Effective: June 14, 2011

Purpose of the Privacy Policy: is committed to respecting and protecting your privacy rights, and we created this Privacy Policy to give you (the user) notice of how your private information will (and will not) be used by us in connection with our website (together with its subdomains, content and services). In simplified form (greater detail is below), our policy can be summarized as follows:
  • We may collect some information on you, but you control how much you share about yourself.
  • We take your information seriously.
  • We do not collect information from children under 13 years of age.
  • Except for your consent, we will not sell or rent your personal information but may share with our vendors, suppliers and contributors in connection with the services you are seeking.
  • We may aggregate information.
  • If we use a third party to assist us, they will be bound to protect your information.
  • If you are outside the United States, you understand and agree that we may store your information in the United States.
  • In certain legal situations, we may be compelled to disclose your personal information, but we will let you know if that occurs.
This Privacy Policy applies to the sites where it appears:
This privacy policy applies to how we use your information. This policy describes how we treat personal information on the websites where it appears (the ?Platforms?). By interacting with us, you consent to these practices.

We collect information from and about you.
We may collect contact information and personal information on the Platforms. For example, we may collect your address when you use the Platforms. We also collect your name, email address and phone number if you register with us. We may collect information about your device and Internet usage. If or when you use the Platforms, we might collect information from your phone. We may also collect information about the parts of our Platforms you use or third party apps or websites you visit when you leave our Platforms. When you use our app, we may work with third parties who collect information about you. We may collect other information. For example, we may collect your location using a cellular network location, GPS, browser services, Wi-Fi networks or information you provide. We might look at how often you use the Platforms.

We collect information in different ways:
We collect information from you passively. For example, we may collect information from your phone, like your UDID. Our vendors might also use scripts or other tools to track your activities on our Platform. They may do this to make sure our Platforms function properly. We collect information directly from you. For example, we collect information if you register on the Platforms. We combine information. For example, we may combine information that we have collected offline with information we collect online. Or we may combine information we collect on with information we?ve collected separately. We may also combine information we collect from you with information we receive from third parties. We may get information about you from third parties. For example, our affiliates or partners may give us information about you. If our Platforms have social media integration, social media platforms may also give us information about you.

We use information as disclosed and described here:
We use information to administer the Platforms. We use information to communicate with you about your account or our relationship. We may contact you about our account or feedback. We might also contact you about this Policy or our Terms. We use information to respond to your requests or questions. For example, we might use your information to respond to your customer feedback. We use information for security purposes. We may use information to protect our company, our customers, and our websites. We use information to improve our products and services. We may use your information to make our website and products better. We might use your information to customize your experience with us. We use information for marketing purposes. For example, we might provide you with information about new products and special offers from us. We might also use your information to serve you ads about products and offers. We might tell you about new features or updates. These might be third party offers or products we think you might find interesting. To manage this, read the choices section below. We use information as otherwise permitted by law.

We may share information with third parties:
We will share information with our vendors. These are third parties who perform services on our behalf. For example, we may share information with vendors who send emails for us. We may share information with any successor to all or part of our business. For example, if part of our business was sold, we may share information as part of that transaction. We will share information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share information to respond to a court order or subpoena. We may share it if a government agency or investigatory body requests. We might share information when we are investigating potential fraud. We may share your information with others with whom you have authorized us to share your information. We may share information for other reasons we may describe to you. We will not rent or sell your mobile telephone number to other companies or individuals, unless we have your consent. We may use or disclose such information in any of the following limited circumstances:
  • We have your consent.
  • We need to enforce our Terms of Use.
  • We provide such information to a company controlled by, or under common control with, for any purpose permitted by this Policy.
  • We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
  • We believe it is necessary to share Personal Information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of ?s Terms of Use, or as otherwise required by law.
  • We transfer Personal Information about you if is, or its assets are, acquired by or merged with another company.
You have certain choices about sharing and marketing practices:
You can control cookies and tracking tools. Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because you cannot control flash cookies through your browser settings. You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions. Our Do Not Track Policy: Some browsers have ?do not track? features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

Your California privacy rights:
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at, or write to us at the address listed below. Indicate in your letter that you are a California resident making a ?Shine the Light? inquiry.

These sites and apps are not intended for children:
Our Platforms are meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at You can also write to us at the address listed at the end of this policy. Please mark your inquiries ?COPPA Information Request.? Parents, you can learn more about how to protect children's privacy on-line here.

We store information in the United States:
Information we maintain may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This site is subject to U.S. laws, which may not afford the same level of protection as those in your country.

