Privacy Policy

Last revised: 05/22/2023

Empathy Project Ltd. (and its affiliates) (“Empathy”, “we”, “our” or “us”) respects the privacy of the users of its Services (as such terms are defined in our Terms of Use available at: (“Terms”)), including (i) visitors to its website available at (and its subdomains) (the “Site”), which offers general information regarding Empathy and the Services, and (ii) users of its mobile application (the “App”), which provides a digital tool for dealing with loss, (collectively: the “User(s)” or “you”), and is committed to protecting the personal information that our Users share with us. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site and/or App and the associated Services. This policy (this “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit or use the Site, the App, and/or our Services and our practices for collecting, using, maintaining, protecting, and disclosing that information. Capitalized terms that are not defined herein shall have the meaning ascribed to them in our Terms, into which this Privacy Policy is incorporated by reference. 


By entering, connecting to, accessing or using the Site and/or the App and/or the Services we offer, you agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your personal information (as defined below). Please note: If you disagree with any term provided herein, you may not access or use the Site and/or the App and/or the Services in any manner. This Privacy Policy may change from time to time. Your continued use of the Site, the App and our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

For avoidance of doubt, you hereby consent to the collection, processing, transfer and use of your personal information. You also acknowledge and confirm that you are not required to provide us with your personal information and that such information is voluntarily provided to us.

2. What information may we collect from our Users?

We may collect two types of data and information from our Users:

2.1. Non-identifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from whom we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information that does not enable identification of an individual User, and that is available to us while such User is entering and/or using the Site and/or the App and/or the Services. You may access and browse our Services without disclosing personal information, although, like most websites and online services, we passively collect certain Non-Personal Information from your devices when you access and browse our Services, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, wifi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information that may include the User’s click-stream and tap-stream on the Site and the App, the activities of the User on the Site and the App, and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Google Analytics to obtain detailed analytics on the device and the User’s behavior on the Site and the App.

Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain technologies such as Cookies (as further detailed below). 

2.2. Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

  1. Personal Information is collected as part of the User’s communications with Empathy:

  • Personal Information is collected from the details you provide us, consciously and voluntarily, while starting to use our Services (e.g., before starting the Account registration process). You will be asked to answer several preliminary questions, which may include your full name and that of your loved one who has passed, your email address, your loved one’s state of residence and date of death, your relationship to your loved one, information regarding their preferences, etc. Additional information may be required from time to time in order to complete the registration process. 

  • Personal Information is collected from the details you provide us, consciously and voluntarily, as part of any communications with us, by any means, including while contacting us via our phone number, our email address, through our social media pages, by using our Helpline service or by approaching our customer and support services, including, inter alia, your and your loved one’s full names, your telephone number, your loved one’s state of residence and date of death, and your relationship with your loved one. To the extent necessary, for the provision of the services, you may optionally provide additional Personal Information to our representatives, including, inter alia, financial statements. Once your contact details are received by us, our representative may contact you for further communication and as such may collect additional Personal Information from you. 

  • Personal Information may be (i) included in the User-Generated Content you may upload, post, generate or publish on the Site and/or on the App, and (ii) uploaded by you while using the Vault service, such as personal photos and legal and financial documents.

  • We collect your email address when you register to our mailing lists.

  • Personal Information relating to job applicants. You may, at your discretion, use the “Join the Team” page available on our Site in order to apply to the open positions we publish on the Site. (In clicking on and applying to the relevant open position, you will be asked to provide us with some or all of the following: email address, contact details, your CV, etc., in order to be considered for the position.) Please note that we may also collect similar data relating to you from public sources, such as publicly available social media pages and public databases. In addition, please note the following: (i) the Personal Information collected as part of the application process, including any Personal Information included in your CV, may be accessed by our HR department and/or by Empathy’s managers, worldwide, solely for the purposes of evaluation and to enable us to contact you with respect to the recruitment process; (ii) if you submit an application on behalf of a third party, you hereby acknowledge that such third party was made aware of this Privacy Policy and has granted his/her consent to the processing of his/her Personal Information by Empathy; (iii) Empathy will retain Personal Information collected from applicants solely for the period that is necessary for the purposes set forth under this Privacy Policy or for the maximum statutory period in which a claim with respect to the recruitment process may be brought against Empathy; and (iv) if you have successfully been recruited to work for Empathy, any Personal Information collected as part of the application process may be retained by Empathy for the purposes of your employment.

