This Privacy Policy explains how we collect, use, and share your information when you interact with the Service. It also outlines your privacy rights and explains how applicable laws help protect those rights.
We handle your personal information to deliver and improve the Service. By continuing to use the Service, you agree to the practices described in this Privacy Policy.
Interpretation
Terms starting with capital letters have defined meanings outlined in the following sections. These meanings apply equally, whether used in the singular or plural.
Definitions
For the purposes of this Privacy Policy:
Affiliate refers to any organization that owns, is owned by, or is under shared ownership with another party, where "ownership" means having 50% or more of the voting shares or equivalent control.
Application refers to any software product made available by the Company for installation on your electronic device.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
CCPA and/or CPRA refer to the California Consumer Privacy Act and its amendment, the California Privacy Rights Act of 2020.
Company (also referred to as "the Company," "We," "Us," or "Our") means Southley Technology Limited. Under the GDPR, the Company acts as the Data Controller.
Consumer, as defined by the CCPA/CPRA, means a natural person who resides in California. A resident includes:
any individual currently in the U.S. not on a temporary visit, and
any individual domiciled in the U.S. but temporarily living abroad.
Data Controller, as defined by the GDPR, is the entity (here, the Company) that alone or jointly decides the purpose and method of processing Personal Data.
Device indicates any tool capable of accessing the Service, such as a smartphone or tablet.
GDPR stands for the General Data Protection Regulation enforced within the European Union.
Personal Data refers to information that can identify a specific person. Under GDPR, this includes data like names, ID numbers, location info, online identifiers, and other personal attributes. Under CCPA/CPRA, it includes any information that relates to or could reasonably be linked to you directly or indirectly.
Service means the Application.
Service Provider refers to individuals or organizations that process data on the Company’s behalf. This includes contractors or partners who support Service operations or help analyze how the Service is used. Under GDPR, such entities are considered Data Processors.
Usage Data represents data collected automatically through your interaction with the Service, such as how long you spend on a page or feature.
You means the person using or accessing the Service, or the entity represented by that person. Under the GDPR, this may also be referred to as the Data Subject or User.
Types of Data We Collect
Personal Information
When using our Service, we may ask you to provide specific personal details that can be used to identify or contact you. This may include, but is not limited to:
Your email address
Usage information
Usage Information
We automatically collect Usage Data while you interact with the Service. This may involve data such as your Device’s IP address, browser type and version, pages visited, time and date of access, time spent on pages, device identifiers, and other diagnostic details.
If you access the Service through a mobile device, we may also collect information like:
Device model
Unique mobile ID
Mobile IP address
Mobile operating system and browser type
Additional technical and diagnostic identifiers
Your browser may also send us information automatically when you use our Service on any device.
This data may be used to personalize your experience, and could be stored locally on your device or uploaded to our or a third-party service provider’s servers, depending on usage. You can modify these access permissions through your device’s settings at any time.
The Company may process your data for the following reasons:
To operate and maintain the Service, including monitoring user activity
To fulfill contractual obligations and support ongoing service agreements
To contact you via email or notifications about updates, features, or security matters
To respond to and manage your support requests
To handle business changes like mergers, asset sales, or restructuring involving user data
To analyze data, understand trends, and improve our Service and overall experience
We may disclose your personal information in these situations:
Business transactions: During discussions or execution of mergers, acquisitions, or similar processes
With affiliates: To related entities under common ownership, in line with this Privacy Policy
With partners: To provide you with certain products or services
Public interactions: Information you share in public areas may become publicly visible
With your approval: For any other purpose, with your explicit consent
We retain your Personal Data only as long as necessary to fulfill the purposes detailed in this Privacy Policy. It may also be stored longer if required to comply with legal obligations, resolve disputes, or enforce agreements.
Usage Data is usually kept for shorter periods unless it is needed to boost security, improve functionality, or meet legal requirements.
Your Personal Data may be handled at the Company's headquarters or other locations where related parties are based. As a result, your information could be transferred to and stored in regions beyond your state, province, or country—where privacy laws might not offer the same protections as those in your jurisdiction.
By accepting this Privacy Policy and submitting your information, you acknowledge and agree to such data transfers.
The Company will take appropriate and reasonable precautions to ensure your data is processed securely and in line with this Privacy Policy. No transfer will occur to any organization or country unless proper security measures are in place to protect your Personal Data and associated information.
You reserve the right to request the removal of any Personal Data we have collected from you. We are committed to helping you exercise this right.
The Service may include tools that allow you to erase specific personal details directly.
You can also modify, correct, or delete your information by adjusting your personal settings within the Service. If preferred, you may contact us to request access to, changes to, or deletion of your submitted information.
Please note that certain data may need to be retained where legally required or when justified by legitimate grounds.
