Frump Fighters Interactive™ App Privacy Policy

App Privacy Policy

The following privacy policy (“Privacy Policy”) sets forth Holden Media, LLC d/b/a Frump Fighters’ (“Company” “we” or “us”) policy with respect to information, including personally identifiable and non-personally identifiable data (“Personal Data”) and other information, Company collects from visitors to the Company application, Frump Fighters Interactive™ (the “App”) and all components thereof (collectively the “Company Properties”).

This Privacy Policy supplements and forms a part of Company’s Terms of Use at https://nowthaticando.com/app-terms-conditions. Capitalized terms not defined here have the meaning given to them in the Company Terms of Use.

When you use any part of the Company Properties, you are consenting to the collection, transfer, storage, disclosure, and other uses of your information as described in this Privacy Policy.

This Privacy Policy does not apply to the practices of third parties that Company does not own or control, including third-party websites, services, and applications that you elect to access in connection with the

Company Properties, or to individuals that Company does not manage or employ. While we attempt to facilitate access only to those third-party services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those third-party services. We encourage you to carefully review the privacy policies of any third-party services that you access.

The Company is located in the United States and may offers services to individuals in other countries. The Company has reviewed each country’s relevant privacy rules and regulations and has detailed below its efforts to comply with relevant laws.

To reach the Company’s data protection and chief privacy officer, please email hello@frumpfighters.com.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

Information We Collect

When you interact with us through the Company Properties, we may collect Personal Data and other information from you, as further described below.

Personal Data That You Provide: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Company Properties or use the Company Properties.

When signing up, you will be asked to provide us with certain personal information, such as your first name, last name, and email address. In this Privacy Policy, we refer to this information as “Personal Information” or “Personal Data.” Users under the age of eighteen (18) should not sign up a Frump Fighters Interactive™ Account.

If we learn we have collected Personal Information from a user under the age of 18 without parental consent, or if we learn a user under the age of 18 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a user under the age of 18 may have provided us Personal Information in violation of this Privacy Policy, please contact us at hello@frumpfighters.com.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred and stored from your current location to the offices and servers of Company and the authorized third parties referenced below.

To sign up for the Company Properties you will provide some or all of the following information:

– First and Last Name

– Mailing Address

– E-mail Address

If you purchase any Company products and services, we collect billing and credit card information. This information is used to complete the purchase transaction.

Upon creation of Frump Fighters Interactive™ Account, you will be able to use the Company Properties.

In addition, you may be asked to create a password to access your account on the Company Properties. It is your responsibility to keep your password secure and not share it with anyone.

Other Information We Collect

From Your Activity: We may collect or receive information regarding: (1) IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer; (2) browser type and language; (3) referring and exit pages and URLs; (4) date and time; and (5) details regarding your activity on the App, such as search queries and other performance and usage data.

Non-Identifiable Data: When you interact with the Company Properties, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Company may store such information itself or such information may be included in databases owned and maintained by Company affiliates, agents, or service providers. The Company Properties may use such information and pool it with other information. It is important to note that no Personal Data is available or used in this process.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Company Properties, Company may conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Company may share this aggregate data with its affiliates, agents, and business partners. This aggregate information does not identify you personally. Company may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Device Identifiers: The Company Properties, through its third-party providers, may collect device-specific information when you access the Company Properties. Device information may include unique device identifier, media access control address, network information, and hardware model, as well as non-personally identifiable usage and traffic data and information about how the device interacts with the Company Properties. This type of data enables Company and third parties authorized by Company to figure out how often individuals use parts of the Company Properties and learn more about our users’ demographics and Internet behaviors, so that we can analyze, operate, and improve our products and services.

Cookies Policy

We use, and allow certain other companies to use, Cookies on the Company Properties to analyze our traffic, and to recognize your device. We also share information about your use of the Company Properties with our social media and analytics partners. This section explains what cookies are, how we use Cookies and similar technologies on the Company Properties and what you can do to manage how Cookies are used.

WHAT ARE COOKIES?