Please note: If the Personal Information you provide to us includes information about others, you represent and warrant that you are legally authorized to disclose such information to us and you are fully and solely responsible for providing all necessary information notices to affected data subjects and for obtaining the required consents under applicable law from these data subjects for the use, processing, sub-processing and storing of their information in accordance with these Terms.

b. Personal Information is collected from other sources: We may also obtain Personal Information from third parties service providers and/or partners in order to communicate and offer you our Services (“Empathy’s Partners”) and from publicly available sources in order to provide you with our Services (such as published obituaries in local newspapers, social media accounts, etc.). In addition, upon your request and to the extent that you provide us with applicable power of attorney and/or consent (as the case may be) we may also approach third parties (such as government agencies) on your behalf and collect Personal Information that is held by them, all in order to provide you with the Services.

c. Personal Information is also collected via technology

  • Geolocation data: While you use the Site and/or the App, we may access, collect, process, monitor and/or remotely store “geolocation data,” including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes.

  • Technical and Behavioral Information: To the extent that the Technical and Behavioral Information detailed above under Section 2.1 is linked to or associated with a specific individual, then such information will be considered as Personal Information. 

  • Identifiers: We process certain online identifiers, such as your Internet Protocol (IP) address, your Unique Device Identifier (UDID) or other unique identifiers for geolocation, targeted advertising and security purposes. In addition, when using the Site and/or the App, our authorized third-party service providers may collect your advertising identifiers, as further detailed below.

  • Please note that: We use third-party tracking services and usage logs to track and analyze data from Users of the Site and/or the App for security and fraud prevention purposes. We may also use cookies to gather information regarding your use of the Site and/or the App and the information that you searched for and accessed.

Please note that we do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of the Termsand the Privacy Policy.

3. How do we collect information on our Users?

There are a few methods that we use: 

  1. We collect information through your entry to and use of the Site and/or the App and/or your use of our other Services, including interactions with our social media pages. In other words, when you are using our Site and/or our App and/or our Services, we are aware of it and may gather, collect and store information related to such usage (such as the Non-Personal Information detailed above, and your IP address), either independently or through the help of our authorized third-party service providers, as detailed below.

  2. We collect information that you decide to provide us voluntarily. For example, we collect Personal Information when you register for a User Account and when you contact us via our email address or via our Helpline service. 

  3. We may collect information from third parties. Such information may include publicly available obituaries published in local newspapers, social media accounts, search engines or similar platforms, and contact details provided by Empathy’s Partners.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers, as detailed below.

4. Why do we collect this information?

4.1. Non-Personal Information is collected in order to:

  • Use it for statistical, analytical and research purposes and for customization, development and improvement of the Site and/or App and/or our Services.

  • Enhance the User’s experience while using the Services.

  • Keep the Site and/or the App safe and secure and to help prevent fraud.

4.2. Personal Information is processed by us in order to

  • Enable the provision of our Services.

  • Respond to your inquiries, requests, comments and suggestions.

  • Provide support and technical assistance.

  • Send you updates, notices, announcements, and additional information related to Empathy, including regarding changes made to our Terms and updated information regarding our Services, by email, SMS or phone, through App notifications or through the post.

  • Conduct online surveys to better understand your needs and how we can modernize, innovate and improve our Services.

  • Conduct internal operations, including for troubleshooting, data analysis, testing, research and statistical purposes.

