Privacy Policy

PRIVACY POLICY
Last updated August 23, 2023 This privacy notice for Daleely, Inc. ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you: Visit our website at Daleely.me, or any website of ours that links to this privacy notice Download and use our mobile application (Daleely), our Facebook application (Daleely), or any other application of ours that links to this privacy notice Engage with us in other related ways, including any sales, marketing, or events Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details
about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us. Do we process any sensitive personal information? We do not process sensitive personal information. Do we receive any information from third parties?
We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information. In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information. How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your
personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe. What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights. How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends
on the context of your interactions with us and the Services, the choices you make, and the
products and features you use. The personal information we collect may include the
following: names, phone numbers, email addresses, mailing addresses, job titles,
usernames, passwords, contact preferences, contact or authentication data, billing
addresses, and debit/credit card numbers
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make
purchases, such as your payment instrument number, and the security code associated with
your payment instrument. All payment data is stored by Stripe. You may find their privacy
notice link(s) here: https://stripe.com/privacy.
Social Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, Twitter, or other social media
accounts. If you choose to register in this way, we will collect the information described in
the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
Application Data. If you use our application(s), we also may collect the following
information if you choose to provide us with access or permission:
• Geolocation Information. We may request access or permission to track location-
based information from your mobile device, either continuously or while you are
using our mobile application(s), to provide certain location-based services. If you
wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from
your mobile device, including your mobile device's bluetooth, calendar, camera,
contacts, microphone, reminders, sensors, sms messages, social media accounts,
storage, and other features. If you wish to change our access or permissions, you
may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your
mobile device ID, model, and manufacturer), operating system, version information
and system configuration information, device and application identification
numbers, browser type and version, hardware model Internet service provider

•and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are
using our application(s), we may also collect information about the phone network
associated with your mobile device, your mobile device’s operating system or
platform, the type of mobile device you use, your mobile device’s unique device ID,
and information about the features of our application(s) you accessed.
Push Notifications. We may request to send you push notifications regarding your
account or certain features of the application(s). If you wish to opt out from
receiving these types of communications, you may turn them off in your device's
settings.
This information is primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and
you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser
and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services.
This information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring URLs,
device name, country, location, information about how and when you use our Services, and
other technical information. This information is primarily needed to maintain the security
and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related diagnostic, usage, and
performance information our servers automatically collect when you access or use our
Services and which we record in log files. Depending on how you interact with us, this log
data may include your IP address, device information, browser type, and settings and
information about your activity in the Services (such as the date/time stamps associated
with your usage, pages, and files viewed, searches, and other actions you take such as which
features you use), device event information (such as system activity, error reports
(sometimes called "crash dumps" ), and hardware settings).
Device Data. We collect device data such as information about your computer, phone,
tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware model, Internet
service provider and/or mobile carrier, operating system, and system configuration
information.
Location Data. We collect location data such as information about your device's location,
which can be either precise or imprecise. How much information we collect depends on the
type and settings of the device you use to access the Services. For example, we may use GPS
and other technologies to collect geolocation data that tells us your current location (based
on your IP address). You can opt out of allowing us to collect this information either by
refusing access to the information or by disabling your Location setting on your device.
However, if you choose to opt-out, you may not be able to use certain aspects of the
Services.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social
media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you
and update our records, we may obtain information about you from other sources, such as
public databases, joint marketing partners, affiliate programs, data providers, social media
platforms, and from other third parties. This information includes mailing addresses, job
titles, email addresses, phone numbers, intent data (or user behavior data), Internet
Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for
purposes of targeted advertising and event promotion. If you interact with us on a social
media platform using your social media account (e.g., Facebook or Twitter), we receive
personal information about you such as your name, email address, and gender. Any
personal information that we collect from your social media account depends on your social
media account's privacy settings.
Information is collected when you use our Facebook application(s). We by default access
your Facebook basic account information, including your name, email, gender, birthday,
current city, and profile picture URL, as well as other information that you choose to make
public. We may also request access to other permissions related to your account, such as
friends, check-ins, and likes, and you may choose to grant or deny us access to each
individual permission. For more information regarding Facebook permissions, refer to the
Facebook Permissions Reference page.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with the law. We may
also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
• To facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
• To deliver and facilitate the delivery of services to the user. We may process your
information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your
information to respond to your inquiries and solve any potential issues you might
have with the requested service.
• To send administrative information to you. We may process your information to
send you details about our products and services, changes to our terms and policies,
and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and
manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you
choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request
feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the
personal information you send to us for our marketing purposes if this is in
accordance with your marketing preferences. You can opt out of our marketing
emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?"
below.
• To deliver targeted advertising to you. We may process your information to develop
and display personalized content and advertising tailored to your interests, location,
and more.
• To protect our Services. We may process your information as part of our efforts to
keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our
Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We
may process your information to better understand how to provide marketing and
promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we
have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

