PRIVACY POLICY
Last updated Sep 03, 2024
This privacy notice for Solve.Care Foundation OÜ (doing business as Solve.Care) ("we," "us," or "our"), describes how and why we might
collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
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Download and use our mobile application (Tuumio Wallet), or any other application of ours that links to this privacy notice.
Engage with us in other related ways, including any sales, marketing, or events.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our
policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following
each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending
on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal
information you disclose to us.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as
otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your
consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with
specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal
information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights
regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us.
We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining
information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and
the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
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phone numbers
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories
of sensitive information:
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health data
financial data
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number,
and the security code associated with your payment instrument. All payment data is stored by Stripe and Binance Pay. You may find their
privacy notice link(s) here:
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or
permission:
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Geolocation Information. We may request access or permission to track location-based information from your mobile device, either
continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our
access or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile
device's bluetooth, calendar, camera, sensors, microphone, contacts, storage, sms messages, social media accounts, reminders, and
other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer),
operating system, version information and system configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or
proxy server). If you are using our application(s), we may also collect information about the phone network associated with your
mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique
device ID, and information about the features of our application(s) you accessed.
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Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s).
If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal
analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such
personal information.
Information automatically collected
In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when
you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific
identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.
The information we collect includes:
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Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers
automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with
us, this log data may include your IP address, device information, browser type, and settings and information about your activity in
the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you
take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash
dumps"), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention,
and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
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To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you
can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested
service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any
potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services,
changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and
exchanges made through the Services.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for
communication with another user.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including
fraud monitoring and prevention.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an
individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under
applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect
your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your
personal information. As such, we may rely on the following legal bases to process your personal information:
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Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a
specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
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Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual
obligations to you, including providing our Services or at your request prior to entering into a contract with you.
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Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate
business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may
process your personal information for some of the purposes described in order to:
Diagnose problems and/or prevent fraudulent activities
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Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations,
such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital
interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a
specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including,
for example:
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If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the
information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention
of the laws of Canada or a province
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If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of
records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent
with the purposes for which the information was produced
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If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
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Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of
company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer
retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require
us keeping your personal information for longer than thirty six (36) months past the termination of the user's account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such
information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any
personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over
the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify
your information. Although we will do our best to protect your personal information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least
18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that
personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures
to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please
contact us at [email protected].
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you
greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may
include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict
the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In
certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request
by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied
consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any
time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below
or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it
affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
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Log in to your account settings and update your user account.
Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.
However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our
legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at [email protected].
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can
activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no
uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to
DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted specific rights regarding access to your personal
information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category
A. Identifiers
Examples
Collected
Contact details, such as real name, alias, postal address, telephone or
mobile contact number, unique personal identifier, online identifier, Internet
Protocol address, email address, and account name
NO
B. Personal Information as defined in
the California Customer Records
statute
Name, contact information, education, employment, employment history,
and financial information
YES
NO
NO
C. Protected classification
characteristics under state or
federal law
Gender and date of birth
D. Commercial information
Transaction information, purchase history, financial details, and payment
information
E. Biometric information
Fingerprints and voiceprints
NO
NO
F. Internet or other similar network
activity
Browsing history, search history, online behavior, interest data, and
interactions with our and other websites, applications, systems, and
advertisements
G. Geolocation data
Device location
YES
YES
H. Audio, electronic, visual, thermal,
olfactory, or similar information
Images and audio, video or call recordings created in connection with our
business activities
I.
Professional or employment-related
information
Business contact details in order to provide you our Services at a business
level or job title, work history, and professional qualifications if you apply
for a job with us
NO
J. Education information
Student records and directory information
NO
NO
K. Inferences drawn from collected
personal information
Inferences drawn from any of the collected personal information listed
above to create a profile or summary about, for example, an individual’s
preferences and characteristics
L. Sensitive personal Information
Biometric data and account login information
YES
We will use and retain the collected personal information as needed to provide the Services or for:
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Category B - As long as the user has an account with us
Category G - For the duration of the service transaction only. This data is not stored.
Category H - For the duration of the service transaction only. This data is not stored.
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Category L - For the duration of the session only. This data is not stored.
Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right
to limit the use or disclosure of your sensitive personal information.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online,
or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR
INFORMATION?" Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider.
Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological
development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding
twelve (12) months.
We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and
obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third parties with which we shared personal 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
using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal
of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information
provided below and include the email address associated with your account and a statement that you reside in California. We will make sure
the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed
from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request
and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another
consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
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whether we collect and use your personal information;
the categories of personal information that we collect
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;the categories of personal information that we sold, shared, or
disclosed for a business purpose;
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the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a
consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s
Privacy Rights
We will not discriminate against you if you exercise your privacy
rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
If the business collects any of the following:
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social security information, drivers' licenses, state ID cards, passport numbers
account login information
credit card numbers, financial account information, or credentials allowing access to such accounts
precise geolocation
racial or ethnic origin, religious or philosophical beliefs, union membership
the contents of email and text, unless the business is the intended recipient of the communication
genetic data, biometric data, and health data
data concerning sexual orientation and sex life
you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the
Services.
Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other
purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.
Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a
consumer is not covered by this right, as well as the publicly available information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the
information in our system. These verification efforts require us to ask you to provide information so that we can match it with information
you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information
so that we can match the information you provide with the information we already have on file, or we may contact you through a
communication method (e.g., phone or email) that you have previously provided to us.
We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent
possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide additional information for the purposes of
verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we
finish verifying you.
Other privacy rights
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You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the
information.
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You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an
authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the
CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out
request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request
submission.
To exercise these rights, you can contact us by submitting a data subject access request, by email at [email protected], or by referring
to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from
you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these
rights are not absolute, and in certain cases, we may decline your request as permitted by law.
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Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling
in furtherance of decisions that produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please email [email protected] or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within
forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal,
including a written explanation of the reasons for the decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below.
However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
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Right to be informed whether or not we are processing your personal data
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Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling
in furtherance of decisions that produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please email [email protected] or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within
sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions.
Utah Residents
This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these
rights are not absolute, and in certain cases, we may decline your request as permitted by law.
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Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data
To submit a request to exercise these rights described above, please email [email protected] or submit a data subject access
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not
include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data"
does not include deidentified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data:
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Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling
in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Exercise your rights provided under the Virginia VCDPA
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they
have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the
request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response
period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension
within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our
decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action
taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New
Zealand's Privacy Act2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from
you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our
services, in particular:
offer you the products or services that you want
respond to or help with your requests
manage your account with us
confirm your identity and protect your account
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting
us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?"
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the
Australian Privacy
Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New
Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting
us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?"
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can
contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries: [email protected]
Complaints (complete POPIA/PAIA form 5): [email protected] & [email protected]
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated
version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:
Solve.Care Foundation OÜ
Narva mnt 5, Kesklinna linnaosa
Tallinn, Harju 10117
Estonia
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to
review, update, or delete your personal information, please fill out and submit a data subject access request.
Harju maakond, Tallinn,
Kesklinna linnaosa,
Narva mnt 5, 10117