  • Comply with our legal obligations, and in order to be able to protect our rights and legitimate interests, including improving our services. 

  • Maintain our data-processing records and for general administrative purposes.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of the Terms.

5. Sharing Information with Third Parties

Empathy respects its Users’ privacy and will not disclose, share, rent or sell their Personal Information to any third party, other than as permitted under these Terms. 

In addition to using the information collected by us for the purposes described ‎above, we may also share your Personal Information in the following cases: 

  • Empathy’s Personnel: Personal Information that we collect and process may be transferred to or accessed by Empathy’s personnel for the sole purposes of enabling the provision of our Services and to contact you. Please note that all of Empathy’s personnel who will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.  

  • Service Providers: We may share Personal Information with commercial software providers, consultants and data processors that perform services on our behalf, including, without limitation, companies that provide analysis, messaging services and hosting services, and with respect to the users referred to us by Empathy’s Partners, also periodic reports about their usage of our Services, for purposes of learning and improving our services granted to partners.

  • Vendors: At your request, we may transfer Personal Information to third-party service providers, spanning both private and public organizations, in order to enable them to contact you for the purpose of providing their services. Examples of such services may be assistance with memorial arrangements (including planning a funeral), arranging for house cleaning, handling your loved one’s personal belongings, finding an estate attorney, etc. We do not have any control over, and will not be liable for, the manner in which such service providers will process this information. For any inquiries regarding the privacy practices used by such third parties to process Personal Information, please contact them directly. 

  • In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce these terms, and to defend against any claims or demands asserted against us; (c) to detect, prevent or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of Empathy, its Users or the general public; and (e) when Empathy is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Empathy.

For avoidance of doubt, Empathy may use Non-Personal Information and transfer and disclose it to third parties at its discretion. 

6. Data subjects’ rights

To exercise any rights you may have under applicable privacy laws (such as the right to access, the right to rectification and the right to delete) please contact us by sending an email to [email protected] with sufficient details, and we will respond within a reasonable time frame, but in any event no later than as required by applicable law. We confirm that we do not sell your Personal Information.

Aggregated and/or anonymous information derived from your use of the Services may remain on our servers indefinitely.

7. Location of your data

The information collected from you, as detailed in this Privacy Policy, may, in whole or in part, be transferred, and further transferred, to affiliated entities, any future and/or potential investor or acquirer of Empathy or to other third-party service providers (such as hosting cloud services, as further detailed below), who may be located in countries outside of your jurisdiction, including in a country whose laws do not ensure the same level of protection as that under the privacy protection laws applicable in your jurisdiction. Any transfer of data will be in accordance with the safeguards permitted under applicable privacy laws. 

8. Minors

Our Services are  not intended for children under 18 years of age. No one under age 18 may provide any personal information to us. We do not knowingly collect personal information from children under the age of 18. If you are under 18 years of age, do not use or provide any information to us. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

 9. Security

We take reasonable measures to maintain the security and integrity of your Personal Information and prevent unauthorized access to your Personal Information or use thereof through generally accepted industry-standard technologies and internal procedures. Your Personal Information is hosted on third parties’ servers, which provide advanced strict security standards (both physical and logical). In the event of any breach of the security, confidentiality, or integrity of your Personal Information, we will inform you of this breach as required by applicable law. Please note, however, that there are inherent risks in the transmission of information over the internet or other methods of electronic storage, and we cannot guarantee confidentiality of your Personal Information or that unauthorized access or use of your Personal Information will never occur. Empathy shall not be responsible or liable for unauthorized access, hacking, or other security intrusions or failure to store, or the theft, deletion, corruption, destruction, damage or loss of any data or information. Any transmission of Personal Information is at your own risk. 

10. Third-party service providers

In order to provide our Services, we may use third-party service providers, which may collect, store and/or process the information detailed herein. Such third-party service providers may include without limitation the following categories of service providers:

Please read the third-party service providers’ terms of use and privacy policies to understand their privacy practices. 

