PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) explains what information of yours (“you,” “yours,” or “user”) will be collected by Canopy LLC (“Canopy”) when you download and use the Let’s Pause App, our websites, or use other services (collectively referred to the “Let’s Pause App” or “Let’s Pause” in this Privacy Policy) and, how the information will be used, and how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources.

We suggest that you read this Privacy Policy in conjunction with Canopy’s Terms of Use Agreement, which incorporates this Privacy Policy by reference.

This page informs you of our policies regarding the collection, use, and disclosure of personal information when you use the Let’s Pause App and the choices you have associated with that data.

We use your data to provide and improve the Let’s Pause App. By using the Let’s Pause App, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use Agreement.

A.What information do we collect?

When you download the Let’s Pause App, you will be prompted to register and create an account. As part of the registration process, we may collect certain information such as:

• Name;
• Username;
• Email address
• Cell number
• Gender identity;
• Date of birth;
• Photographs;
• Location

At the time of registration, you will also be asked to create a secure password. Once you are fully registered, you will be able to review and change your password and other information by logging into your Let’s Pause account at any time. Please be sure to keep your account details updated.

Please remember that certain registration information, such as your name, username and other details may be visible to other users of Let’s Pause who view your activity or your profile page.

For users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA). 

For your reference “personal information” within the meaning of the CCPA means any information that relates to or describes an individual or household, including any data that is linked or linkable to an individual or household.

The below table answers what personal information we may collect and disclose:

Please bear in mind that personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Demographic information that cannot be reasonably linked to an individual
• Information excluded from the CCPA’s scope, like:
• 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;
• 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.

B. How do we use your information?

Our primary purpose is to provide a safe forum for you to share your experiences and thoughts on mental and physical health and wellness issues. Accordingly, we may use your information to:

• Offer you our services and features;
• Contact you with information about Let’s Pause App (e.g. updates and new features);
• Conduct research and identify trends in how you and other users interact with the Let’s Pause App;
• To personalize Let’s Pause and the content we deliver to you, including any promotions;
• Moderate, monitor and review accounts to ensure that any content or information uploaded by the users of Let’s Pause are not in breach of our Terms of Use Agreement
• Enforce Canopy’s Terms of Use Agreement and to resolve disputes
• Investigate fraud, protect Canopy’s legal rights and protect our users from harm.We may also use email communications to contact you with newsletters, marketing or other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by sending an email to info@letspause.app. Should you opt-out of email communications you will need to log in to home directly through the home page, as you will no longer be directly notified of activities you are eligible to participate in.

C. How do we collect information about you?

In addition to the information that Canopy has obtained directly from you, with your consent, we also collect information about you through other means, such as:

I. Usage Data
Usage data is data collected automatically either generated by the use of the Let’s Pause App or from the Let’s Pause infrastructure itself (for example, the duration of a visit).

II.Tracking Technologies
We use web beacons, tags, scripts and other tracking technologies to track and collect user activity on Let’s Pause. In addition, we may set and access “cookies” on your mobile device to gather information that does not constitute personal information. A “cookie” is a small file containing a string of characters that is sent to your mobile device when you use Let’s Pause. We use cookies to improve the quality of Let’s Pause and to better understand how people interact with each through Let’s Pause. We do this by storing user preferences in cookies and by tracking user trends and patterns of how users interact with or use Let’s Pause.

We may use the following types of Cookies:

• Session Cookies
Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you while you are logged into or are using the Let’s Pause App. This allows us to process your online transactions and requests, and to verify your identity, after you have logged in, as you move through the Let’s Pause App.

• Persistent Cookies
Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information or to maintain the security of Let’s Pause.

• Third Party Cookies
We also may engage third parties, including, without limitation, Google Analytics, to track and analyze non-personally identifiable data from Let’s Pause. We use the data collected by such third parties to help us administer and improve the quality of Let’s Pause and Canopy’s services and to analyze usage. We do not have access to or control over these third party cookies, nor does this Privacy Policy cover such third parties’ use of data.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Let’sPause App.

