5.
DO
WE
USE
COOKIES
AND
OTHER
TRACKING
TECHNOLOGIES?
In
Short: We
may
use
cookies
and
other
tracking
technologies
to
collect
and
store
your
information.
We
may
use
cookies
and
similar
tracking
technologies
(like
web
beacons
and
pixels)
to
gather
information
when
you
interact
with
our
Services.
Some
online
tracking
technologies
help
us
maintain
the
security
of
our
Services
and
your
account
,
prevent
crashes,
fix
bugs,
save
your
preferences,
and
assist
with
basic
site
functions.
We
also
permit
third
parties
and
service
providers
to
use
online
tracking
technologies
on
our
Services
for
analytics
and
advertising,
including
to
help
manage
and
display
advertisements,
to
tailor
advertisements
to
your
interests,
or
to
send
abandoned
shopping
cart
reminders
(depending
on
your
communication
preferences).
The
third
parties
and
service
providers
use
their
technology
to
provide
advertising
about
products
and
services
tailored
to
your
interests
which
may
appear
either
on
our
Services
or
on
other
websites.
To
the
extent
these
online
tracking
technologies
are
deemed
to
be
a
"sale"/"sharing"
(which
includes
targeted
advertising,
as
defined
under
the
applicable
laws)
under
applicable
US
state
laws,
you
can
opt
out
of
these
online
tracking
technologies
by
submitting
a
request
as
described
below
under
section
"
DO
UNITED
STATES
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
"
Specific
information
about
how
we
use
such
technologies
and
how
you
can
refuse
certain
cookies
is
set
out
in
our
Cookie
Notice
.
Google
Analytics
6.
HOW
DO
WE
HANDLE
YOUR
SOCIAL
LOGINS?
In
Short: If
you
choose
to
register
or
log
in
to
our
Services
using
a
social
media
account,
we
may
have
access
to
certain
information
about
you.
Our
Services
offer
you
the
ability
to
register
and
log
in
using
your
third-party
social
media
account
details
(like
your
Facebook
or
X
logins).
Where
you
choose
to
do
this,
we
will
receive
certain
profile
information
about
you
from
your
social
media
provider.
The
profile
information
we
receive
may
vary
depending
on
the
social
media
provider
concerned,
but
will
often
include
your
name,
email
address,
friends
list,
and
profile
picture,
as
well
as
other
information
you
choose
to
make
public
on
such
a
social
media
platform.
We
will
use
the
information
we
receive
only
for
the
purposes
that
are
described
in
this
privacy
notice
or
that
are
otherwise
made
clear
to
you
on
the
relevant
Services.
Please
note
that
we
do
not
control,
and
are
not
responsible
for,
other
uses
of
your
personal
information
by
your
third-party
social
media
provider.
We
recommend
that
you
review
their
privacy
notice
to
understand
how
they
collect,
use,
and
share
your
personal
information,
and
how
you
can
set
your
privacy
preferences
on
their
sites
and
apps.
7.
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
twelve
(12)
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.
8.
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.
9.
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
collect,
solicit
data
from,
or
market
to
children
under
18
years
of
age,
nor
do
we
knowingly
sell
such
personal
information.
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
info@memcap.com
.
10.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
In
Short:
Depending
on
your
state
of
residence
in
the
US
or
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,
depending
on
your
country,
province,
or
state
of
residence.
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.
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
.
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.
Opting
out
of
marketing
and
promotional
communications: You
can
unsubscribe
from
our
marketing
and
promotional
communications
at
any
time
by
clicking
on
the
unsubscribe
link
in
the
emails
that
we
send,
replying
"STOP"
or
"UNSUBSCRIBE"
to
the
SMS
messages
that
we
send,
or
by
contacting
us
using
the
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below.
You
will
then
be
removed
from
the
marketing
lists.
However,
we
may
still
communicate
with
you
—
for
example,
to
send
you
service-related
messages
that
are
necessary
for
the
administration
and
use
of
your
account,
to
respond
to
service
requests,
or
for
other
non-marketing
purposes.
Account
Information
If
you
would
at
any
time
like
to
review
or
change
the
information
in
your
account
or
terminate
your
account,
you
can:
-
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.
Cookies
and
similar
technologies:
Most
Web
browsers
are
set
to
accept
cookies
by
default.
If
you
prefer,
you
can
usually
choose
to
set
your
browser
to
remove
cookies
and
to
reject
cookies.
If
you
choose
to
remove
cookies
or
reject
cookies,
this
could
affect
certain
features
or
services
of
our
Services.
If
you
have
questions
or
comments
about
your
privacy
rights,
you
may
email
us
at
info@memcap.com
.
11.
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.
California
law
requires
us
to
let
you
know
how
we
respond
to
web
browser
DNT
signals.
Because
there
currently
is
not
an
industry
or
legal
standard
for
recognizing
or
honoring
DNT
signals,
we
do
not
respond
to
them
at
this
time.
12.
