[//]: <> (Basically this whole document is a mashup of generated/pre-made documents from both https://termly.io/ and https://www.termsfeed.com/)
[//]: <> (and then modified slightly to fit our needs. We did not write most of this, but have done our best to make it reflect our goals/intentions.)
[//]: <> (However there is quite a lot of legalese here, and possibly broad policies which we do not necessarily want/need. In those cases we are more)
[//]: <> (than happy to revise/remove the problematic areas to clarify our goals/intentions.)

# Privacy Policy

## Last updated: March 17th, 2025

## Interpretation and Definitions

### Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

### Definitions

For the purposes of this Privacy Policy:

- **Account** means a unique account created for You to access Our Service or parts of Our Service.
- **Affiliate** means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- **Application** refers to Pretendo Network, the software program provided by the Company.
- **Company** (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Yesterware LLC.
- **Country** refers to: Florida, United States
- **Device** means any device that can access the Service such as a computer, a cellphone or digital tablet, or game console.
- **Personal Data** is any information that relates to an identified or identifiable individual.
- **Service** refers to the Application.
- **Service Provider** means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- **Usage Data** refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- **You/Your** means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

This privacy notice 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 https://pretendo.network, or any website of Ours that links to this privacy notice
- Download and use Our applications/software, 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 by using the contact details provided in the section "[Contact Us](#contact-us)" below

### SUMMARY OF KEY POINTS

***We aim to collect as little information as possible about You outside of what is required for Us to operate Our Services. We do not collect excess personal data, and we do not directly share Your information with 3rd parties outside of what is automatically collected as part of Our Services. We do not sell or otherwise profit from Your data.***

***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***](#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 [personal information You disclose to Us](#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 do not receive any information from third parties.

**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](#2-how-do-we-process-your-information).

**In what situations and with which parties do We share personal information?** We may share information in specific situations and with specific third parties. Learn more about [when and with whom We share Your personal information](#4-when-and-with-whom-do-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](#8-how-do-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](#9-what-are-your-privacy-rights).

**How do You exercise Your rights?** The easiest way to exercise Your rights is 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).

### TABLE OF CONTENTS

1. [What Information Do We Collect?](#1-what-information-do-we-collect)
2. [How Do We Process Your Information?](#2-how-do-we-process-your-information)
3. [What Legal Bases Do We Rely on to Process Your Personal Information?](#3-what-legal-bases-do-we-rely-on-to-process-your-information)
4. [When and With Whom Do We Share Your Personal Information?](#4-when-and-with-whom-do-we-share-your-personal-information)
5. [Do We Use Cookies and Other Tracking Technologies?](#5-do-we-use-cookies-and-other-tracking-technologies)
6. [Is Your Information Transferred Internationally?](#6-is-your-information-transferred-internationally)
7. [How Long Do We Keep Your Information?](#7-how-long-do-we-keep-your-information)
8. [How Do We Keep Your Information Safe?](#8-how-do-we-keep-your-information-safe)
9. [What Are Your Privacy Rights?](#9-what-are-your-privacy-rights)
10. [Controls for Do-not-track Features](#10-controls-for-do-not-track-features)
11. [Do California Residents Have Specific Privacy Rights?](#11-do-california-residents-have-specific-privacy-rights)
12. [Do Virginia Residents Have Specific Privacy Rights?](#12-do-virginia-residents-have-specific-privacy-rights)
13. [Do We Make Updates to This Notice?](#13-do-we-make-updates-to-this-notice)
14. [Contact Us](#contact-us)

### 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, but is not limited to, the following:

- User Account Details, such as the username and email You provided upon sign up.
- Profile information, such as Your gender, birthday, country, and language.
- Contact Preferences, such as if You wish to receive a newsletter We may offer.
- Console identifiers, for authenticating You to the services.
- The IP address(es) You use when connecting to Our services.
- Your primary 'Mii' character.
- Details of Your connected accounts, such as Your Discord and Google account identifiers.

**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](https://stripe.com/privacy).

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 may 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.