Business Changes
In the event of a merger, acquisition, or asset sale involving the Company, your Personal Data may be included in the transferred assets. You will be notified before the transfer, and a new Privacy Policy may then apply.
Legal Requirements
The Company may disclose your Personal Data when required by law or in response to legitimate requests from legal authorities, such as courts or government agencies.
Other Circumstances
We may also disclose your information in good faith when necessary to:
Fulfill legal duties
Defend the Company's rights or property
Prevent or address unlawful activity related to the Service
Ensure the safety of users or the public
Protect against potential legal claims
Protecting your Personal Data is a priority for us. However, please be aware that no method of online transmission or digital storage can be entirely secure. While we take reasonable precautions to safeguard your data, we cannot guarantee complete protection.
Certain third-party Service Providers we work with may gain access to your Personal Data. These external vendors may collect, handle, store, use, and share information about your activity on our Service, in accordance with their own privacy policies.
To better understand and improve how users interact with our Service, we may use third-party analytics tools.
Google Analytics
Google Analytics is a web-based tool from Google that tracks and generates reports on site traffic and user interactions. The information it gathers helps us analyze usage patterns within the Service. Google may also share this data with its affiliated services and use it for ad personalization within its network.
You can disable certain Google Analytics features through your mobile device settings (e.g., ad preferences), or by following the guidance found in Google’s Privacy Policy: https://policies.google.com/privacy
To learn more about how Google protects your data, visit: https://support.google.com/analytics/answer/6004245
Firebase
Firebase, another analytics platform offered by Google Inc., helps us track Service usage. Like Google Analytics, you can control certain features through your device's advertising settings or follow Google’s instructions in their privacy documentation.
For further details about how Firebase collects and processes information, please review:
https://policies.google.com/privacy
https://policies.google.com/technologies/partner-sites
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Apple Store In-App Payments
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
The Company uses remarketing to advertise to you after visiting our Service. We and third-party vendors use cookies and other technologies to recognize your device and understand your Service usage, enabling us to improve it and serve more relevant ads to you.
These third-party vendors collect, store, use, process, and transfer information about your activity on our Service per their Privacy Policies to enable us to:
- Measure and analyze traffic and browsing activity on our Service
- Show ads for our products/services on third-party sites or apps
- Measure and analyze the performance of our ad campaigns
Some vendors may use non-cookie technologies unaffected by browser settings blocking cookies. Your browser may not block these technologies. Use the following third-party tools to decline interest-based advertising information collection:
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
The EDAA's opt-out platform http://www.youronlinechoices.com/
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You can opt-out of personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). Refer to your device's Help system for more details.
We may share information like hashed email addresses or other online identifiers collected on our Service with third-party vendors. This helps them recognize you and deliver ads across devices and browsers. For more details on the technologies used and their cross-device capabilities, please review the Privacy Policies of each vendor listed below.
The third-party vendors We use are:
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or similar activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Legal Grounds for Processing Personal Data Under the GDPR
We may process your Personal Data under one or more of the following legal justifications:
Consent: You have given us clear permission to handle your data for specific, identified purposes.
Contractual necessity: Processing is essential to carry out a contract with you or to take steps at your request before entering into one.
Legal compliance: Processing is required to meet a legal duty that applies to the Company.
Vital interests: Processing is necessary to safeguard your vital interests or those of another person.
Public interest: Data is processed as part of a task carried out in the public interest or under official authority granted to the Company.
Legitimate interests: Processing is needed for purposes pursued by the Company that are deemed legitimate.
If clarification is needed, the Company will help explain which legal basis applies and whether the data is required by law, by contract, or for entering into an agreement.
We are committed to protecting your Personal Data and upholding your rights. If you are located in the EU, you are entitled to the following rights:
Access: You may view, update, or delete your data via your account settings. Contact us if assistance is needed.
Correction: You have the right to correct any inaccurate or incomplete personal information.
Objection: You may object to the processing of your data where we rely on legitimate interests, based on your particular circumstances.
Erasure: You may request the deletion of your data where no lawful reason for continued processing exists.
Data portability: You can request that your data be provided in a structured, commonly used, machine-readable format for transfer to you or a third party. This applies to data processed based on consent or contract.
Withdrawal of consent: You may withdraw your consent at any time. Note that doing so may limit access to some features of the Service.
To exercise your rights—such as access, correction, deletion, or objection—please contact us directly. We may ask you to verify your identity before processing your request. We aim to respond promptly to all inquiries.
If you believe your data has been mishandled, you have the right to file a complaint with a Data Protection Authority. If you are based in the EEA, please contact your local authority for further guidance.
This section of our Privacy Policy is specifically intended for residents of California and serves as an addendum to the general Privacy Policy. It applies exclusively to individuals living in the State of California who visit, use, or interact with our Service.