DO
UNITED
STATES
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short: If
you
are
a
resident
of
California,
Colorado,
Connecticut,
Delaware,
Florida,
Indiana,
Iowa,
Kentucky,
Montana,
New
Hampshire,
New
Jersey,
Oregon,
Tennessee,
Texas,
Utah,
or
Virginia
,
you
may
have
the
right
to
request
access
to
and
receive
details
about
the
personal
information
we
maintain
about
you
and
how
we
have
processed
it,
correct
inaccuracies,
get
a
copy
of,
or
delete
your
personal
information.
You
may
also
have
the
right
to
withdraw
your
consent
to
our
processing
of
your
personal
information.
These
rights
may
be
limited
in
some
circumstances
by
applicable
law.
More
information
is
provided
below.
Categories
of
Personal
Information
We
Collect
We
have
collected
the
following
categories
of
personal
information
in
the
past
twelve
(12)
months:
|
Category
|
Examples
|
Collected
|
|
A.
Identifiers
|
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
|
NO
|
|
C
.
Protected
classification
characteristics
under
state
or
federal
law
|
Gender,
age,
date
of
birth,
race
and
ethnicity,
national
origin,
marital
status,
and
other
demographic
data
|
NO
|
|
D
.
Commercial
information
|
Transaction
information,
purchase
history,
financial
details,
and
payment
information
|
NO
|
|
E
.
Biometric
information
|
Fingerprints
and
voiceprints
|
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
|
NO
|
|
G
.
Geolocation
data
|
Device
location
|
NO
|
|
H
.
Audio,
electronic,
sensory,
or
similar
information
|
Images
and
audio,
video
or
call
recordings
created
in
connection
with
our
business
activities
|
NO
|
|
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
|
|
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
|
NO
|
|
L
.
Sensitive
personal
Information
|
|
NO
|
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.
Sources
of
Personal
Information
How
We
Use
and
Share
Personal
Information
Will
your
information
be
shared
with
anyone
else?
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.
Your
Rights
You
have
rights
under
certain
US
state
data
protection
laws.
However,
these
rights
are
not
absolute,
and
in
certain
cases,
we
may
decline
your
request
as
permitted
by
law.
These
rights
include:
-
Right
to
know
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
the
deletion
of
your
personal
data
-
Right
to
obtain
a
copy of
the
personal
data
you
previously
shared
with
us
-
Right
to
non-discrimination
for
exercising
your
rights
-
Right
to
opt
out
of
the
processing
of
your
personal
data
if
it
is
used
for
targeted
advertising
(or
sharing
as
defined
under
California’s
privacy
law)
,
the
sale
of
personal
data,
or
profiling
in
furtherance
of
decisions
that
produce
legal
or
similarly
significant
effects
(
"profiling"
)
Depending
upon
the
state
where
you
live,
you
may
also
have
the
following
rights:
-
Right
to
obtain
a
list
of
the
categories
of
third
parties
to
which
we
have
disclosed
personal
data
(as
permitted
by
applicable
law,
including
California's
and
Delaware's
privacy
law)
-
Right
to
obtain
a
list
of
specific
third
parties
to
which
we
have
disclosed
personal
data
(as
permitted
by
applicable
law,
including
Oregon’s
privacy
law)
-
Right
to
limit
use
and
disclosure
of
sensitive
personal
data
(as
permitted
by
applicable
law,
including
California’s
privacy
law)
-
Right
to
opt
out
of
the
collection
of
sensitive
data
and
personal
data
collected
through
the
operation
of
a
voice
or
facial
recognition
feature
(as
permitted
by
applicable
law,
including
Florida’s
privacy
law)
How
to
Exercise
Your
Rights
Under
certain
US
state
data
protection
laws,
you
can
designate
an
authorized
agent
to
make
a
request
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
applicable
laws.
Request
Verification
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.
We
will
only
use
personal
information
provided
in
your
request
to
verify
your
identity
or
authority
to
make
the
request.
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.
If
you
submit
the
request
through
an
authorized
agent,
we
may
need
to
collect
additional
information
to
verify
your
identity
before
processing
your
request
and
the
agent
will
need
to
provide
a
written
and
signed
permission
from
you
to
submit
such
request
on
your
behalf.
Appeals
Under
certain
US
state
data
protection
laws,
if
we
decline
to
take
action
regarding
your
request,
you
may
appeal
our
decision
by
emailing
us
at
info@memcap.com
.
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
may
submit
a
complaint
to
your
state
attorney
general.
California
"Shine
The
Light"
Law
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
by
using
the
contact
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
13.
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
at
the
top
of
this
privacy
notice.
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.
14.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you
have
questions
or
comments
about
this
notice,
you
may
email
us
at
info@memcap.com
or
contact
us
by
post
at:
Memcap
LLC
3030
Maltby
Rd
#375
Bothell
,
WA
98021
United
States
15.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
Based
on
the
applicable
laws
of
your
country
or
state
of
residence
in
the
US
,
you
may
have
the
right
to
request
access
to
the
personal
information
we
collect
from
you,
details
about
how
we
have
processed
it,
correct
inaccuracies,
or
delete
your
personal
information.
You
may
also
have
the
right
to
withdraw
your
consent
to
our
processing
of
your
personal
information.
These
rights
may
be
limited
in
some
circumstances
by
applicable
law.
To
request
to
review,
update,
or
delete
your
personal
information,
please
fill
out
and
submit
a
data
subject
access
request
.
