.

 

Notice to Non-U.S. Users

As the Internet is a global environment, collecting and processing Personal Information may involve the transmission of this data internationally, including into and/or outside of the United States. Therefore, by communicating electronically with us, you acknowledge and agree to your personal data being processed in this way.

Specifically, if you are located outside of the United States, please be aware that by using the Website, your information may be transferred to the United States or other third-countries, the privacy laws of which may be deemed by your country to have inadequate data protection. If you are located outside of the United States and voluntarily submit information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States or other third-countries.

Changes to this Privacy Policy

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy policy. If our information practices change materially at some time in the future, we will post an updated policy to our Website and update the “last updated” date. You are advised to review this Privacy Policy periodically for any changes. Changes are effective when they are posted. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.

Notice to California Users

If you are a California resident, we are required to provide additional information concerning how we use and disclose your Personal Information. You may have additional rights regarding how we use your Personal Information. If you are a California resident and have an established relationship with us, California Civil Code Section 1798.83 permits you to request a notice disclosing the categories of Personal Information we have shared with third parties, if any, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to the contact information provided below. California law also permits residents of California to opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request in writing to the contact information provided below. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.

 

Please note that at this time we do not respond to browser-based “do not track” signals.

Contact

If you have questions about this privacy policy, please contact:

Onebox Holdings US LLC

300 Lenora Street

PMB 1643

Seattle, WA 98121

 

[email protected]

+1-206-886-0504

 

 

APXIUM PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Last Updated: November 26, 2021

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Privacy Policy for Onebox Holdings US LLC (collectively, “Apxium” “we”, “us” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) that visit the Apxium Website, including apxium.com/us (the “Website”), when downloading the Apxium software application and the Apxium mobile application (the “Software”),  and all other related products and services offered by Apxium in connection with the Software (individually and collectively, the “Apxium Platforms”).  We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

Information We Collect

Our Website and the Apxium Platforms collect information in a manner that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household (“personal information”).  In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

 

Category	Examples
A. Identifiers.	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.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).   Apxium does not collect this category of personal information from general Website or Basic Space Platform users. Apxium may collect this category of gender information users of the Apxium Services.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, software application, or advertisement.
G. Geolocation data.	Physical location or movements.

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • 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 categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase from our Website or from the Apxium Platforms.
• Indirectly from you. For example, from observing your actions on our Website or from the Apxium Platforms.
• From third party services

Use of Personal Information

For information generally on how we use your personal information and to which entities, please refer to our Privacy Policy.

Sharing Personal Information

For information generally on how we share your personal information and to which entities, please refer to our Privacy Policy.

Disclosure of Personal Information

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

 

Category	Examples
A. Identifiers.	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.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).   Apxium does not collect this category of personal information from general Website or Basic Space Platform users. Apxium may collect this category of gender information users of the Apxium Services.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, software application, or advertisement.
G. Geolocation data.	Physical location or movements.

 

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates
• Service providers.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold your personal information.

 

Your Rights and Choices

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.  Once we receive and confirm your verifiable consumer request, 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, list disclosing:
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Do Not Sell My Information

We do not sell your personal information.  Please note that distributing your information within our organization across business unites is not considered a sale, nor is providing data to third-parties that does not meet the definition of personal information. The sale of personal information does not include if you direct us to interact with a third-party, any third-party alerts that you have opted out of, the sharing of information is necessary to perform a business purpose and meets the other conditions specified, or the information is transferred as part of an asset in a merger, acquisition, bankruptcy or other change of control of Apxium.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, 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 providers 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 perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you 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; and
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, opt out, and deletion rights described above, please submit a verifiable consumer request to us in one of the following ways:

By Mail:                      Onebox Holdings US LLC

300 Lenora Street

PMB 1643

Seattle, WA 98121

 

By Email:                   [email protected]

 

By Telephone:            +1-206-886-0504

 

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; and
• 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 45 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 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.

Non-Discrimination

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.

Changes to Our Privacy Notice

 

The Last Modified date of this Privacy Notice is set forth at the top of the Site.  We will notify you of any material change by posting notice on the Site.  Your continued use of the Site after the Last Modified date constitutes your acceptance of the amended Privacy Notice.  We encourage you to periodically review this page for the latest information on our privacy practices.  Any amended Privacy Policy supersedes all previous versions.  IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY NOTICE, YOU MUST STOP USING THE SERVICES AFTER THE LAST MODIFIED DATE OF SUCH CHANGES.

Contact Information

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

 

By Mail:          Onebox Holdings US LLC

300 Lenora Street

PMB 1643

Seattle, WA 98121

 

By Email:       [email protected]

 

By Telephone: +1-206-886-0504