11. Cookies

When you access or use the Site and/or the App, we and/or our third-party service providers may use common industrywide technologies such as cookies, web beacons, pixels, clear GIFs and other similar tools (or other similar technologies) (collectively, “Cookies”), which may enable us, among other things, to distinguish your device from those of other Users of the Site and/or the App, to improve the Site’s and the App’s performance, to deliver a better and more personalized service according to our Users’ individual interests and the device or browser they use, to track Users’ use of the Site and/or the App, to gather information about Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and to perform other analytics, and to develop our Site and/or our App.

Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device, and we and/or our authorized third-party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third-party service providers may use both session Cookies (which expire once you close the web browser) and persistent Cookies (which stay on the User’s device until he/she deletes them). 

Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Site and/or the App may be limited. 

For detailed instructions regarding the blocking of Cookies, please refer to your browser’s ‘Help,’ ‘Tools’ or ‘Edit’ options, or see

It is possible to opt out of having your browsing activity within the Site and/or the App recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users’ activity on the Site and/or the App, including through the use of its services’ persistent cookies. Google provides a browser add-on that allows users to opt out of Google Analytics across all websites, which can be downloaded here:

You can opt out of receiving interest-based advertising on your device by visiting the following sites:, and If you wish to opt out of receiving interest-based advertising on your mobile device, please see the advertising preferences information on for iOS devices or for Android devices. 

12. Platform providers

Any processing of Personal Information that will be conducted through in-app purchases will be made by the Platform Provider. Empathy is not affiliated with such Platform Providers; neither is an agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Platform Providers is at the User’s discretion, sole liability and risk. It is the User’s responsibility to abide by all the terms specified by the respective Platform Providers in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Platform Providers.

13. Links to third-party websites

Certain links provided in the Site and App permit Users to leave our Site and App and enter non-Empathy sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Empathy. Empathy is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in such a linked site or service. Empathy reserves the right to terminate any link at any time. You further acknowledge and agree that Empathy shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resources. Most of these linked sites and services provide legal documents, including their own terms of use and privacy policies, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

14. Direct marketing

You hereby agree that we may use the contact details you provided to us (including, without limitation, email address and phone number) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products and services. You may withdraw your consent by sending a written notice the following email address: [email protected]. Alternatively you may follow the instructions for removing yourself from the mailing list, which are available in the messages you receive.

15. Data retention & modification

Your data is yours. In the event that you wish to modify or delete the Personal Information you provided to us via the Services, you can do it independently using the Account settings, or you can send us an email with your request to [email protected] and we will modify or delete your Personal Information pursuant to any applicable privacy laws. Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise, we may retain your Personal Information for as long as reasonably required to fulfill the purposes that the Personal Information was collected for, all as permitted under any applicable privacy laws. Aggregated and/or anonymous information derived from your use of our Services may remain on our servers indefinitely. 

16. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site, the App and any information collected therein and/or provided to us voluntarily. Empathy may, at its sole discretion, change this Privacy Policy from time to time, so please revisit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Site and/or the App, and/or we will send you an email (to the extent that you provided us with your email address) regarding the change. Such material changes will take effect four (4) days after this notice was provided on the Site and/or the App or sent via email, whichever is earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Site and/or the App on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law, and without any prior notice.


The following additional privacy notices for California residents (the “California Notice”) supplement the information contained in the other portions of this Privacy Policy and apply solely to individuals who reside in the State of California (“California consumer” or “you”). We’ve adopted this California Notice to comply with the California Consumer Privacy Act and its related regulations (the “CCPA”) and other applicable California laws.

Overview of Consumer Rights Under the CCPA

Under the CCPA, California consumers have certain rights regarding their Personal Information, including:

  • The right to know the categories of Personal Information that we have collected and the categories of sources from which we obtained such information.

  • The right to know our business purposes for sharing Personal Information.

  • The right to know the categories of third parties with whom we shared Personal Information.