We use standard security measures:
The Internet is not 100% secure. We cannot promise that your use of our Platforms will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords. To learn more about how to protect yourself online, visit We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law.

We may link to other sites or have third party services on our Platforms we don?t control:
Our Platforms may have links to websites we do not control. Our Platforms may also have plugins or host other third party services that we don?t control. This policy does not apply to the privacy practices of those websites or third parties. When you interact with those websites or third parties, they may collect information from you. Read the privacy policy of other websites carefully. We are not responsible for these third party practices.

Feel free to contact us if you have more questions:
If you have any questions about this Policy, please email us at You can also write to us or call at:
6001 Shellmound St. STE# 325
Emeryville, CA 94608
(888) 556-3889

If you have any questions about this Policy or want to correct or update your information, please email us at

We may update this Policy:
This Privacy Policy may be updated from time to time, but the changes will not apply retroactively. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our website ( Please check our website periodically for updates.


This PRIVACY POLICY IS FOR CALIFORNIA RESIDENTS ONLY and it supplements the information contained in the general Privacy Policy shown above. This Privacy Policy applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

  1. Understanding Your Rights and Choices Under the CCPA

  2. 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.

    1. Access to Specific Information and Data Portability Rights

    2. 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 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

      1. The categories of personal information we collected about you.
      2. The categories of sources for the personal information we collected about you.
      3. Our business or commercial purpose for collecting or selling that personal information.
      4. The categories of third parties with whom we share that personal information.
      5. The specific pieces of personal information we collected about you (also called Data Portability)

    3. Deletion Request Rights

    4. 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, 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 providers to:

      1. 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.
      2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      3. Debug products to identify and repair errors that impair existing intended functionality.
      4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 seq.).
      6. 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.
      7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      8. Comply with a legal obligation.
      9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    5. Exercising Access, Data Portability, and Deletion Rights

      1. To exercise the access, data portability, and deletion rights described above, please call us (855) 866-5770.
      2. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
      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:

        1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
        2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
        3. 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

    6. Right to Opt Out of Sale of Personal Information to Third Parties.

    7. You have the right to know if your personal information may be sold and the right to opt out of such sale. In our efforts to comply with this right to opt out, you may visit this link & provide us your email address and zip code so we can verify and process your requests. See section 5 below for more details ("Sharing Personal Information").

    8. Response Timing and Format

      1. We endeavor to respond to a verifiable consumer request within 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. If you have an account with us, we will deliver our written response to the email address associated with that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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.
      2. For consumer requests to opt out of sale of personal information, we will review, verify and process your request within 10 days of receiving this request.
      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.

  3. Non-Discrimination

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

      1. Deny you goods or services.
      2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
      3. Provide you a different level or quality of goods or services.
      4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

  4. Information We Collect

    1. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected categories of personal information from consumers within the last twelve (12) months that include the following:

      1. Identifiers,
      2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)),
      3. Commercial information,
      4. Internet or other electronic network activity &
      5. Geolocation data.

    2. Personal information does not include:

      1. Publicly available information from government records.
      2. De-identified or aggregated consumer information.
      3. Information excluded from the CCPA's scope, like:

        1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
        2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

    3. We obtain the categories of personal information listed above from the following categories of sources:

      1. Directly from our consumers or their agents. For example, from information that our customers provide to us related to the services for which they engage us.
      2. Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
      3. Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
      4. From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

  5. Use of Personal Information

    1. We may use or disclose the personal information we collect for one or more of the following business purposes:

      1. To fulfill or meet the reason for which the information is provided.
      2. To provide you with information, products or services that you request from us.
      3. To provide you with email alerts and other notices concerning our products or services that may be of interest to you.
      4. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
      5. To improve our website and present its contents to you.
      6. For testing, research, analysis and product development.
      7. As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
      8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
      9. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
      10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

    2. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Notice will be provided by amending this California specific Privacy Policy.

  6. Sharing Personal Information

    1. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we describe the purpose to the recipient and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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

      1. Identifiers,
      2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)),
      3. Commercial information,
      4. Internet or other electronic network activity &
      5. Geolocation data.

    3. We disclose your personal information for a business purpose to the following categories of third parties:

      1. Our partners.
      2. Service providers.
      3. Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
      4. In the preceding twelve (12) months, we have sold personal information.

  7. Changes to Our Privacy Notice

  8. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

  9. Contact Information

  10. If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

    Phone: (855) 866-5770