California Privacy Notice

Last Updated Date: May 28, 2020

This California Privacy Notice (“Notice”) supplements the information contained in Eturi Corp.’s (“Eturi,” “we,” “our,” or “us”) Privacy Policy and applies solely to California consumers. We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms used in this Notice but not defined shall have the meaning ascribed to them in the CCPA. For the purpose of this Notice, we refer to our website, https://ourpact.com, and our applications, including those for use on mobile devices, tablets, personal computers, and any other devices that connect to the internet that link to this Privacy Notice, such as OurPact and OurPact Jr., collectively as the “Services.”

1. What Information is Covered by this Notice?

This Notice relates to our collection, use, and disclosure of California consumers’ personal information. “Personal information,” as used herein, generally means information that relates to you or your household. The chart below identifies the categories of personal information we have collected about California consumers in the previous 12 months. We have also identified the categories of personal information that we have disclosed for a business purpose in the preceding 12 months and the categories of third parties to whom the information was disclosed.

CategoryCollected – From/About Parents or Legal Guardians (i.e., General Users of Our Services)Collected – From/About Your ChildrenCategories of Third Parties to Whom We Have Disclosed Personal Information for a Business Purpose
A. Identifiers.

Yes

Examples: real name, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.

Yes

Examples: real name, date of birth, and age.

Service providers

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

Some personal information included in this category may overlap with other categories.

Yes

Examples: real name, address, telephone number, credit card number, debit card number, and similar financial information.

Yes

Example: real name.

Service providers

C. Protected classification No characteristics under California or federal law.

No

Yes

Service providers Example: gender.

Service providers

D. Commercial information.

Yes

Examples: Your purchasing or consuming histories or tendencies as it relates to Eturi products and services.

No

Service providers

F. Internet or other similar network activity.

Yes

Examples: device information such as operating system, device operating system version, IP addresses, browser type and language, browser version, and device identifier numbers. Other examples may include browsing history, search history, information on a consumer's interaction with a website, application, information provided via the chat feature, or advertisement.

Yes

Examples: device access times, device identifier numbers, apps installed on child’s device, information relating to child’s device permission status, and encrypted screenshots generated by your Eturi Applications account and the transcribed content from the screenshots (“Screenshots”).

Screenshots may capture children’s browsing activity, search activity, messaging activity, and other information regarding a child’s interaction with an Internet website, application, advertisement, device or interactions with a device in general, such as via the chat feature.

Other examples include information about child’s usage and activity in connection with the Services (e.g., error/crash reporting, usage analytics such as screen views, your child’s use of any hyperlinks available within the Services, time on page, and page hits).

Service providers

G. Geolocation data.

No

Yes

Service providers

H. Sensory data.

No

Yes

Example: profile photos that you may upload of your child.

Service providers

L. Information required to support certain Services features.

Some personal information included in this category may overlap with other categories.

Yes

Examples: custom word lists, schedules you may create to schedule device access for your child’s device and related screen time allowance information, geofence location information and preferences.

Yes

Examples: Screenshots, information relating to which apps are installed on the child’s device information relating to child’s device status/permission status, geofence notifications when leaving or entering a predefined area.

Service providers

2. What Are The Sources From Which Personal Information is Collected?

We have identified the categories of sources from which we collect personal information in Section 2 (How We Collect Information) of our Privacy Policy.

3. How Do We Use Personal Information?

We may use your personal information for a variety of business or commercial purposes. For a detailed list explaining how we may use personal information, please see Section 3 (How We Use the Personal Information We Collect) of our Privacy Policy. For information relating to how we use the personal information we collect relating to children, please see Section 5 (Children’s Privacy Rights) of our Privacy Policy.

4. Who Do We Share Personal Information With?

Under certain circumstances, we may share your personal information with third parties. The chart above in Section 1 (What Information is Covered by this Notice) identifies the categories of personal information that we have disclosed for a business purpose in the preceding 12 months and the categories of third parties to whom the information was disclosed. Eturi does not sell personal information including personal information of minors under 16 years of age.

5. Your CCPA Rights.

Subject to certain exceptions, the CCPA affords California consumers the following rights:

  1. a. Request to Know. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following, as requested by you:

    • The specific pieces of personal information we collected about you.

    • The categories of personal information we collected about you.

    • The categories of sources from which we collect personal information about you.

    • The categories of personal information that we have disclosed about you for a business purpose.

    • The categories of third parties to whom we have disclosed your personal information for a business purpose.

    • Our business or commercial purpose for collecting personal information.

  2. b. Request to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete, as applicable) your personal information from our records, unless an exception applies.

  3. c. Request to Opt-Out of the Sale of Personal Information. California consumers have the right to opt out of the sale of their personal information by a business. As noted above, however, Eturi does not sell personal information.

  4. d. No Discrimination. You have a right not to receive discriminatory treatment by Eturi for the exercise of the privacy rights conferred by the CCPA.

6. How to Exercise Your CCPA Rights

  1. a. Submitting a Request to Know. You may submit a Request to Know by emailing us at dataprotection@ourpact.com.

  2. b. Submitting a Request to Delete. You may submit a Request to Delete by emailing us at dataprotection@ourpact.com or by mailing us at 2255 El Camino Real STE 125, San Diego CA 92130.

  3. c. Verification Methods. Once you submit a request, we will verify that you are the consumer to which the request pertains by matching the identifying information provided by you (e.g., name, email address, account-related information) to the information we maintain. Depending on the type of request you submit, we will attempt to match either two or three of the data points you provided. If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request.

    You can select an “authorized agent” to submit requests on your behalf. We will require the authorized agent to have a written authorization confirming that authority. We may also require you to verify your own identity directly with us. Once your authorized agent is verified, they may submit a request in the typical way described above.

7. Alternate Format of CCPA Notice.

If you have a disability that prevents or limits your ability to access this CCPA Notice, please email us at dataprotection@ourpact.com. We will work with you to provide this notice in an alternative format.

8. Contact for More Information.

If you have any questions or concerns about our privacy policies and practices, please contact us at dataprotection@ourpact.com or, by mail, to: Eturi Corp., Attn: Data Protection Officer - Legal, 12255 El Camino Real STE 125, San Diego CA 92130.