5.
DO
WE
USE
COOKIES
AND
OTHER
TRACKING
TECHNOLOGIES?
In
Short:
We
may
use
cookies
and
other
tracking
technologies
to
collect
and
store
your
information.
We
may
use
cookies
and
similar
tracking
technologies
(like
web
beacons
and
pixels)
to
access
or
store
information.
Specific
information
about
how
we
use
such
technologies
and
how
you
can
refuse
certain
cookies
is
set
out
in
our
Cookie
Notice
.
6.
IS
YOUR
INFORMATION
TRANSFERRED
INTERNATIONALLY?
In
Short:
We
may
transfer,
store,
and
process
your
information
in
countries
other
than
your
own.
Our
servers
are
located
in
.
If
you
are
accessing
our
Services
from
outside
,
please
be
aware
that
your
information
may
be
transferred
to,
stored,
and
processed
by
us
in
our
facilities
and
by
those
third
parties
with
whom
we
may
share
your
personal
information
(see
"
WHEN
AND
WITH
WHOM
DO
WE
SHARE
YOUR
PERSONAL
INFORMATION?
"
above),
in
and
other
countries.
If
you
are
a
resident
in
the
European
Economic
Area
(EEA)
or
United
Kingdom
(UK),
then
these
countries
may
not
necessarily
have
data
protection
laws
or
other
similar
laws
as
comprehensive
as
those
in
your
country.
However,
we
will
take
all
necessary
measures
to
protect
your
personal
information
in
accordance
with
this
privacy
notice
and
applicable
law.
7.
HOW
LONG
DO
WE
KEEP
YOUR
INFORMATION?
In
Short:
We
keep
your
information
for
as
long
as
necessary
to
fulfill
the
purposes
outlined
in
this
privacy
notice
unless
otherwise
required
by
law.
We
will
only
keep
your
personal
information
for
as
long
as
it
is
necessary
for
the
purposes
set
out
in
this
privacy
notice,
unless
a
longer
retention
period
is
required
or
permitted
by
law
(such
as
tax,
accounting,
or
other
legal
requirements).
When
we
have
no
ongoing
legitimate
business
need
to
process
your
personal
information,
we
will
either
delete
or
anonymize
such
information,
or,
if
this
is
not
possible
(for
example,
because
your
personal
information
has
been
stored
in
backup
archives),
then
we
will
securely
store
your
personal
information
and
isolate
it
from
any
further
processing
until
deletion
is
possible.
8.
DO
WE
COLLECT
INFORMATION
FROM
MINORS?
In
Short:
We
do
not
knowingly
collect
data
from
or
market
to
children
under
18
years
of
age
.
We
do
not
knowingly
solicit
data
from
or
market
to
children
under
18
years
of
age.
By
using
the
Services,
you
represent
that
you
are
at
least
18
or
that
you
are
the
parent
or
guardian
of
such
a
minor
and
consent
to
such
minor
dependent’s
use
of
the
Services.
If
we
learn
that
personal
information
from
users
less
than
18
years
of
age
has
been
collected,
we
will
deactivate
the
account
and
take
reasonable
measures
to
promptly
delete
such
data
from
our
records.
If
you
become
aware
of
any
data
we
may
have
collected
from
children
under
age
18,
please
contact
us
at
contact@noosh.ai
.
9.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
In
Short:
In
some
regions,
such
as
the
European
Economic
Area
(EEA),
United
Kingdom
(UK),
and
Canada
,
you
have
rights
that
allow
you
greater
access
to
and
control
over
your
personal
information.
You
may
review,
change,
or
terminate
your
account
at
any
time.
In
some
regions
(like
the
EEA,
UK,
and
Canada
),
you
have
certain
rights
under
applicable
data
protection
laws.
These
may
include
the
right
(i)
to
request
access
and
obtain
a
copy
of
your
personal
information,
(ii)
to
request
rectification
or
erasure;
(iii)
to
restrict
the
processing
of
your
personal
information;
and
(iv)
if
applicable,
to
data
portability.
In
certain
circumstances,
you
may
also
have
the
right
to
object
to
the
processing
of
your
personal
information.
You
can
make
such
a
request
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below.
We
will
consider
and
act
upon
any
request
in
accordance
with
applicable
data
protection
laws.
Withdrawing
your
consent:
If
we
are
relying
on
your
consent
to
process
your
personal
information,
which
may
be
express
and/or
implied
consent
depending
on
the
applicable
law,
you
have
the
right
to
withdraw
your
consent
at
any
time.
