Effective date: 20 March 2024.

This Privacy Notice supplements the information contained in Prequel, Inc.'s ("Prequel," "Company," "us," "our," or "we") Privacy Policy ("Site Privacy Policy"). It is specifically tailored to address the data privacy laws applicable to our interactions solely with visitors, Users, and other individuals residing in the United States, namely California, Colorado, Connecticut, Utah, Virginia, Illinois, Texas, and Washington ("consumers," "you," or "your"). By referring to both this Privacy Notice and the Site Privacy Policy, you gain a comprehensive understanding of our data processing practices.

Your privacy is of utmost importance to us. By using our applications and services, you acknowledge and consent to the terms outlined in this Privacy Notice and the Site Privacy Policy.

For this notice, all terms defined in applicable legislation shall have the same meaning when used herein. Any capitalized terms not defined within this document shall carry the meanings ascribed to them in the Company's Privacy Policy. In the event of any inconsistencies between this Privacy Notice and the Company's Privacy Policy, the provisions of this Privacy Notice shall prevail.

1.1. We may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information").

1.2. In particular, we may collect the following categories of personal information from you within the last twelve (12) months:

A. Identifiers. Examples: name, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.

B. Personal information categories. Examples: name, signature, physical characteristics or description, address, and telephone number. Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under U.S. laws. Examples: age, race, ancestry, national origin, citizenship, religion or creed, marital status, 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).

D. Commercial information. Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Internet or other similar network activity. Examples: Browsing history (if using our website), search history, and information on a consumer's interaction with a website, application, or advertisement.

F. Geolocation data. Examples: Physical location or movements.

G. Sensory data.Examples: Audio, electronic, visual, or similar information.

H. Inferences are drawn from other personal information. Examples: profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

1.3. Personal information does not include:
(i) Publicly available information from government records;
(ii) De-identified or aggregated consumer information;
(iii) Information excluded from the U.S. privacy laws mentioned above scope.

2.1. We may use or disclose the personal information we collect for one or more of the following purposes:
(i) To fulfil or meet the reason for which you provided the information. For example, if you share your name and contact information to ask a question about our website, app or product we will use that personal information to respond to your inquiry.
(ii) To provide, support, personalize and develop our websites, apps and products.
(iii) To process your requests and respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
(iv) To notify you about changes to our websites, apps or any products or services we offer or provide through our websites and apps.
(v) To notify you about changes to our policies and/or terms of use.
(vi) To maintain a record of our dealings with you.
(vii) To understand and analyze the usage trends and preferences of our Users, to improve our websites, apps and other products and to develop new features, and functionality.
(viii) To contact you for administrative and information purposes - this may include providing customer service or sending communications, including changes to our terms of use.
(ix) To engage features of third-party social networks.
(x) For testing, research, analysis and product development.
(xi) To help maintain the safety, security, and integrity of our websites and apps, databases, other technology assets and business.
(xii) To diagnose or fix technological problems concerning our websites, apps and products.
(xiii) To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
(xiv) To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
(xv) 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.
(xvi) As described to you when collecting your personal information or as otherwise outlined in certain U.S. laws.

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

3.2. In the preceding twelve (12) months, we may disclose the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: Personal information categories listed in the U.S. Customer Records statutes.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.

3.3. We may disclose your personal information for business purposes to the following categories of third parties:
(i) our affiliates.
(ii) Service providers.
(iii) 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.
(iv) Law enforcement bodies and courts.

3.4. We may share your personal information for the following general purposes:
(i) Service Providers: we may disclose personal information to third-party service providers that assist us with our operations. For example, analytics, log management, payment processing and data storage and processing services.
(ii) Protecting our Rights: we may disclose personal information to third parties if We believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
(iii) Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of Company's assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.

3.5. We have not sold any personal information.

The U.S. laws provide consumers with specific rights regarding their personal information. This section describes it. To guarantee full transparency and openness, we have outlined the primary rights and business obligations clearly and practically within this Privacy Notice for your easy understanding and practical utility:

	California		Colorado	Connecticut	Utah	Virginia
	California Consumer Privacy Act	California Privacy Rights Act	Colorado Privacy Act	Connecticut Data Privacy Act	Utah Consumer Privacy Act	Virginia Consumer Data Protection Act
Right to access/ Right to know	V	V	V	V	V	V
Right to correct		V	V	V		V
Right to delete	V	V	V	V	V	V
Right to opt out of certain processing		Sensitive Data	Profiling/ Targeted advertising purposes	Profiling/ Targeted advertising purposes	Profiling/ Targeted advertising purposes	Profiling/ Targeted advertising purposes
Right to portability	V	V	V	V	V	V
Right to opt out of sales	V	V	V	V	V	V
Right to opt in for sensitive data processing			V	V		V
Right against automated decision-making		V	Right to opt out of certain automated decision-making	Right to opt out of certain automated decision-making		Right to opt out of certain automated decision-making
Private right of action	Private right of action limited to certain violations, only	Private right of action limited to certain violations, only