A cookie is a small text file which is sent to your computer (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Company Properties. The Cookie will collect information relating to your use of the Company Properties, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Company Properties via a link from third party site, the URL of the linking page.

In addition to Cookies, the Company Properties may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Company Properties and to recognize users by accessing our cookies. We may employ web beacons to facilitate administration and navigation of the Company Properties, to track the actions of users of the Company Properties, to compile aggregate statistics about usage and response rates on the Company Properties, and to provide an enhanced online experience for visitors to the Company Properties. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF, and tracker GIF.

WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO WE USE THEM?

Essential – These are Cookies which are essential for the running of the Company Properties. Without these Cookies, parts of the Company Properties would not function. These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how we may use essential Cookies include:

Setting unique identifiers for each unique visitor, so that website numbers can be analyzed.

Functional – These Cookies are used to remember your preferences on the Company Properties and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally. Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.

Examples of how we may use functional Cookies include:

Gathering data about visits to the Company Properties, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from.
Eliminating the need for returning users to re-enter their login details.

Analytical Performance – Analytical performance Cookies are used to monitor the performance of the Company Properties, for example, to determine the number of page views and the number of unique users on the Company Properties. We use this information to improve user experience or identify areas of the Company Properties which may require maintenance. The information is anonymous (i.e., it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.

Examples of how we may use analytical Cookies include:

Measuring users’ behavior
Analyze which pages are viewed and how long for and which links are followed to better develop the Company Properties

Third Party Cookies – You may notice on some pages of the Company Properties that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third-party service providers may set their own Cookies on your device. We do not control the use of these third-party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third-party websites for more information about these Cookies.

HOW CAN YOU MANAGE OR OPT OUT OF COOKIES?

Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Company Properties. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.

We may use both session cookies, which expire once you close the App, and persistent cookies, which stay on your device until you delete them and other technologies to help us collect data and to enhance your experience with the App. We may use cookies for various purposes, including to: (1) type of device; (2) personalize your experience; (3) analyze which portions of the App are visited and used most frequently; and (4) measure and optimize advertising and promotional effectiveness.

If you do not want us to deploy cookies in the App, you can opt out by setting your device/web browser to reject cookies. You can still use the App if you choose to disable cookies, although your ability to use some of the features may be affected.

Opting out of Analytical Performance Cookies

If you would like to opt out of Analytics Cookies, please do so by clicking on the links below:

Google Analytics: https://tools.google.com/dlpage/gaoptout

FURTHER INFORMATION AND CONTACT DETAILS

If you have any questions about or if you would like more information on the Cookies that we use and their purposes, please contact us at the email address set forth below.

Our Use of Your Personal Data and Other Information

The Company Properties may use the information collected in the following ways:

To operate and maintain the Company Properties;
To register your Frump Fighters Interactive™ Account;
To authenticate you when you log into your Frump Fighters Interactive™ Account;
To provide you with requested services;
To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
To respond to your comments or inquiries;
To provide you with user support; or,
To protect, investigate, and deter against unauthorized or illegal activity.

Company may also share your Personal Data with our users, with your consent, in order to provide the services on the Company Properties. Please be careful with the information you provide and confirm it can be shared with other users before providing the information. We cannot control how other users will use the Personal Data you provide.

Company uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Company Properties, we will use your Personal Data to provide you with access to such Company Properties and to monitor your use of the same. Company and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Company Properties to help us improve the content and functionality of the Company Properties, to better understand our users and to improve the Company Properties. Company and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as at hello@frumpfighters.com.

You acknowledge that this information may be personal to you, and by creating an account and providing such information, you allow others, including Company, to identify you and therefore you may not be anonymous. Company Properties user profiles are available for view by Company and other Company Properties’ users, and other users can contact or follow you through the Company Properties. Content that you post on, through, or in connection with the Company Properties, including on third party services, such as your social media accounts, may also be public.

If Company intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including delivering content, tracking, and enhancing our users experience on the Company Properties. The information collected are used only to support the internal operations of the Company Properties.

