CCPA Privacy Notice

(1) Introduction, Scope & Applicability

This CCPA privacy notice ("CCPA Notice") applies to California residents ("consumers" or "you") and is an integral part of, and supplements, LightnerTok LTD ("Company", "we" or "our") Privacy Policy.

This CCPA Notice provides with the information required under the California Privacy Rights Act of 2020 (collectively "CCPA") regarding Company's collection and use of "personal information" as the "business" when you ("you" or "user") access, use or otherwise interact with our website available at: https://lightnertok.com/ ("website").

Definitions used under this CCPA Notice shall have the same meaning as assigned to them under the CCPA, or as defined in our Privacy Policy, as applicable. When we refer to "Personal Data" under our Privacy Policy, it shall also mean "personal information" as defined under the CCPA.

(2) Categories of Personal Information We Collect

Personal Information is defined under the CCPA as any 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, household or device. Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA's scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; 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.

Category A – Identifiers

Under the CCPA, this category includes, for example, a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

We collect this category of data sets - when you access or interact with our website, we collect Online Identifiers (such as Internet Protocol (IP) address, cookie identifiers, and similar unique online identifiers), as well as Contact Information, if you contact us via email, which may include, as applicable, your name and email address.

Category B – Personal Information (Cal. Civ. Code § 1798.80(e))

Under the CCPA, this category includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, any other financial information, medical information, health insurance information. Some personal information included in this category may overlap with other categories.

When you contact us we collect Contact Information, which may include, as applicable, your name and telephone number.

Category C – Protected Classification Characteristics

Under the CCPA, this category includes: age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

We do not collect this category of data sets.

Category D – Commercial Information

Under the CCPA, this category includes records of personal property, products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies.

We do not collect this category of data sets.

Category E – Biometric Information

Under the CCPA, this category includes genetic, physiological, behavioral, biological characteristics, activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, other physical patterns, sleep, health, or exercise data.

We do not collect this category of data sets.

Category F – Internet or Other Similar Network Activity

Under the CCPA, this category includes browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

We collect this category of data sets – when you access and browse the website, we collect Usage Data which includes information regarding your use and interactions with our website or marketing campaigns (such as the access or usage time and date, session durations, the pages viewed on our website and click stream within the website, the URL or advertising campaign from which you have reached our website, etc.).

Category G – Geolocation Data

Under the CCPA, this category includes, for example, physical location or movements.

We collect this category of data sets - approximate location derived from IP address.

Category H – Sensory Data

Under the CCPA, this category includes audio, electronic, visual, thermal, olfactory, or similar information.

We collect this category of data sets - for example, we collect Contact Communications Data with you, which may include calls recording.

Category I – Professional or Employment-Related Information

Under the CCPA, this category includes current or past job history, performance evaluations.

We do not collect this category of data sets.

Category J – Non-public Education Information

(per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): under the CCPA, this category includes education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

We do not collect this category of data sets.

Category K – Inferences Drawn from Other Personal Information

Under the CCPA, this category includes profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not collect this category of data sets.

Category L – Sensitive Personal Information

Under the CCPA, this category includes government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.

We do not collect this category of data sets.

(3) Categories of Sources of Personal Information

We collect Personal Information through the following categories of sources:

• Directly and indirectly from activity on our website: for example, website's Usage Data collected automatically from measurement tools.
• Directly from you: for example, your Contact Information if you provide it to us as part of an interaction with us, such as by contacting us using the contact details made available on the website.
• From third parties: for example, from vendors who assist us in performing services such as advertising partners and data analytics providers.

(4) How We Use Personal Information

We use the Personal Information we collect for the following purposes:

• To fulfill or meet the reason you provided the Personal Information (e.g., respond to your inquiry);
• To monitor and improve our website and the content we make available therein, as well as our marketing efforts;
• To analyze use of our website;
• Where required, to respond to law enforcement; or
• As otherwise as detailed in our Privacy Policy (please see Section 4 of our Privacy Policy "The Data Sets Collected, Purpose of Use and Lawful Basis").

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.

(5) Disclosures of Personal Information for a Business Purpose

We may disclose Personal Information to our contractors or service providers for a "business purpose". When we disclose Personal Information for a "business purpose", we enter a contract that describes the purpose, requires the recipient to both keep Personal Information confidential and not use it for any purpose except performing the contract, as well as restrict the recipient from "selling" or "sharing" such Personal Information we disclosed.