You
can
withdraw
your
consent
at
any
time
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below
.
However,
please
note
that
this
will
not
affect
the
lawfulness
of
the
processing
before
its
withdrawal
nor,
when
applicable
law
allows,
will
it
affect
the
processing
of
your
personal
information
conducted
in
reliance
on
lawful
processing
grounds
other
than
consent.
10.
CONTROLS
FOR
DO-NOT-TRACK
FEATURES
Most
web
browsers
and
some
mobile
operating
systems
and
mobile
applications
include
a
Do-Not-Track
(
"DNT"
)
feature
or
setting
you
can
activate
to
signal
your
privacy
preference
not
to
have
data
about
your
online
browsing
activities
monitored
and
collected.
At
this
stage
no
uniform
technology
standard
for
recognizing
and
implementing
DNT
signals
has
been
finalized
.
As
such,
we
do
not
currently
respond
to
DNT
browser
signals
or
any
other
mechanism
that
automatically
communicates
your
choice
not
to
be
tracked
online.
If
a
standard
for
online
tracking
is
adopted
that
we
must
follow
in
the
future,
we
will
inform
you
about
that
practice
in
a
revised
version
of
this
privacy
notice.
11.
DO
CALIFORNIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short:
Yes,
if
you
are
a
resident
of
California,
you
are
granted
specific
rights
regarding
access
to
your
personal
information.
California
Civil
Code
Section
1798.83,
also
known
as
the
"Shine
The
Light"
law,
permits
our
users
who
are
California
residents
to
request
and
obtain
from
us,
once
a
year
and
free
of
charge,
information
about
categories
of
personal
information
(if
any)
we
disclosed
to
third
parties
for
direct
marketing
purposes
and
the
names
and
addresses
of
all
third
parties
with
which
we
shared
personal
information
in
the
immediately
preceding
calendar
year.
If
you
are
a
California
resident
and
would
like
to
make
such
a
request,
please
submit
your
request
in
writing
to
us
using
the
contact
information
provided
below.
If
you
are
under
18
years
of
age,
reside
in
California,
and
have
a
registered
account
with
Services,
you
have
the
right
to
request
removal
of
unwanted
data
that
you
publicly
post
on
the
Services.
To
request
removal
of
such
data,
please
contact
us
using
the
contact
information
provided
below
and
include
the
email
address
associated
with
your
account
and
a
statement
that
you
reside
in
California.
We
will
make
sure
the
data
is
not
publicly
displayed
on
the
Services,
but
please
be
aware
that
the
data
may
not
be
completely
or
comprehensively
removed
from
all
our
systems
(e.g.
,
backups,
etc.).
CCPA
Privacy
Notice
The
California
Code
of
Regulations
defines
a
"resident"
as:
(1)
every
individual
who
is
in
the
State
of
California
for
other
than
a
temporary
or
transitory
purpose
and
(2)
every
individual
who
is
domiciled
in
the
State
of
California
who
is
outside
the
State
of
California
for
a
temporary
or
transitory
purpose
All
other
individuals
are
defined
as
"non-residents."
If
this
definition
of
"resident"
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
information.
What
categories
of
personal
information
do
we
collect?
We
have
collected
the
following
categories
of
personal
information
in
the
past
twelve
(12)
months:
We
may
also
collect
other
personal
information
outside
of
these
categories
through
instances
where
you
interact
with
us
in
person,
online,
or
by
phone
or
mail
in
the
context
of:
- Receiving
help
through
our
customer
support
channels;
- Participation
in
customer
surveys
or
contests;
and
- Facilitation
in
the
delivery
of
our
Services
and
to
respond
to
your
inquiries.
How
do
we
use
and
share
your
personal
information?
More
information
about
our
data
collection
and
sharing
practices
can
be
found
in
this
privacy
notice
.
You
may
contact
us
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
are
using
an
authorized
agent
to
exercise
your
right
to
opt
out
we
may
deny
a
request
if
the
authorized
agent
does
not
submit
proof
that
they
have
been
validly
authorized
to
act
on
your
behalf.
Will
your
information
be
shared
with
anyone
else?
We
may
disclose
your
personal
information
with
our
service
providers
pursuant
to
a
written
contract
between
us
and
each
service
provider.
Each
service
provider
is
a
for-profit
entity
that
processes
the
information
on
our
behalf,
following
the
same
strict
privacy
protection
obligations
mandated
by
the
CCPA.
We
may
use
your
personal
information
for
our
own
business
purposes,
such
as
for
undertaking
internal
research
for
technological
development
and
demonstration.