We may collect personal data that can identify, describe, relate to, reference, or reasonably be linked—either directly or indirectly—to a specific consumer or device. Below are the categories of personal information we may have collected from California residents in the past twelve (12) months.
The categories and corresponding examples listed below follow the definitions established under the CCPA/CPRA. While not every type of information listed has necessarily been collected by us, the list represents a good faith assessment of the categories that may apply, based on our current data practices. Certain types of information are only collected when voluntarily submitted by you.
Category A: Identifiers
Examples: Real name, alias, mailing address, unique identifiers, online ID, IP address, email, account name, driver's license or passport number, etc.
Collected: Yes
Category B: Personal data under California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples: Name, signature, Social Security number, physical description, contact details, ID numbers, insurance data, education or job history, financial and health-related information.
Collected: Yes
Category C: Protected classification attributes (as defined by California or U.S. law)
Examples: Age (40+), race, ethnicity, religion, disability status, sex, gender identity or expression, sexual orientation, veteran status, etc.
Collected: No
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: Yes.
Category E: Biometric data
Examples: Fingerprints, facial recognition data, voiceprints, retina scans, or behavioral data such as keystroke patterns or health and activity tracking.
Collected: No
Category F: Internet or similar activity
Examples: Interactions with our services, websites, or ads.
Collected: Yes
Category G: Geolocation data
Examples: General location data.
Collected: No
Category H: Sensory data
Examples: Audio, video, electronic, thermal, or olfactory information.
Collected: No
Category I: Employment-related details
Examples: Job history, performance records.
Collected: No
Category J: Education records (as defined by FERPA)
Examples: Grades, transcripts, class schedules, student IDs, financial aid data, and disciplinary actions.
Collected: No
Category K: Inferred data
Examples: User profiles indicating preferences, traits, behaviors, or psychological trends.
Collected: No
Category L: Sensitive personal information
Examples: Account credentials (e.g., login and password), geolocation identifiers.
Collected: Yes
Certain types of personal information are not considered within the scope of the CCPA/CPRA, including:
Public information made available via government records
Deidentified or aggregated data that cannot be linked to an individual
Data excluded under other regulatory frameworks, such as:
Health data covered by HIPAA or CMIA
Information from clinical trials
Financial data regulated by FRCA, GLBA, or FIPA
Driver-related data under the Driver's Privacy Protection Act of 1994
We collect the categories of personal information mentioned above from the following sources:
Direct input from you — For example, through forms you complete, or preferences you set when using our Service.
Indirect observations — Such as tracking how you interact with features of the Service.
Automated methods — Like cookies and other technologies placed on your device by us or our Service Providers while you browse the Service.
In line with what the CCPA/CPRA defines as “business purposes,” we may use or disclose the personal data we gather for activities such as:
Operating and delivering our Service to you
Providing customer support, resolving inquiries, and enhancing the Service
Meeting legal obligations, including responses to law enforcement or regulatory requests
As described at the time of data collection or permitted by applicable law
Conducting internal audits and administrative tasks
Identifying and preventing security threats, fraud, or illegal actions, including taking legal steps where needed
Supporting one-time operational tasks
These examples are not exhaustive. For more details, please refer to the “Use of Your Personal Data” section in our Privacy Policy.
If we intend to collect new categories of personal data or use existing information for substantially different or unrelated purposes, we will update this Privacy Policy accordingly.
In the past 12 months, we have used or disclosed, or may use or disclose, the following categories of personal data for business purposes:
Category A: Identifiers
Category B: Data listed in the California Customer Records statute
Category F: Internet or similar network activity
These categories follow CCPA/CPRA definitions. This does not mean all listed data types were disclosed but reflects our good faith belief that some data from these categories may have been shared.
When personal data is shared for business reasons, we enter into agreements that specify the purpose of sharing and require the recipient to maintain confidentiality and restrict usage to the agreed-upon purpose.
In the last 12 months, we may have shared your personal data—within the categories above—with:
Service Providers
Our Affiliates
Business Partners
Third parties whom you or your authorized representative have directed us to disclose information to in connection with services or products
Under CCPA/CPRA definitions, “sale” includes various forms of transferring personal data to third parties in exchange for value, which may be non-monetary.
We may have sold, and may sell, personal data falling into the following categories:
Category A: Identifiers
Category B: California Customer Records data
Category F: Internet or network activity
Please note that listing a category does not mean every type of data under that category was sold. This is based on our good faith understanding that some data may have been exchanged for value.
We do not knowingly collect personal data from individuals under the age of 16 through our Service. However, some third-party websites we may link to could collect such information independently. These external websites are governed by their own privacy policies and terms. We recommend that parents and guardians supervise their children’s internet use and instruct them not to share personal data on other platforms without permission.
