Lamini Privacy Policy

Effective as of: Aug 13, 2024

Last Modified: Aug 13, 2024

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This Privacy Policy (this “Policy”) describes how Lamini Inc., (“Lamini”, “we”, “us”, or “our”) collects, uses, discloses and protects information relating to an identified or identifiable individual (collectively, “Personal Information”) that is provided to us, or that we collect when you visit our websites or use our products or services (collectively, the “Services”). Please note that this Policy does not apply to Personal Information collected on any third-party site or application that may link to, or be accessible from, our websites or the Services. The terms “you”, “your”, and “yours” refer to anyone who utilizes the Services.    

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We may change this Policy from time to time. If we make changes, we will notify you by posting the revised Policy on our website and update the “Last Modified” date above. We encourage you to review this Policy whenever you use our Services or interact with us in any other way to stay informed about our information practices and the choices available to you.

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Collection of Information

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Information We Collect Automatically

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  1. When you visit our website, certain information may be automatically collected due to your use of the Services or from the Services infrastructure, including data about the device and network you use, such as your IP address, device type, operating system version, unique device identification numbers, browser type, broad geographic location and other technical information. We also collect information about how your device has interacted with our website, including your access times, pages viewed, links clicked, and the page you visited before navigating to our Services. 
  2. We use tracking technologies, such as Cookies (as defined below) and Web Beacons (as defined below), to track the activity on our Services and store certain information. This information is used to improve and analyze our Services.
  3. A “Cookie” is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies. Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
  4. A “Web Beacon” is a small electronic file (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited certain pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
  5. We may use both Session and Persistent Cookies for the purposes set out below:‍
    • 1. Necessary / Essential Cookies ‍
    • Type: Session Cookies
    • Administered by: Us
    • Purpose: These Cookies are essential to provide you with services available through our website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide You with those services.
    • 2. Cookies Policy / Notice Acceptance Cookies‍
    • Type: Persistent Cookies
    • Administered by: Us
    • Purpose: These Cookies identify if users have accepted the use of cookies on our website.
    • 3. Functionality Cookies‍
    • Type: Persistent Cookies
    • Administered by: Us
    • Purpose: These Cookies allow us to remember choices you make when you use our website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use our website.
    • 4. Tracking and Performance Cookies‍
    • Type: Persistent Cookies
    • Administered by: Us, Third-Parties
    • Purpose: These Cookies are used to track information about traffic to our website and how users use it. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our website. We may also use these Cookies to test new pages, features, or new functionality of the Website to see how our users react to them.

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Information You Directly Provide

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  1. We collect information you provide directly to us, which may include Personal Information). If you create an account, submit content through our Services, request customer support, or otherwise communicate with us on our website, we will collect certain information from you, including your username, email address, password, and any other information you choose to provide.
  2. For the purposes of the EU General Data Protection Regulation (“GDPR”), Personal Information means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  3. For the purposes of the California Consumer Privacy Act (“CCPA”), Personal Information means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

 

Information We Do Not Collect

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We do not knowingly collect any sensitive information from you, including details regarding your race or ethnic origin, political views, religious beliefs, or health status.

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Use of Information

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We may use Personal Information for the following purposes:

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  1. To provide and maintain our Services, including to monitor the usage of our Services.
  2. To manage your account as a user of the Service. The Personal Information you provide can give you access to different functionalities of the Service that are available to you as a registered user.
  3. To contact you: To contact you by email regarding updates or informative communications related to the functionalities, products or Services, including the security updates, when necessary or reasonable for their implementation.
  4. To provide you with news and general information about the Services.
  5. To manage your requests: To attend and manage your requests to Us.
  6. For business transfers: 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 about our Services is among the assets transferred.
  7. For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

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Sharing of Information

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  1. We do not sell, trade, or otherwise share Personal Information with third parties, except as described in the following circumstances or as otherwise described in this policy:
    • ‍With service providers: To monitor and analyze the use of our Services.
    • ‍For business transfers: In connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business to another company.‍
    • With affiliates: In which case we will require those affiliates to honor this Policy. Affiliates may include a parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
    • ‍With other users: when you share Personal Information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.‍
    • With Your consent: We may disclose your Personal Information for any other purpose with Your consent.
  2. We may also disclose Personal Information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If we are going to disclose your Personal Information in response to legal process, we will use reasonable efforts to give you prior written notice, unless we are prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for Personal Information about users of our Services that we believe are improper. We may also disclose your Personal Information if we believe in good faith that such action is necessary to:‍‍
    • Protect and defend the rights or property of the Company
    • Prevent or investigate possible wrongdoing in connection with the Services
    • Protect the personal safety of Users of the Services or the public
    • Protect against legal liability

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The security of Personal Information is important to us, and we implement technical and organizational measures that we consider appropriate in light of the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons. However, you should be aware that we cannot ensure that your Personal Information will never be accessed, disclosed, altered, or destroyed in ways not described in this Privacy Policy. By way of example, third parties may unlawfully intercept or access transmissions or private communications.