The following categories of Personal Information are shared by the Company for a "business purpose":

• Auditing related to counting ad impressions: Category A, F, G – shared with advertising networks, data analytics providers, social media networks.
• Helping to ensure security and integrity: Category A, B, F, G – shared with affiliated companies and subsidiaries, operational partners, security and fraud prevention providers, customer support provider, operating systems.
• Debugging to identify and repair errors: Category A, F, G – shared with security and analytics providers.
• Short-term, transient use: Category A, F, G – shared with advertising networks, data analytics providers, social media networks.
• Performing services on behalf of the business: Category A, B, F, G – shared with affiliated companies and subsidiaries, operating systems, CRM, customer support, cloud computing and storage vendors.
• Undertaking internal research for technological development: Category A, F, G – shared with cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools.
• Undertaking activities to verify or maintain quality or safety: Category A, B, F, G – shared with cloud and hosting providers, security tools, task management tools and development, customer support and optimization tools.
• Providing advertising and marketing services: Category A, B, F, G – shared with advertising networks, data analytics providers, social media networks, and platforms such as CRM.
• Advancing business' commercial or economic interests: Category A, B, F, G – shared with affiliated companies and subsidiaries, advertising networks, data analytics providers, social media networks.

(6) Sale or Share of Personal Information

We do not "sell" or "share" information as most people would commonly understand these terms – meaning we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.

For retargeting and analytic purposes, when we promote our website, we use third-party tools that market our website online, measure the marketing efforts, identify users that are interested in our website, etc. This is done by placing tracking technologies on our website such as cookies, tags, pixels, or similar, and by placing these technologies, online identifiers and online behavior information is shared with such vendors, including for "cross-context behavioral advertising". Under the CCPA, the practices described above are defined as "sharing" or "selling" Personal Information.

The categories of Personal Information disclosed to such third parties under this practice considered "sell" or "share" includes Category A; Category F and Category G.

(7) Children Under Age 16

Our website is not intended for children, and we do not knowingly collect or sell information from children under the age of 16.

(8) Retention of Personal Information

The retention periods of Personal Information we collect and store are determined by us in accordance with the following criteria:

• For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially collected;
• For as long as it remains necessary to comply with our regulatory or legal obligations;
• To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain Personal Information for any particular period, and we may delete it for any reason and at any time, without providing notice.

(9) Your Rights Under the CCPA

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law.

The Right to Know and Access Rights

You have the right to know what Personal Information the "business" has collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, "selling", or "sharing" Personal Information, the categories of third parties to whom the "business" discloses Personal Information, and the specific pieces of Personal Information the "business" has collected about you.

Deletion Rights

You have the right to request the deletion of Personal Information that the "business" has collected from you, subject to certain exceptions.

Correct Inaccurate Information

The right to request a "business" to correct inaccurate Personal Information that the "business" maintains about you.

Rights Related to "Sharing" and "Sale" of Personal Information

You have the right to opt-out of the "sharing" of your Personal Information for "cross-contextual behavioral advertising," often referred to as "interest-based advertising" or "targeted advertising" and the "sale" of your Personal Information.

Limit the Use or Disclosure of Sensitive Personal Information

Under certain circumstances, if the "business" uses or discloses Sensitive Personal Information, you have the right to limit such use or disclosure.

Opt-out of Automated Decision Making

In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.

Non-discrimination

You have the right not to receive discriminatory treatment by the "business" for the exercise of privacy rights conferred by the CCPA, including denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc.

Data Portability

You may request to receive a copy of your Personal Information you provided, including specific pieces of Personal Information, in a portable format.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

How Can You Exercise Your Rights?

You may exercise your rights by contacting us at: [email protected].

Certain rights can be exercised by you independently, for example:

• You can opt-out from receiving emails from us by clicking the "unsubscribe" link or other opt-out alternatives we make available, as detailed in the marketing communication we sent you.
• Opt-out from selling or sharing can be executed at any time, by using the cookie preferences management tool or the "Do Not Sell or Share my Personal Information" button all available through our website.

You can designate an authorized agent to submit requests on your behalf via the methods above. However, we will require written proof of the agent's permission to do so and verify your identity directly. We will not verify your identity if the agent provides a power of attorney documentation.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) 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. 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.

(10) Other Rights Applicable to California Residents

California Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding the disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at: [email protected].

Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the "Do Not Track" settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us. However, as noted above, we do honor opt-out preference signals.

(11) Notice of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.

(12) Contact Us

If you have any questions or concerns about this CCPA Notice, please contact us at [email protected].

(13) Updates

As required under the CCPA, we will update the CCPA Notice every 12 months, if needed. The last revision date will be reflected in the "Last Updated" heading at the top of this CCPA Notice.