  • The right to access the specific pieces of Personal Information that we have collected and the right to delete your personal information.

  • The right to not be discriminated against if a California consumer exercise their rights under the CCPA.

The provisions below of this California Notice provide further details about these rights and how you may exercise them.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device (collectively, "Personal Information"). Personal information does not include:

  • Publicly available information from government records.

  • De-identified or aggregated California consumer information.

  • Information excluded from the CCPA’s scope, including:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

  • Personal information covered by certain other laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of Personal Information from California consumers within the last twelve (12) months: 




An individual’s name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers

Personal information categories described in Cal. Civ. Code § 1798.80(e)

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Internet or other similar network activity

Browsing history, search history, information on a California consumer's interaction with our website, application, or advertisement and any social media sites from which user information is linked, connected or obtained

Inferences drawn from other personal information

Examples include a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes

Sources of Personal Information

In addition to sources of Personal Information addressed elsewhere in this policy, we obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly From You. For example, from forms you complete or products and services you purchase or from communications with you such as when you contact us (whether in person, by mail, by phone, online, via electronic communication or by other means) including our Helpline. 

  • Indirectly From You. For example, from observing your actions on our Site, the App or from products or services that you have purchased from us, if you have enabled such functionality, such as telemetry services.

  • From Others.

    • From third party service providers. For example, if you choose to make an electronic payment directly to us, or through a linked website or mobile application, or through an affiliate of ours, we may receive Personal Information about you from third parties such as payment services providers, for the purposes of that payment.

    • From affiliates. We may collect Personal Information about you from our affiliates or others acting on their behalf.

  • From Public Sources. For example, we may collect information from public records. 

Uses of Personal Information 

In addition to uses of Personal Information addressed elsewhere in this policy, we may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • To fulfill the reason that you provided the information. For example, if you share your name and contact information to request a price quote, request to be contacted by an affiliate, or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we may use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders or to process returns.

  • To perform services such as customer service, order fulfillment, payment processing, financing and advertising, marketing or analytic services.

  • To advance our commercial or economic interests, such as by helping you to buy, rent, lease, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

  • To verify or maintain quality or safety standards or improve or upgrade a product or service provided or controlled by or for us.

  • To provide, support, personalize and develop our Site, App, products and services such as to perform warranty related services or other post-sale activities such as product or service monitoring or repairs.

  • To create, maintain, customize and secure your Account with us.

  • To process your requests, purchases, transactions and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. 

  • To personalize your Site and App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site or App, third-party sites and via mail, email or text message (with your consent, where required by law).

  • To help maintain the safety, security and integrity of our Site, our App, products and services, databases and other assets and business.

  • For testing, research and analysis purposes, including to develop and improve our Site, App, and products and services.

  • To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.

  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA or applicable law.

  • To send you information relevant to your past purchases and interests, subject to compliance with applicable laws regarding direct marketing.

  • To otherwise use as reasonably necessary and proportionate to achieve our operational or notified purpose for collecting Personal Information and as compatible with the context in which we collected the information.

  • To perform services on behalf of a CCPA-covered business or its service provider, such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services.

  • To review and audit our business interactions with you. 

  • To detect or prevent security incidents or other illegal activity.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site, the App, users, including California consumers, is among the assets transferred.

 We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice. 

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business 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. 

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: 

  • Identifiers

  • Personal Information categories described in Cal. Civ. Code § 1798.80(e)

  • Commercial information

  • Internet or other similar network activity

  • Inferences drawn from other Personal Information

The categories of third parties to which we may disclose Personal Information collected by us include the following: 

  • Service providers

  • Affiliates and subsidiaries 

  • Vendors and other third parties that assist us in providing our Services

  • Our employees

  • Recipients of data from cookies 

Sales of Personal Information

We do not sell Personal Information to third parties.  

Exercising Your CCPA Rights and Choices

The sections below describe how you may exercise your rights under the CCPA. 