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). This information is used to ensure compatibility with devices and locate areas of Our Services which may be having issues.
- *Device Data.* We may collect data about the 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 (console serial numbers), location, browser type, hardware model, and system configuration information. This data is uses for moderation and to ensure valid clients are reaching the expected Services.
- *Location Data.* We do not collect location data, either either precise or imprecise, directly. Games may at times send location based data, for the intent of geolocation and region locking purposes, however this is not stored or processed by Our Services.

Pretendo Network uses various 3rd party services as part of Our infrastructure. These 3rd parties may collect additional information outside of our control, but are required for the operation of Our Services. Please refer to the relevant parties policies:

- [Cloudflare](https://www.cloudflare.com/privacypolicy/)
- [Bunny](https://bunny.net/privacy/)
- [Discourse](https://www.discourse.org/privacy)
- [Stripe](https://stripe.com/privacy)
- [Mastodon](https://mastodon.pretendo.network/privacy-policy)

### 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 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 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 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.

### 3. What Legal Bases Do We Rely on to Process Your Personal 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](#9-what-are-your-privacy-rights).
- **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:
  - Analyze how Our Services are used so We can improve them to engage and retain users
  - 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](#9-what-are-your-privacy-rights) 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 third parties.*

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

- **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. Similarly, other users will be able to view descriptions of Your activity, communicate with You within Our Services, and view Your profile.
- **3rd Parties.** When using Our Services, Your data may be automatically collected by the various 3rd party services in use as part of Our infrasture. Pretendo Network does not share or sell Your data to these 3rd parties. The data collected is automatic, through normal usage of Our Services and is required for the operation of Our Services.

### 5. Do We Use Cookies and Other Tracking Technologies?

***In Short:*** *We may use cookies and other tracking technologies to collect and store Your information.*

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how We use such technologies and how You can refuse certain cookies is set out in Our [Cookie Notice](/terms/cookies).

### 6. Is Your Information Transferred Internationally?

***In Short:*** *We may transfer, store, and process Your information in countries other than Your own.*

We operate servers in various countries, including in the United States and Germany. If You are accessing Our Services from outside of the countries where Our Services are operating, 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?](#4-when-and-with-whom-do-we-share-your-personal-information)" above), in and other countries.

If You are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in Your country. However, We will take all necessary measures to protect Your personal information in accordance with this privacy notice and applicable law.

### 7. How Long Do We Keep Your Information?

***In Short:*** *We keep Your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.*

We will only keep Your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require Us keeping Your personal information for longer than the period of time in which users have an account with Us.

When We have no ongoing legitimate business need to process Your personal information, We will either delete or anonymize such information, or, if this is not possible (for example, because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further processing until deletion is possible.

### 8. 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.

### 9. What Are Your Privacy Rights?

***In Short:*** *In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, You have rights that allow You greater access to and control over Your personal information. You may review, change, or terminate Your account at any time. These rights are extended to all users regardless of region.*

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 "[Contact Us](#contact-us)" 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](https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm) or [UK data protection authority](https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/).

If You are located in Switzerland, You may contact the [Federal Data Protection and Information Commissioner](https://www.edoeb.admin.ch/edoeb/en/home.html).

**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 "[Contact Us](#contact-us)" 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.

#### Account Information

If You would at any time like to review or change the information in Your account or terminate Your account, You can:

- Use the provided methods of managing Your account on Your given game console.
- Contact Us using the contact information provided.

Upon Your request to terminate Your account, We will deactivate or delete Your 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. We may also retain some account information, such as both the account usernames and Your account principal ID, in order to prevent reallocation and for various system 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.

### 10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting You can activate to signal Your privacy preference not to have data about Your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates Your choice not to be tracked online. If a standard for online tracking is adopted that We must follow in the future, We will inform You about that practice in a revised version of this privacy notice.

### 11. Do California Residents Have Specific Privacy Rights?

***In Short:*** *Yes, if You are a resident of California, You are granted specific rights regarding access to Your personal information. These rights are extended to all users regardless of region.*

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 would like to make such a request, please submit Your request in writing to Us using the contact information provided below.