D. Disclosure and Retention of Data

As set forth in the table above, Canopy may sell your personal information to others. If you are a California resident, please see disclosed the section below titled Special Information for California Residents. Canopy may store personal information in locations outside the direct control of Canopy (for instance, on servers or databases co-located with hosting providers). Any personal information you elect to make publicly available through Let’s Pause, such as by posting comments, photos, etc., will be available to others. If you remove information that you have made public on Let’s Pause copies may remain viewable in cached and archived pages, or if other users have copied or saved that information. However, copying and saving information of other users of Let’s Pause is not permissible under our Terms of Use Agreement.

We may disclose a user’s personal information to:

• Third party companies and individuals to facilitate the use of the Let’s Pause App (“Service Providers”) and to provide the Let’s Pause App on our behalf, to perform app related services or to assist us in analyzing how Let’s Pause is being used. In this instance, those third parties are prohibited from using any personal information for purposes other than those requested by Canopy or as required by applicable law. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
•  With our licensors in order to provide services to those licensors, as necessary. Such disclosure of personal information to Canopy’s licensors may constitute a “sale” under the terms of the CCPA.

Canopy may disclose your personal information in the good faith belief that such action is necessary:

• To comply with a legal obligation
• To protect and defend the rights or property of Canopy or its clients
• To prevent or investigate possible wrongdoing in connection with the Let’s Pause App
•  To protect the personal safety of users of the Let’s Pause App or the public
• To protect against legal liability

Under certain circumstances, Canopy may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other than as disclosed herein, only Canopy employees with a business need-to-know, or whose duties reasonably so require, are granted access to your personal information and data.

Canopy will retain your personal information and other personal data for as long as your account is active or as needed to provide you services, but no longer than one (1) year after your last visit and use of the Let’s Pause App or when you shut down your account. We will retain and use your personal information and other data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply withapplicable laws), resolve disputes, perform security and fraud-prevention activities, and enforce our legal agreements and policies.

Canopy will also retain your usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Let’s Pause App, or we are legally obligated to retain this data for longer time periods.

Please be advised that your information, including personal information, may be transferred to — and maintained on — computers located in a different U.S. state from your state of residence where the data protection laws may differ from those in your jurisdiction.

Your consent to this Privacy Policy and the Terms of Use Agreement followed by your submission of such information represents your agreement to that transfer.

E. Change in Control

What Happens In The Event Of A Change Of Control: Canopy may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as your name and email address, and other user information related to the Let’s Pause community may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information or data, as well as any choices you may have regarding your personal information or data.

F. Security of Data

The security of your data is important to us and we have implemented commercially reasonable measures designed to secure your and other users’ personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Please note that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect our users’ personal data, we cannot guarantee its absolute security.

G. Links To Other Sites

The Let’s Pause App may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

H. Children’s Privacy

The Let’s Pause App is not intended for anyone under the age of 13 (“Children”). We do not knowingly collect personal information from anyone under the age of 13. If you are between 13-18 years old, please ask a parent or guardian for permission before you use Let’s Pause. We will require If you are a parent or guardian and you are aware that your Children has provided us with personal information, please contact us. If we become aware that we have collected personal information from Children without verification of parental consent, we take steps to remove that information from the Let’s Pause App and our servers.

I. Special Information for California Residents

Under the California Consumer Privacy Act (“CCPA”), California Residents are afforded certain rights over their personal information, which are detailed below. Any terms defined in the CCPA have the same meaning defined therein when used in this Privacy Policy.

a. Your Rights And Choices
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.

b. Access to Specific Information and Data Portability Rights
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:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• The categories of third parties to whom the consumer’s personal information has been sold and the specific categories of personal information sold to each category of third party.

c. Deletion Request Rights
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.

Exercising Access, Data Portability, and Deletion Rights

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

• Sending an email to info@letspause.app.
• Submit a request through your community.

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 and data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you are registered customer, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to a
reasonably degree of certainty.

d. Response Timing and Format
Canopy will 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. Any disclosures Canopy provides will only cover the 12-month period preceding the verifiable user’s 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.

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.

e. Non-Discrimination
We will not discriminate against you for exercising any of your applicable CCPA rights. Unless permitted by the CCPA, we will not:

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

f. Opt Out of the ‘Sale’ of Your Personal Information

The CCPA defines the terms “sell” and “sale” very broadly, such that some of our research related activities might fall within the definition of “sale” under certain circumstances.

To exercise the opt out of the sale right, please submit a request to info@letspause.app

J. Changes To This Privacy Policy

Canopy may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on Let’s Pause, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.