How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us, or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; and
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

ADVERTISING

Retargeting Ads

From time to time, the App may engage in remarketing efforts with third-party companies, such as Google, Facebook, or Instagram, in order to market the App. These companies use cookies to serve ads based on someone’s past visits to the App. This means, after visiting the App, you may see an ad for our services. However, your personally identifiable information is not used by any remarketing service other than to present you offers from Company. We use the following third-party service providers for remarketing:

Facebook: Opt-out of Facebook remarketing here
Google: Opt-out of Google remarketing here

Pinterest: Opt-out of Pinterest remarketing here

Instagram: Opt-out of Instagram remarketing here

Newsletters

On the App, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, Company may see if and when you open an email and which links within the email you click. Also, this allows Company to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.

LEGAL BASIS FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

We are responsible as a “controller” of your Personal Data under the GDPR and below are the types of lawful basis that we will rely on to collect and process your Personal Data:

Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at hello@frumpfighters.com.
Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligationmeans processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
Consentmeans where you have consented to a certain use of your Personal Data.
Vital Interest means processing your Personal Data to protect the vital interests of the data subject or another natural persons.

THIRD-PARTY USE OF PERSONAL INFORMATION

Company will not sell, distribute, or reveal users’ personal information, except when required by law, without their consent. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Third Party Vendors: We may share your information with third party vendors or service providers who help us provide our products or services or the App, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.

Parent Companies and Affiliates: We may share your information with a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), provided that we require our Affiliates to honor this Privacy Policy.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Related Companies: We may also share your Personal Data with our related companies for purposes consistent with this Privacy Policy.

Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.

Agents, Consultants, and Related Third Parties: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the App or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our customer contracts.

The App may share your information with third parties when you explicitly authorize us to share your information. Additionally, the App may use third-party service providers to service various aspects of the App. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The App currently uses the following third-party service providers:

Deadline Funnel – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.
Google Analytics – this service tracks the App usage and provides information such as referring websites and user actions on the App. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
Pinterest Tag– this service tracks the App usage and provides information such as user actions on the App. Pinterest Tag may capture your IP address, but no other personal information is captured by Pinterest Tag.
Fomo– this service is used to serve our ecommerce platform. Fomo tracks and displays customer reviews, orders, and social media posts.
Chatra– this service allows the Company to chat with App visitors. Chatra may capture your IP address, name, and email address.
Convertbox– this service is used to capture App visitors email address and provide notification pop-up on the App.
Google Pay – this service is used to serve our ecommerce platform. At no time is your banking information passed to the App. We receive only information used for order fulfillment.
Amazon Pay – this service is used to serve our ecommerce platform. At no time is your banking information passed to the App. We receive only information used for order fulfillment
Stripe – this service is used to serve our ecommerce platform. At no time is your banking information passed to the App. We receive only information used for order fulfillment
Paypal– this service is used to serve our ecommerce platform. At no time is your banking information passed to the App. We receive only information used for order fulfillment
Thrivecart– this service is used to serve our ecommerce platform. At no time is your banking information passed to the App. We receive only information used for order fulfillment ConvertKit – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.
Facebook Pixel– this service tracks App usage and provides information such as referring websites and user actions on the App. Facebook Pixel may capture your IP address, but no other personal information is captured by Facebook Pixel.

At this time, your personal information is not shared with any other third-party service providers. This list may be amended from time to time in the Company’s sole discretion.

How We Protect Your Personal Information: We strive to take appropriate security measures (including physical, electronic, and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to personal information. Your account is also protected by a password for your privacy and security, and you must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately, limiting access to your devices, and by signing off after you have finished accessing your account.

We take commercially reasonable steps to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

RIGHTS RELATED TO YOUR PERSONAL INFORMATION

Under laws in certain countries in which we operate, customers and other visitors to our App from those countries have a right to access Personal Data about themselves, and to amend, correct or delete Personal Data that is inaccurate, incomplete, or outdated. We will, upon request, provide you with confirmation regarding whether we are processing Personal Data about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Data that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise inconsistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Data that you request.

Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

Opt-out – If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications. You may also notify us at hello@frumpfighters.com to be removed from our mailing list.