If You are under 18 years of age, reside in California, and have a registered account with Services, You have the right to request removal of unwanted data that You publicly post on the Services. To request removal of such data, please contact Us using the contact information provided below and include the email address associated with Your account and a statement that You reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all Our systems (e.g., backups, etc.).

#### CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

The rights described above are extended to all users regardless of California residency.

**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                                                                                                          | NO            |
| 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                                                                                                                                                                             | NO            |
| 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                                                | NO            |
| G. Geolocation data                                                                  | Device location                                                                                                                                                                                          | NO            |
| H. Audio, electronic, visual, thermal, olfactory, or similar information             | Images and audio, video or call recordings created in connection with Our business activities                                                                                                            | NO            |
| 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                             | NO            |
| J. Education Information                                                             | Student records and directory information                                                                                                                                                                | NO            |
| 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 Information                                                    |                                                                                                                                                                                                          | 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 C - As long as the user has an account with Us
- Category D - As long as the user has an account with Us

We may also collect other personal information outside of these categories through instances where You interact with Us in person, online, or by phone or mail in the context of:

- Receiving help through Our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of Our Services and to respond to Your inquiries.

**How do We use and share Your personal information?**

More information about Our data collection and sharing practices can be found in this privacy notice.

You may contact Us or by referring to the contact details at the bottom of this document.

If You are using an authorized agent to exercise Your right to opt out We may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on Your behalf.

**Will Your information be shared with anyone else?**

We will not directly share Your information with any 3rd parties outside of the automatic data collection implemented by the 3rd parties as part of Our infrastructure.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to Service users, website visitors, users, and other consumers.

**Your rights with respect to Your personal data**

*Right to request deletion of the data — Request to delete*

You can ask for the deletion of Your personal information. If You ask Us to delete Your personal information, We will respect Your request and delete Your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, Our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. Additionally, we operate several archives of historical data prior to the shutdown of Nintendo Network. The data held in these archives may be viewed publicly and are exempt from various GDPR and related laws regarding data deletion as they are archived for the interest of the public. See each archives respective policies for how dtaa retention is handled.

*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., 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.
- You may request to opt out from future selling or sharing of Your personal information to third parties. Upon receiving an opt-out request, We will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, You can contact Us or by referring to the contact details at the bottom of this document. If You have a complaint about how We handle Your data, We would like to hear from You.

### 12. Do Virginia Residents Have Specific Privacy Rights?

***In Short:** Yes, if You are a resident of Virginia, You may be granted specific rights regarding access to and use of Your personal information. These rights are extended to all users regardless of region.*

**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](#1-what-information-do-we-collect)
- [How We use Your personal data](#2-how-do-we-process-your-information)
- [When and with whom We share Your personal data](#4-when-and-with-whom-do-we-share-your-personal-information)

*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 will not directly share Your information with any 3rd parties outside of the automatic data collection implemented by the 3rd parties as part of Our infrastructure.

We have not sold any personal data to third parties for business or commercial purposes. We will not sell personal data in the future belonging to Service users, website visitors, users, and other consumers.

*Exercise Your rights provided under the Virginia CDPA*

More information about Our data collection and sharing practices can be found in this privacy notice.

You may contact Us by 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 privacy@pretendo.network. 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](https://www.oag.state.va.Us/consumer-protection/index.php/file-a-complaint).

### 13. Do We Make Updates to This Notice?

***In Short:** Yes, We will update this notice as necessary to stay compliant with relevant laws.*

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If We make material changes to this privacy notice, We may notify You either by prominently posting a notice of such changes or by directly sending You a notification. We encourage You to review this privacy notice frequently to be informed of how We are protecting Your information.

## Modifications to the Policy

We may update this Privacy Policy from time to time. We will notify You of any changes by updating the "Last updated" date at the top of this policy. We may also notify You of any changes via email. You are advised to review this page periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

### Contact Us

If You have any questions about this policy, You can contact Us:

- By email: privacy@pretendo.network