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Third Party Services

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We may use third party services to maintain and improve our Services. No Personal Information is transmitted unless required for continuity of service, for example sending email, or providing customer support.

We may use site monitoring tools to collect anonymized information about usage. These tools may collect your IP address, device type, browser type, operating system, geographic location, and other technical information. We use this information to improve the quality and relevance of our website to our visitors.

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Security

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We implement reasonable safeguards to protect the Personal Information that we collect from you. We make no independent representations or warranties as to the policies, practices, or procedures of any third party. 

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Data Retention

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  1. We keep Personal Information associated with your account stored for as long as your account remains active or as needed to provide you with our Services. We store other Personal Information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. You also have the right to delete or request that we assist in deleting the Personal Information that we have collected about you. The Services may give you the ability to delete certain Personal Information from within the Services. Please contact us at support@lamini.ai  to request deletion. 
  1. We may also retain usage data for internal analysis purposes. Such data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
  1. Your information, including Personal Information, is processed at our operating offices and in any other places where the parties involved in the processing are located. As such, this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.
  1. We will take commercially reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

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Additional Information for EEA and UK Users-GDPR Privacy

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Legal Basis for Processing Personal Information under GDPR

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We may process Personal Information under the following conditions:

  1. Consent: You have given your consent for processing Personal Information for one or more specific purposes.
  2. Performance of a contract: Provision of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  3. Legal obligations: Processing Personal Information is necessary for compliance with a legal obligation to which we are subject.
  4. Vital interests: Processing Personal Information is necessary in order to protect your vital interests or of another natural person.
  5. Public interests: Processing Personal Information is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
  6. Legitimate interests: Processing Personal Information is necessary for the purposes of the legitimate interests pursued by us.

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Your Rights under the GDPR

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We undertake to respect the confidentiality of your Personal Information and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to:

  1. Request access to your Personal Information. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist. This also enables you to receive a copy of the Personal Information we hold about you.
  2. Request correction of the Personal Information that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  3. Object to processing of your Personal Information. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Information on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
  4. Request erasure of Your Personal Information. You have the right to ask us to delete or remove Personal Information when there is no good reason for us to continue processing it.
  5. Request the transfer of your Personal Information. We will provide to you, or to a third-party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  6. Withdraw your consent. You have the right to withdraw your consent on using your Personal Information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

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Exercising of your GDPR Data Protection Rights

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  1. You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request we will try our best to respond to You as soon as possible.
  2. You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, if you are in the European Economic Area (“EEA”), please contact your local data protection authority in the EEA.

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Additional Information for California Users-CCPA Privacy Notice

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This privacy notice section for California residents supplements the information contained in this Policy and it applies solely to all visitors, users, and others who reside in the State of California.

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Categories of Personal Information Collected

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We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of Personal Information which we may collect or may have been collected from California residents within the last twelve (12) months.

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Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if you provided such Personal Information directly to Us：

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1. Category A: Identifiers and Account Information

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2. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

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3. Category C: Protected classification characteristics under California or federal law.

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4. Category D: Commercial information.

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5. Category E: Biometric information.

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6. Category F: Internet or other similar network activity.

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7. Category G: Geolocation data.

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8. Category H: Sensory data.

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9. Category I: Professional or employment-related information.

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10. Category 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).

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11. Category K: Inferences drawn from other personal information.

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12. Category L: Sensitive personal information.

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Under CCPA, personal information does not include:

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  1. Publicly available information from government records
  2. Deidentified or aggregated consumer information
  3. Information excluded from the CCPA's scope, such as:some text
    • 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

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Sources of Personal Information

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We obtain the categories of Personal Information listed above from the following categories of sources:

  1. Directly from you. For example, from the forms you complete on our Services, or preferences you express or provide through our Services.
  2. Indirectly from You. For example, from observing your activity on our Services.
  3. Automatically from You. For example, through cookies we or our service providers set on your device as you navigate through our Services.
  4. From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that we use to provide the Service to you.