4.1. Right to Access/ Right to Know. You have the right to confirm whether and know the personal data we collected on you. You can exercise your right by reviewing this Privacy Notice, you may access and request a copy of the specific personal data collected by us about you. Once we receive and confirm your verifiable consumer request (see section 4.3 herein), we will disclose to you:
(i) The categories of personal information we collected about you.
(ii) The categories of sources for the personal information we collected about you.
(iii) our business or commercial purpose for collecting and selling that personal information.
(iv) The categories of third parties with whom we share that personal information.
(v) The specific pieces of personal information we collected about you (also called a data portability request).
(vi) If we disclosed your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

4.2. Right to Correction and Delete. You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data. You can exercise this right directly.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see section 4.3 herein), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to
(i) Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
(ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
(iii) Debug products to identify and repair errors that impair existing intended functionality.
(iv) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
(v) 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.
(vi) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
(vii) Comply with a legal obligation.
(viii) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

4.3. Right to Portability. You have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Once we receive and confirm your verifiable consumer request (see section 4.4 herein), we will provide this right to you.

4.4. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:

[email protected]
Fanariou 10, apt. 102, Limassol, Cyprus, 3106.

4.4.1. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

4.4.2. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
(i) Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person; and
(ii) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

4.4.3. 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.

4.4.4. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

4.4.5. Response Timing and Format

4.4.5.1. We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

4.4.5.2. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

4.4.5.3. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

4.5. Right to opt out from (i) selling Personal Data; (ii) Right to opt out from processing for Targeted Advertising; and (iii) Right to opt out from Profiling. You have the right to opt out of the processing of your Personal Data for the purposes of targeted advertising, its sale to a third party for monetary gain or other value, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer. You may authorize another person acting on your behalf to opt out (including by technical tools and opt out signals).

4.5.2. To exercise the right to opt out, you (or your authorized representative) shall submit a variable notice to [email protected].

4.5.3. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

4.6. Right Against Automated Decision-Making. You have the right not to be subjected to decisions based solely on automated processing, including profiling, which significantly affects you. We understand the importance of human input in certain decisions that may impact you, and we are committed to upholding this right.
We want to assure you that our business prohibits making significant decisions about you based solely on automated processes without any human involvement. Human insight is an integral part of our decision-making processes to ensure fairness, transparency, and accountability.
For more details about how we handle your personal information, including the use of automated decision-making processes, please submit a variable notice to [email protected].

4.7. Private right of action. As a resident of certain U.S. states, you have the right to bring a private right of action for certain unauthorized access and exfiltration, theft, or disclosure of your personal information. You can initiate legal proceedings if your non-encrypted or non-redacted personal information is subject to unauthorized access and exfiltration, theft, or disclosure.
Before filing an action, you are required to provide us with written notice of the alleged actions, please submit a variable notice to [email protected].

We will not discriminate against you for exercising any of your rights. Unless permitted by the U.S. laws, we will not:
(i) Deny you goods or services.
(ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
(iii) Provide you with a different level or quality of goods or services.
(iv) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We are committed to protecting the privacy and security of our users' sensetive information. This section outlines our practices by applicable laws, including but not limited to the Illinois Biometric Information Privacy Act (BIPA), Texas Capture or Use of Biometric Identifier Act (CUBI), and Washington Biometric Information Privacy Act.

6.1. Information Collected. The data we gather as part of our services does not encompass biometric information, as photographs are expressly excluded from the category of data classified as biometric identifiers. We do not collect, store, and use biometric identifiers or biometric information, such as a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.

6.2. Consent. As we are not currently collecting any biometric identifiers or biometric information, your consent is not necessary at this time. We will seek additional consent if we intend to use your biometric information for any other purpose not mentioned herein.

6.3. Purpose of Collection. As we are not currently collecting any biometric identifiers or biometric information, we do not set any purpose other than what is explicitly stated in the Site Privacy Policy.

6.4. Retention and Deletion. As we are not currently collecting any biometric identifiers or biometric information, we do not establish a special retention and deletion rules and schedule than what is explicitly stated in the Site Privacy Policy.

6.5. Security Measures. As we are not currently collecting any biometric identifiers or biometric information, we do not set any additional measures. We implement industry-standard security measures to protect your information from unauthorized access, disclosure, alteration, and destruction. Our commitment to security includes encryption, access controls and other measures what is explicitly stated in the Site Privacy Policy.

6.6. Your Rights. You have the right to inquire about the types of information we hold about you, the purpose of its collection, and request its deletion. For inquiries or requests related to your information, please contact us directly (please see Section 8 for more inquiries).

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 post the updated Privacy Notice via the Services or on the Site and update the Privacy Notice's effective date. Your continued use of our websites, apps and Services following the posting of changes constitutes your acceptance of such changes.

8.1. If you have any questions or comments about this Privacy Notice, how the Company collects and uses your information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under U.S. laws, please do not hesitate to contact our representative responsible for personal information as follows:

Fanariou 10, apt. 102, Limassol, Cyprus, 3106
[email protected]

8.2. If you have any questions about this Privacy Notice or our Privacy policy, you can contact us at [email protected].