Access – You may request access to the personal information we have about you by submitting a request to hello@frumpfighters.com.

Amend – You may contact us at hello@frumpfighters.com to amend or update your personal information.

Forget – In certain situations, you may request that we erase or forget your Personal Data. To do so, please submit a request to hello@frumpfighters.com.

Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.

How to File a GDPR Complaint.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

CALIFORNIA RESIDENTS

California Residents: Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have certain rights with respect to your personal information. For the purposes of this section, personal information is used as defined in the CCPA. Company reserves the right to verify all requests made pursuant to the CCPA.

Access and Disclosure

You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed. You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request. We have not sold any of your Personal Data in the past twelve (12) months.

Please note that we are not required to:

Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.

Deletion Request Rights

You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the personal 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, 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 to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another 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 consumer expectations based on your relationship with us.
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.

No Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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.

Exercising Your Rights

To exercise the access, disclosure and deletion rights described above, please submit a verifiable request to us by emailing hello@frumpfighters.com, Attn: CCPA.

You may only make a verifiable request for access or disclosure twice within a twelve (12) month period. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To respond to your request or provide you with personal information, Company must verify your identity or your authority to make the request. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by e-mailing us at hello@frumpfighters.com. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Timing

We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. 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 preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Other Terms and Conditions

Your access to and use of the Company Properties is subject to the Terms of Use at https://nowthaticando.com/app-terms-conditions. Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, the Company Properties, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

Storage And Transfer Outside of the Country Where You Access The Company Properties.

The Company Properties are located in the United States. If you access the Company Properties outside of the United States, please note that your Personal Data may be transferred and stored in the United States. Nonetheless, the Company endeavors to comply with the data protection laws where the Company Properties are available for use.

Your Personal Data may also be used or stored by us or our third-party providers outside of the country where you reside or access the Company Properties if you consent to such transfer. Should you choose to share the Your Personal Data with other Users, we shall transfer that data based on your consent. We require that our service providers safeguard your personal information. Should your Personal Data be used or stored outside of the country where you access the Company Properties, it will also be subject to the laws of the country in which it is used or stored.

E-mail Communications

From time to time, the Company may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our services, we may receive a notification when you open an email from the Company or click on a link therein.

If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email.

If you would like to stop receiving marketing or promotional communications via email from the Company, you may opt out of such communications by clicking the “unsubscribe” link at the bottom of email communications or by contacting hello@frumpfighters.com to request to opt out, however, we reserve the right to send you transactional emails such as customer service communications.

EXTERNAL DATA STORAGE

We may store your data on servers provided by third party hosting vendors with whom we have contracted. The policies and procedures described here do not apply to websites not controlled by Company (the Third-Party Sites”) The links from the Company Properties do not imply that Company endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

ARBITRATION

This Privacy Policy will be governed and construed in accordance with the laws of the State of Washington. Any controversy or claim arising out of or relating to the Privacy Policy, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association (“AAA”) under its Commercial Arbitration Rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The place of any such arbitration shall be in or near Whatcom County, Washington. The parties also agree that the AAA Optional Rules for Emergency Measures of Protection shall apply to the proceedings.

No Class Actions: We all agree that we can only bring a claim against each other on an individual basis. That means: (a) neither you nor Company can bring a claim as a plaintiff or class member in a class action, consolidated action or representative action; (b) an arbitrator cannot combine more than one person’s claim into a single case, and cannot preside over any consolidated, class or representative arbitration proceeding (unless we both agree to change this); (c) an arbitrator’s decision or award in one person’s case can only impact the person who brought the claim, not other users, and cannot be used to decide other disputes with other users.

Changes to this Statement

The Company reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a notice on the Company Properties and/or by updating any privacy information. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated below. Your continued use of the Company Properties available after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Privacy Policy.

Contact Information

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Company Properties. The Company welcomes your questions or comments regarding this Privacy Policy. If you believe that the Company has not adhered to this Privacy Policy please contact Company at:

Email Address: hello@frumpfighters.com

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Last Updated: December 3, 2022