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Use of Personal Information

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We may use or disclose Personal Information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

  1. To operate our Services and provide you with our Services.
  2. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Services.
  3. To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Services, we will use that personal information to respond to your inquiry. 
  4. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  5. As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  6. For internal administrative and auditing purposes.
  7. To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
  8. Other one-time uses.

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Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Personal Information" section.

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If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Policy.

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Disclosure of Personal Information

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We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business or commercial purposes:

  1. Category A: Identifiers and Account Information
  2. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  3. Category F: Internet or other similar network activity
  4. Category G: Geolocation data
  5. Category L: Sensitive personal information

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Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

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When we disclose Personal Information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.‍

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Share of Personal Information

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We may share, and have shared in the last twelve (12) months, Personal Information identified in the above categories with the following categories of third parties:

  1. Service providers
  2. Our affiliates
  3. Our business partners
  4. Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

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Sale of Personal Information

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As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing Personal Information, but not necessarily a monetary benefit. “Consumer” means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose. “Business” means us as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

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We do not sell Personal Information as the term sell is commonly understood. We do allow Service Providers to use your Personal Information for the business purposes described in this Policy, for activities such as advertising, marketing, or analytics, and these may be deemed a sale under CCPA/CPRA.

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We may sell and may have sold in the last twelve (12) months the following categories of Personal Information:

  1. Category A: Identifiers
  2. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  3. Category F: Internet or other similar network activity
  4. Category G: Geolocation data
  5. Category L: Sensitive personal information

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Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of Personal Information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

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Sale of Personal Information of Minors Under 16 Years of Age

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We do not knowingly collect Personal Information from minors under the age of sixteen (16) through our Services, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

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We do not sell the personal information of Consumers we actually know are less than sixteen (16) years of age, unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between thirteen (13) and sixteen (16) years of age, or the parent or guardian of a Consumer less than thirteen (13) years of age. Consumers who opt-in to the sale of Personal Information 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 by contacting us.

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If you have reason to believe that a child under the age of sixteen (16) has provided us with Personal Information, please contact Us with sufficient detail to enable Us to delete that information.

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Your Rights under the CCPA/CPRA

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The CCPA provides California residents with specific rights regarding their Personal Information. If you are a resident of California, you have the following rights:

  1. The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
  1. The right to know/access. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of Personal Information. Once we receive and confirm your 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 purposes for collecting or selling that Personal Information;
    • The categories of third parties with whom we share that Personal Information; and
    • The specific pieces of Personal Information we collected about you.

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If we sold your Personal Information or disclosed your Personal Information for a business purpose, we will disclose to you: 

  1. The right to say no to the sale or sharing of Personal Information (opt-out). You have the right to direct us to not sell your Personal Information. To submit an opt-out request, please contact us.
  1. The right to correct Personal Information. You have the right to correct or rectify any inaccurate Personal Information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our service providers to correct) your personal information, unless an exception applies.
  1. The right to limit use and disclosure of sensitive Personal Information. You have the right to request to limit the use or disclosure of certain sensitive Personal Information we collected about you, unless an exception applies. To submit, please contact us.
  1. The right to delete Personal Information. You have the right to request the deletion of your Personal Information under certain circumstances, subject to certain exceptions. Once we receive and confirm your 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: some text
    • 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 et. 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.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  1. The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by: some text
    • Denying goods or services to you
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to you
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

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Exercising Your CCPA Data Protection Rights

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In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us by email: legal@lamini.ai.

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Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information.

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Your request to us must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

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We cannot respond to your request or provide you with the required information if we cannot:

  1. Verify your identity or authority to make the request
  2. And confirm that the personal information relates to you

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We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

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Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

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For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

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Do Not Sell My Personal Information

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As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing Personal Information, but not necessarily a monetary benefit.

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We do not sell Personal Information as the term sell is commonly understood. We do allow service providers to use your Personal Information for the business purposes described in our Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA.

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You have the right to opt-out of the sale of your Personal Information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your Personal Information. To exercise your right to opt-out, please contact us.

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The service providers we partner with (for example, our analytics or advertising partners) may use technology on the Services that sells “personal information” as defined by the CCPA. If you wish to opt out of the use of your Personal Information for interest-based advertising purposes and these potential sales as defined under CCPA, you may do so by following the instructions below.

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Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

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Limit the Use or Disclosure of Sensitive Personal Information

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If you are a California resident, you have the right to limit the use and disclosure of your sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

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We collect, use and disclose sensitive Personal Information in ways that are necessary to provide the Services. For more information on how We use Your Personal Information, please see the "Use of Your Personal Information" section or contact us.

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Contact Us

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If you have any questions about this Policy, please contact us at legal@lamini.ai.