SmartPass, Inc.’s (hereinafter “SmartPass”) Privacy Policy (available at https://www.smartpass.app/privacy) explains how we, SmartPass, Inc., collect, use and share your data when you use our Services.  This California Supplemental Privacy Notice is provided and directed to individuals who reside in California and use SmartPass websites, applications, or activities offered through either (collectively “Services”).  This California Supplemental Privacy Notice does not reflect SmartPass’s collection, use or disclosure of California residents’ personal data where an exception under the California Consumer Privacy Act (“CCPA”) applies.

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Data Handling over the Preceding Twelve Months

Over the preceding twelve-months, SmartPass collected the personal data enumerated within our Privacy Policy. These categories of personal data correspond to the following categories enumerated under the definition of “personal information” in the CCPA.

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, and account name.
• Information that identifies or is capable of being associated with your, including payment information.
• Internet or other electronic network activity information.
• Geolocation information.
• Audio, electronic, visual or other similar information.
• Education information.
• Professional or employment-related information.

SmartPass collected this personal data described in our Privacy Policy.  In the last twelve-months, we used this data for the purposes described within our Privacy Policy.  In the last twelve-months, SmartPass disclosed personal data we collected to the categories of recipients described in our Privacy Policy.  SmartPass did not sell any personal data of anyone including any California residents under sixteen years of age.

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California Rights and Choices

California residents have certain legal rights related to their personal data.  Except as otherwise provided or excepted by applicable law, California residents may exercise the following rights:

• Right to Know/Portability
  You have the right to request that SmartPass disclose to you certain information about personal data collected about you within the past twelve months. Once a verifiable request is confirmed, SmartPass will disclose:
  
  • the categories of personal data collected;
  • the categories of sources from which personal data is collected;
  • the business or commercial purpose for collecting personal data;
  • the categories of third parties to whom data is disclosed or sold; and
  • the specific pieces of information collected.
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• Right to Opt Out
  You have a right to opt-out of future “sales” of personal data. Note that the CCPA defines “sell” and “personal data” very broadly, including the use of cookie data and other tracking methods used for analytics described in this CA Statement may be considered a “sale” under those definitions. To opt-out of this limited “sale” of personal data, please email us at [email protected].  All opt-out requests will receive a response within fifteen (15) business days.
  
  SmartPass does not “sell” the personal data of California residents we know are less than eighteen years of age, unless we receive affirmative authorization (the “right to opt in”) from either the California resident who is between 13 and 18 years of age, or the parent or guardian of a California resident less than 13 years of age. California residents who opt into personal data sales may opt out of future sales at any time.
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• Right to Deletion
  You have the right to request deletion of your personal data that you provided that SmartPass has retained, subject to certain exceptions. Once the deletion request is approved, we will delete (and direct our service providers to delete, as applicable) your personal data from our records. Please know that if your SmartPass account is deleted, you will no longer be able to access the account. You would have to create a new account.
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• Right to Non-Discrimination for Exercise of CA Privacy Rights
  SmartPass will not discriminate against you because you exercise any of the above rights, or any other rights under CCPA.  Specifically, if you exercise your rights, SmartPass will not deny you access to our services, charge you different prices or rates for services or provide you a different level or quality of services.
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• How to Submit a Request
  You may submit a request to exercise the rights contained in this California Privacy Notice by emailing us at [email protected].  In your request you should include the full name used to create the account, the email address used to create the account, a phone number in case we need to contact you and what CCPA rights you would like to exercise.
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• Verifiable Request
  As required under applicable law, SmartPass takes steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected personal data or an authorized agent. We may limit our response to your exercise of the above rights as permitted under applicable law.
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• Agent Authorization
  You may designate an authorize agent to make a request on your behalf.  You may also make a request on behalf of your minor child if they reside in California.  As permitted by law, we may require additional verification in response to a request.
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• Responding to Requests
  SmartPass will confirm receipt of your request within fifteen (15) business days from receipt and provide information about how the request will be processed, verification that may be required and when you can anticipate a substantive response.
  
  SmartPass will use commercially reasonable efforts to honor your request within forty-five (45) days of receipt.  If additional time is needed, we will notify you, along with an explanation and anticipated timeframe for the extension which shall not exceed ninety (90) days from receipt of your request.
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Other California Privacy Rights

California residents under the age of eighteen who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed to [email protected].  Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.