This
is
not
considered
to
be
"selling"
of
your
personal
information.
Your
rights
with
respect
to
your
personal
data
Right
to
request
deletion
of
the
data
—
Request
to
delete
You
can
ask
for
the
deletion
of
your
personal
information.
If
you
ask
us
to
delete
your
personal
information,
we
will
respect
your
request
and
delete
your
personal
information,
subject
to
certain
exceptions
provided
by
law,
such
as
(but
not
limited
to)
the
exercise
by
another
consumer
of
his
or
her
right
to
free
speech,
our
compliance
requirements
resulting
from
a
legal
obligation,
or
any
processing
that
may
be
required
to
protect
against
illegal
activities.
Right
to
be
informed
—
Request
to
know
Depending
on
the
circumstances,
you
have
a
right
to
know:
- whether
we
collect
and
use
your
personal
information;
- the
categories
of
personal
information
that
we
collect;
- the
purposes
for
which
the
collected
personal
information
is
used;
- whether
we
sell
or
share
personal
information
to
third
parties;
- the
categories
of
personal
information
that
we
sold,
shared,
or
disclosed
for
a
business
purpose;
- the
categories
of
third
parties
to
whom
the
personal
information
was
sold,
shared,
or
disclosed
for
a
business
purpose;
- the
business
or
commercial
purpose
for
collecting,
selling,
or
sharing
personal
information;
and
- the
specific
pieces
of
personal
information
we
collected
about
you.
In
accordance
with
applicable
law,
we
are
not
obligated
to
provide
or
delete
consumer
information
that
is
de-identified
in
response
to
a
consumer
request
or
to
re-identify
individual
data
to
verify
a
consumer
request.
Right
to
Non-Discrimination
for
the
Exercise
of
a
Consumer’s
Privacy
Rights
We
will
not
discriminate
against
you
if
you
exercise
your
privacy
rights.
Right
to
Limit
Use
and
Disclosure
of
Sensitive
Personal
Information
We
do
not
process
consumer's
sensitive
personal
information.
Verification
process
Upon
receiving
your
request,
we
will
need
to
verify
your
identity
to
determine
you
are
the
same
person
about
whom
we
have
the
information
in
our
system.
These
verification
efforts
require
us
to
ask
you
to
provide
information
so
that
we
can
match
it
with
information
you
have
previously
provided
us.
For
instance,
depending
on
the
type
of
request
you
submit,
we
may
ask
you
to
provide
certain
information
so
that
we
can
match
the
information
you
provide
with
the
information
we
already
have
on
file,
or
we
may
contact
you
through
a
communication
method
(e.g.
,
phone
or
email)
that
you
have
previously
provided
to
us.
We
may
also
use
other
verification
methods
as
the
circumstances
dictate.
We
will
only
use
personal
information
provided
in
your
request
to
verify
your
identity
or
authority
to
make
the
request.
To
the
extent
possible,
we
will
avoid
requesting
additional
information
from
you
for
the
purposes
of
verification.
However,
if
we
cannot
verify
your
identity
from
the
information
already
maintained
by
us,
we
may
request
that
you
provide
additional
information
for
the
purposes
of
verifying
your
identity
and
for
security
or
fraud-prevention
purposes.
We
will
delete
such
additionally
provided
information
as
soon
as
we
finish
verifying
you.
Other
privacy
rights
- You
may
object
to
the
processing
of
your
personal
information.
- You
may
request
correction
of
your
personal
data
if
it
is
incorrect
or
no
longer
relevant,
or
ask
to
restrict
the
processing
of
the
information.
- You
can
designate
an
authorized
agent
to
make
a
request
under
the
CCPA
on
your
behalf.
We
may
deny
a
request
from
an
authorized
agent
that
does
not
submit
proof
that
they
have
been
validly
authorized
to
act
on
your
behalf
in
accordance
with
the
CCPA.
To
exercise
these
rights,
you
can
contact
us
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
have
a
complaint
about
how
we
handle
your
data,
we
would
like
to
hear
from
you.
12.
DO
VIRGINIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short:
Yes,
if
you
are
a
resident
of
Virginia,
you
may
be
granted
specific
rights
regarding
access
to
and
use
of
your
personal
information.
Virginia
CDPA
Privacy
Notice
Under
the
Virginia
Consumer
Data
Protection
Act
(CDPA):
"Consumer"
means
a
natural
person
who
is
a
resident
of
the
Commonwealth
acting
only
in
an
individual
or
household
context.