Access to Specific Information and Data Portability Rights. 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 twelve (12) months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights” below), we will disclose to you:

  • The categories of Personal Information we collected about you.

  • The categories of sources for the Personal Information we collected about you.

  • Our business or commercial purpose for collecting that Personal Information.

  • The categories of third parties with whom we share that Personal Information.

  • The specific pieces of Personal Information we collected about you (also called a data portability request).

  • If we disclosed your Personal Information for a business purpose, a list disclosing:

  • The Personal Information categories that each category of recipient obtained.

 As allowed by the CCPA, we do not provide these access and data portability rights (i) for business-to-business Personal Information or (ii), if applicable, as to Personal Information collected from any of our  California-based employees, job applicants or contractors, if any, when provided or collected in such employee, job applicant or contractor capacities.

Deletion Request Rights. 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 (see “Exercising Access, Data Portability and Deletion Rights” below), we will delete (and direct our service providers to delete) your Personal Information from our (and service provider) records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products or services to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another California consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with California consumer expectations based on your relationship with us, such as future field campaigns or product safety issues.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 As allowed by the CCPA, we do not provide these deletion rights (i) for business-to-business Personal Information or (ii) if applicable, as to Personal Information collected from any of our California-based employees, job applicants or contractors, if any, when provided or collected in such employee, job applicant or contractor capacities. 

Exercising Access, Data Portability and Deletion Rights. To exercise the access, data portability and deletion rights described above, you should submit a verifiable consumer request to us by one of the following methods:

  • Emailing us at [email protected]

  • By postal mail at: 163 W 23rd Street, New York, NY 10011

  • Accessing your online account that you maintain with us.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of a minor child for whom you are a parent or legal guardian. 

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative, which may include:

  • Your name

  • Your address

  • Additional information depending upon the type of request and the sensitivity of the information involved with such request

  • Describe your request with sufficient detail to enable us to properly understand, evaluate and respond to such request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm that the Personal Information involved with the request relates to you. 

Making a verifiable consumer request does not require you to create an account with us. However, we will consider requests made through a password-protected online account that you maintain with us to be sufficiently verified when the request relates to Personal Information associated with that online account, provided such online account functionality is then made available by us on the Website. 

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an online account with us, we may deliver our written response to that online account, provided that such online account functionality is then made available by us on the Website. If you do not have an online account with us, or such functionality is not available for your online account we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the twelve (12) month period immediately preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA or other applicable law, we will not as a result of you exercising any of your rights under the CCPA:

  • Deny you goods or services;

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

  • Provide you a different level or quality of goods or services; or

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. 

Other California Privacy-Related Disclosures

Sharing Personal Information for Direct Marketing Purposes. Before sharing Personal Information of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out.

California Do-Not-Track Disclosure. At this time, the Website is not set up to honor web browser do-not-track settings.  Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit

Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared 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 at: [email protected]

Content Removal Requests for Website Users Under 18 Years Old. While our Site, App and Services are  not intended for use by persons who are under 18 years old, if you are a user under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on the Site or App. You may send us any such requests by one of the following methods: (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at [email protected]; or (ii) by writing to us at 163 W 23rd Street, New York, NY 10011.  We will review the request and respond promptly.  You should be aware that a request to remove content or information posted by you on the Website does not ensure or require complete or comprehensive removal of such content or information from our databases. 


If you have any complaint about use of the Site or App, you may contact us by email at [email protected], or by postal mail at 163 W 23rd Street, New York, NY 10011. In accordance with California Civil Code Section 1789.3, California residents may also file complaints with the Complaint Assistance Unit, Division of Consumer Services, California Department of Consumer Affairs by postal mail at 1625 North Market Boulevard, Suite N112, Sacramento, CA 95834 or by telephone at 800-952-5210.

18. Got any questions?

If you have any questions (or comments) concerning this Privacy Policy, please send us an email at the following address: [email protected]