Send users information about special offers and discounts on our products and services
Develop and display personalized and relevant advertising content for our users
Analyze how our Services are used so we can improve them to engage and retain users
Support our marketing activities
Diagnose problems and/or prevent fraudulent activities
Understand how our users use our products and services so we can improve user experience

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in
a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of
financial abuse
• If it is reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a contravention of the
laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the
court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the information
was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or
with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data
with third-party vendors, service providers, contractors, or agents ("third parties") who
perform services for us or on our behalf and require access to such information to do that
work. We have contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do anything with your
personal information unless we have instructed them to do it. They will also not share your
personal information with any organization apart from us. They also commit to protecting the
data they hold on our behalf and to retain it for the period we instruct. The categories of
third parties we may share personal information with are as follows:

Ad Networks
Affiliate Marketing Programs
Communication & Collaboration Tools
Data Analytics Services
Data Storage Service Providers
Government Entities
Order Fulfillment Service Providers
Payment Processors
Performance Monitoring Tools
Product Engineering & Design Tools
Retargeting Platforms
Sales & Marketing Tools
Social Networks
Testing Tools
User Account Registration & Authentication Services
Website Hosting Service Providers
Cloud Computing Services
Finance & Accounting Tools

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: __________; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled "HOW DO WE PROCESS YOUR INFORMATION?". We obtain and store on your device ("cache") your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use to store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services. The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The
inclusion of a link towards a third- party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
6. 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.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we
may have access to certain information about you.Our Services offer you the ability to register and log in using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose to do this, we will
receive certain profile information about you from your social media provider. The profile
information we receive may vary depending on the social media provider concerned, but
will often include your name, email address, friends list, and profile picture, as well as other
information you choose to make public on such a social media platform. If you log in using
Facebook, we may also request access to other permissions related to your account, such as
your friends, check-ins, and likes, and you may choose to grant or deny us access to each
individual permission.
We will use the information we receive only for the purposes that are described in this
privacy notice or that are otherwise made clear to you on the relevant Services. Please note
that we do not control, and are not responsible for, other uses of your personal information
by your third-party social media provider. We recommend that you review their privacy
notice to understand how they collect, use, and share your personal information, and how
you can set your privacy preferences on their sites and apps.
8. 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 the United States. If you are accessing our Services from outside
the United States, 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 the United States, 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.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using
the European Commission's Standard Contractual Clauses for transfers of personal
information between our group companies and between us and our third- party providers.
These clauses require all recipients to protect all personal information that they process
originating from the EEA or UK in accordance with European data protection laws and
regulations. Our Standard Contractual Clauses can be provided upon request. We have
implemented similar appropriate safeguards with our third-party service providers and
partners and further details can be provided upon request.Binding Corporate Rules:
These include a set of Binding Corporate Rules ("BCRs") established and implemented by us.
Our BCRs have been recognized by EEA and UK data protection authorities as providing an
adequate level of protection to the personal information we process internationally. You
can find a copy of our BCRs here: __________.
9. 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). No purpose in this notice will
require us keeping your personal information for longer than twelve (12) months past the
termination of the user's account.
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.
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational
and technical security measures.
We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from our Services is at
your own risk. You should only access the Services within a secure environment.
11. 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.
If you are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data
protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
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.
Opting out of marketing and promotional communications: You can unsubscribe from our
marketing and promotional communications at any time by clicking on the unsubscribe link
in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that
we send, or by contacting us using the details provided in the section "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing
lists. However, we may still communicate with you — for example, to send you service-
related messages that are necessary for the administration and use of your account, to
respond to service requests, or for other non-marketing purposes.
Account InformationIf you would at any time like to review or change the information in your account or
terminate your account, you can:
• Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account
and information from our active databases. However, we may retain some information in
our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce
our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default.
If you prefer, you can usually choose to set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject cookies, this could affect certain features
or services of our Services. You may also opt out of interest-based advertising by advertisers
on our Services.
If you have questions or comments about your privacy rights, you may email us at
[email protected].
12. 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.
13. 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 contactinformation 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:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	Yes
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	Yes
C. Protected classification characteristics under California or federal law	Gender and date of birth	Yes
D. Commercial information	Transaction information, purchase history, financial details, and payment information	Yes
E. Biometric information	Fingerprints and voiceprints	Yes
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	Yes
G. Geolocation data	Device location	Yes
H. Audio, electronic, visual, thermal, olfactory, or similar information	images and audio, video or call recordings created in connection with our business activities	Yes
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	Yes
J. Education Information	Student records and directory information	Yes
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	No
L. Sensitive Personal		No