It
does
not
include
a
natural
person
acting
in
a
commercial
or
employment
context.
"Personal
data"
means
any
information
that
is
linked
or
reasonably
linkable
to
an
identified
or
identifiable
natural
person.
"Personal
data"
does
not
include
de-identified
data
or
publicly
available
information.
"Sale
of
personal
data"
means
the
exchange
of
personal
data
for
monetary
consideration.
If
this
definition
"consumer"
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
data.
The
information
we
collect,
use,
and
disclose
about
you
will
vary
depending
on
how
you
interact
with
us
and
our
Services.
To
find
out
more,
please
visit
the
following
links:
Your
rights
with
respect
to
your
personal
data
- Right
to
be
informed
whether
or
not
we
are
processing
your
personal
data
- Right
to
access
your
personal
data
- Right
to
correct
inaccuracies
in
your
personal
data
- Right
to
request
deletion
of
your
personal
data
- Right
to
obtain
a
copy
of
the
personal
data
you
previously
shared
with
us
- Right
to
opt
out
of
the
processing
of
your
personal
data
if
it
is
used
for
targeted
advertising,
the
sale
of
personal
data,
or
profiling
in
furtherance
of
decisions
that
produce
legal
or
similarly
significant
effects
(
"profiling"
)
We
have
not
sold
any
personal
data
to
third
parties
for
business
or
commercial
purposes.
We
will
not
sell
personal
data
in
the
future
belonging
to
website
visitors,
users,
and
other
consumers.
Exercise
your
rights
provided
under
the
Virginia
CDPA
More
information
about
our
data
collection
and
sharing
practices
can
be
found
in
this
privacy
notice
.
You
may
contact
us
by
email
at
contact@noosh.ai
,
by
submitting
a
data
subject
access
request
,
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
are
using
an
authorized
agent
to
exercise
your
rights,
we
may
deny
a
request
if
the
authorized
agent
does
not
submit
proof
that
they
have
been
validly
authorized
to
act
on
your
behalf.
Verification
process
We
may
request
that
you
provide
additional
information
reasonably
necessary
to
verify
you
and
your
consumer's
request.
If
you
submit
the
request
through
an
authorized
agent,
we
may
need
to
collect
additional
information
to
verify
your
identity
before
processing
your
request.
Upon
receiving
your
request,
we
will
respond
without
undue
delay,
but
in
all
cases,
within
forty-five
(45)
days
of
receipt.
The
response
period
may
be
extended
once
by
forty-five
(45)
additional
days
when
reasonably
necessary.
We
will
inform
you
of
any
such
extension
within
the
initial
45-day
response
period,
together
with
the
reason
for
the
extension.
Right
to
appeal
If
we
decline
to
take
action
regarding
your
request,
we
will
inform
you
of
our
decision
and
reasoning
behind
it.
If
you
wish
to
appeal
our
decision,
please
email
us
at
contact@noosh.ai
.
Within
sixty
(60)
days
of
receipt
of
an
appeal,
we
will
inform
you
in
writing
of
any
action
taken
or
not
taken
in
response
to
the
appeal,
including
a
written
explanation
of
the
reasons
for
the
decisions.
If
your
appeal
if
denied,
you
may
contact
the
Attorney
General
to
submit
a
complaint.
13.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short:
Yes,
we
will
update
this
notice
as
necessary
to
stay
compliant
with
relevant
laws.
We
may
update
this
privacy
notice
from
time
to
time.
The
updated
version
will
be
indicated
by
an
updated
"Revised"
date
and
the
updated
version
will
be
effective
as
soon
as
it
is
accessible.
If
we
make
material
changes
to
this
privacy
notice,
we
may
notify
you
either
by
prominently
posting
a
notice
of
such
changes
or
by
directly
sending
you
a
notification.
We
encourage
you
to
review
this
privacy
notice
frequently
to
be
informed
of
how
we
are
protecting
your
information.
14.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you
have
questions
or
comments
about
this
notice,
you
may
email
us
at
contact@noosh.ai
or
contact
us
by
post
at:
Noosh
LLC
41
East
28th
Street,
Suite
2C
New
York
,
NY
10016
United
States
15.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
Based
on
the
applicable
laws
of
your
country,
you
may
have
the
right
to
request
access
to
the
personal
information
we
collect
from
you,
change
that
information,
or
delete
it.
To
request
to
review,
update,
or
delete
your
personal
information,
please
fill
out
and
submit
a
data
subject
access
request
.