4. Your rights and choices
4.1. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
4.2. 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" section), we will disclose to you:
(i) The categories of personal information we collected about you.
(ii) The categories of sources for the personal information we collected about you.
(iii) our business or commercial purpose for collecting and selling that personal information.
(iv) The categories of third parties with whom we share that personal information.
(v) The specific pieces of personal information we collected about you (also called a data portability request).
(vi) If we disclosed your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
4.3. 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" section), we will delete (and direct our service providers to delete) your personal information from our 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
(i) 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.
(ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
(iii) Debug products to identify and repair errors that impair existing intended functionality.
(iv) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
(v) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
(vi) 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.
(vii) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
(viii) Comply with a legal obligation.
(ix) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
4.4. Exercising Access, Data Portability, and Deletion Rights
4.4.1. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:
Fanariou 10, apt. 102, Limassol, Cyprus, 3106.
4.4.2. 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 your minor child.
4.4.3. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
(i) Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person; and
(ii) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
4.4.4. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
4.4.5. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
4.5. Response Timing and Format
4.5.1 We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
4.5.2. Any disclosures we provide will only cover the 12-month period 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.
4.5.3. 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.
4.6. Personal Information Sales Opt-Out and Opt-In Rights
4.6.1. If you are a California resident and 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt out of future sales at any time.
4.6.2. To exercise the right to opt out, you (or your authorized representative) shall submit a variable notice to [email protected]
4.6.3. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.