We do not sell the personal data of users we know are under 16 unless we obtain clear opt-in consent. For users aged 13 to 16, we require their direct authorization; for users under 13, this must come from a parent or legal guardian. Anyone who opts in can withdraw their consent at any time. To opt out, you or an authorized representative can submit a request through our contact channels.
If you believe a child under 13 (or under 16) has shared personal data with us, please contact us with sufficient details so we can locate and remove the information.
If you're a California resident, the CCPA/CPRA grants you the following rights concerning your personal data:
Right to Notice: You have the right to be informed about the categories of personal data we collect and the purposes behind their use.
Right to Know/Access: Upon verified request, you may ask us to disclose:
The types of personal data we have collected about you
The sources from which the data was obtained
The business purposes behind collecting or selling the data
The third parties with whom we share personal information
Specific personal data we hold about you
If applicable, the categories of data we sold or disclosed for business purposes
Right to Opt-Out: You may request to opt out of the sale or sharing of your personal information at any time. See the “Do Not Sell My Personal Information” section or contact us directly.
Right to Correct: You can request correction of any inaccurate personal data. Upon verification, we will correct the information and inform our Service Providers to do the same, unless exemptions apply.
Right to Limit Use of Sensitive Information: You may request that we restrict how your sensitive personal data is used or disclosed, unless an exception permits broader use. See the “Limit the Use or Disclosure of My Sensitive Personal Information” section for more.
Right to Deletion: You can request deletion of your personal data. After confirming your request, we will remove the data unless we are legally obligated or permitted to retain it, such as:
Completing a transaction or fulfilling a contract
Detecting and preventing fraud or illegal activity
Debugging errors
Protecting free speech
Complying with applicable laws (e.g., CalECPA)
Supporting scientific or historical research with proper consent
Using the data internally in ways that align with your expectations
Other lawful and necessary uses
Right to Non-Discrimination: You are entitled to exercise your data rights without being treated unfairly. This includes:
No denial of goods or services
No price changes or penalties
No different service quality or access levels
No suggestion that you’ll receive different treatment for exercising your rights
To opt out or limit use of sensitive information, refer to the relevant sections of this Privacy Policy.
If you are a California resident and wish to exercise any of the above rights, you may contact us:
By email: feedback@southleytech.com
Requests must be submitted either by you or someone legally authorized to act on your behalf (e.g., an agent registered with the California Secretary of State).
To process your request, we must:
Verify your identity or the authority of your representative
Receive sufficient detail to understand and respond appropriately to your request
We are unable to act on your request unless these conditions are met.
Once verified, we will respond within 45 days at no cost. If more time is needed, we may extend the response period by another 45 days and inform you in advance.
Responses will include information from the 12 months prior to your request. If applicable, data will be provided in a portable format for easy transfer between entities.
Under the CCPA/CPRA, the terms “sell” and “sale” cover a range of activities, including renting, sharing, transferring, or otherwise disclosing a consumer’s personal data in exchange for something of value. This value may not always be financial in nature.
You have the right to opt out of the sale of your personal information. Once we receive and verify your request, we will stop selling your data. To exercise this right, please contact us using the information provided below.
Some of our partners—such as analytics providers—may use technology that qualifies as a "sale" under CCPA/CPRA. If you'd like to opt out of such activity, follow the steps outlined below.
Please note: the opt-out is browser-specific. You’ll need to repeat the process for each browser you use.
If available, click on buttons labeled “Privacy Preferences,” “Update Privacy Preferences,” or “Do Not Sell My Personal Information” to access and update your privacy choices. You can opt out of certain cookies and tracking technologies by following the on-screen instructions.
When you opt out, a cookie will be placed in that specific browser to remember your choice. If you delete cookies or switch browsers, you’ll need to opt out again.
As a California resident, you have the right to request limits on how your sensitive personal information is used and disclosed—only to what's necessary to provide the services or goods you reasonably expect.
We only use or share sensitive personal data as required to operate the Service. For more details, please see the “Use of Your Personal Data” section or contact us.
Our Service is not designed for children under the age of 13, and we do not knowingly collect personal information from them. If you’re a parent or guardian and believe your child has provided us with such data, please contact us immediately.
If we become aware that a child under 13 has submitted data without verified parental consent, we will promptly remove the data from our systems.
Where parental consent is legally required for data processing, we will request it before collecting or using such information.
Our Service may include links to third-party websites not operated by us. If you click on one of these links, you’ll be taken to that external site. We encourage you to read their Privacy Policies.
We do not control and are not responsible for the content, policies, or practices of third-party websites.
We may revise this Privacy Policy from time to time. Any updates will be posted on this page.
When changes are made, we’ll notify you via email and/or by placing a visible notice on the Service. The “Last updated” date will also be revised accordingly.
We recommend checking this policy periodically. Changes take effect once posted on this page.
If you have any questions about this Privacy Policy, you may contact us:
By email: feedback@southleytech.com