Welcome to the Persona privacy notice. This policy describes the types of information Persona Media, Inc. (“Persona”) may collect from you or that you may provide when you use our mobile application (our "App") and the practices for collecting, using, maintaining, protecting and disclosing that information.
This privacy notice provides you with information on how Persona collects and processes your personal data through your use of this App, including any data you may provide through this App when you register for an account, sign up to our newsletter, purchase a product, or otherwise use our service
This App is not intended for children under the age of 13 and we do not knowingly collect data relating to children.
f you have any questions about this privacy notice, please contact us at:
Persona Media, Inc.
We may collect Personal Information about you when you send such information to us or automatically when you use our App. “Personal Information” means any information about an individual from which that person can be identified. It does not include anonymous data or Aggregated Data.
We may collect, use, store and transfer additional kinds of data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data 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 provide you with goods or services or otherwise fulfil a transaction with you. In this case, we may have to cancel the product or service you have ordered but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Residents of the European Union (“EU”) may have individual rights regarding the use of personal information for marketing. If you are in the EU, please see the additional information in Section 8 below. California residents may have different or additional rights, please see the NOTICE TO CALIFORNIA RESIDENTS in Section 9 below.
Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to offer products, services, or information that we think you may want or need, or that may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details and, in each case, you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing emails at any time by Contacting us firstname.lastname@example.org at any time.
Sharing with Third Parties
This App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our App
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, you may have the right to ask us to delete your data.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
This Section 8 applies only to users who are accessing the App from the EU. Under certain circumstances, EU residents have rights under EU data protection laws in relation to their personal data. If you are an EU resident, you have the right to:
If you wish to exercise any of the rights set out above, please contact us using the contact information in Section 1.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights unless your request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Whenever we transfer personal data out of the European Economic Area, we ensure that a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Information We Collect
Our App collects Personal Information, further defined in Section 2 and 3 above. For purposes of this Section 9, “Personal Information” also includes information that identifies or could reasonably be linked, directly or indirectly, with a particular consumer or device.
Our App has collected the following categories of Personal Information from its consumers within the last twelve (12) months:
|A. Identifiers.||First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (, videos) submitted, stored, sent, or received by the Data Subjects.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (videos) submitted, stored, sent, or received by the consumers.
Note: Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||None|
|D. Commercial information.||None|
|E. Biometric information.||None|
|F. Internet or other similar network activity.||IP Address, system usage data, aggregated data.|
|G. Geolocation data.||None|
|H. Sensory data.||None|
|I. Professional or employment- related information.||None|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||None|
|K. Inferences drawn from other personal information.||None|
For purposes of this Section 9, “Personal Information” does not include:
We obtain the Personal Information listed above from 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 3 above.
Use of Personal Information
We may use or disclose the Personal Information we collect for the business purposes set forth in Section 4 above.
Sharing Personal Information
Persona does not sell or disclose your Personal Information to third parties for commercial purposes or otherwise except as set forth in Section 4 above.
California Residents’ Individual Rights
The CCPA provides California consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access and Data Portability Rights
California consumers 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:
Deletion Request Rights
California residents have the right to request that Persona delete their Personal Information, 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 provider(s) to:
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 emailing us at email@example.com . 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:
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.
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 try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
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.
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.
Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at firstname.lastname@example.org
We will only use Personal Information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. However, note that many features of our App, our products, or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message at email@example.com.