We will use and retain the collected personal information as needed to provide the Services or for:
Category A - As long as the user has an account with us
Category B - As long as the user has an account with us Category
C - As long as the user has an account with us Category
D - As long as the user has an account with us Category
E - As long as the user has an account with us Category
F - As long as the user has an account with us Category
G - As long as the user has an account with us Category
H - As long as the user has an account with us Category
I - As long as the user has an account with us Category
J - As long as the user has an account with usWe 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?
We collect and share your personal information through:
• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags
• Click redirects: __________.
• Social media plugins: __________. We use social media features, such as a "Like"
button, and widgets, such as a "Share" button, in our Services. Such features may
process your Internet Protocol (IP) address and track which page you are visiting on
our website. We may place a cookie to enable the feature to work correctly. If you
are logged in on a certain social media platform and you interact with a widget or
button belonging to that social media platform, this information may be recorded to
your profile of such social media platform. To avoid this, you should log out from
that social media platform before accessing or using the Services. Social media
features and widgets may be hosted by a third party or hosted directly on our
Services. Your interactions with these features are governed by the privacy notices
of the companies that provide them. By clicking on one of these buttons, you agree
to the use of this plugin and consequently the transfer of personal information to
the corresponding social media service. We have no control over the essence and
extent of these transmitted data or their additional processing.
More information about our data collection and sharing practices can be found in this privacy
notice.
You can opt out from the selling or sharing of your personal information by disabling cookies in
Cookie Preference Settings and clicking on the Do Not Sell or Share My Personal Information
link on our homepage.
You may contact us by visiting daleely.me/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.
We have disclosed the following categories of personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months:

Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
Category E. Biometric information, such as fingerprints and voiceprints.
Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
Category G. Geolocation data, such as device location.
Category H. Audio, electronic, visual, and similar information, such as images and audio, video, or call recordings created in connection with our business activities.
Category I. Professional or employment-related information, such as business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
Category J. Education information, such as student records and directory information.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".
We have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:

Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
Category E. Biometric information, such as fingerprints and voiceprints.
Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
Category G. Geolocation data, such as device location.
Category H. Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities.
Category I. Professional or employment-related information, such as business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
Category J. Education information, such as student records and directory information.

The categories of third parties to whom we sold personal information are:
• Ad Networks
• Affiliate Marketing Programs
• Data Analytics Services
• Retargeting Platforms
• Social Networks
• User Account Registration & Authentication Services
The categories of third parties to whom we shared personal information with are:
• Ad Networks
• Affiliate Marketing Programs
• Data Analytics Services
• Retargeting Platforms
• Social Networks
• User Account Registration & Authentication Services
Your rights with respect to your personal data
Right to request deletion of the data — Request to deleteYou 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 by visiting daleely.me/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.
14. 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:
• Personal data we collect
• How we use your personal data
• When and with whom we share your personal data
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 sell personal data to third parties or process personal data for targeted advertising. Please
see the following section to find out how you can opt out from further selling or sharing of your
personal data for targeted advertising or profiling purposes.
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 can opt out from the selling of your personal data, targeted advertising, or profiling by
disabling cookies in Cookie Preference Settings. You may contact us by email at
[email protected], 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 [email protected].
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.
15. 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.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at [email protected]
17. 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.
This privacy policy was created using Termly's Privacy Policy Generator.