Privacy policy.

1 · About this privacy policy

  • Silicea Labs, Inc.: is committed to protecting your privacy and safeguarding your personal information. 

  • The purpose of this Privacy Policy (Policy) is to inform you about the types of personal information we may collect and hold, how that information is used, and with whom that information may be disclosed. This Policy also outlines what you can do if you have concerns about this Policy or your privacy.

2 · Definitions

In this Policy:

  • "personal information" means information or an opinion about an identified individual or an individual who is reasonably identifiable. It does not matter whether the information or opinion is true or not, or whether it is recorded in a material form or not.

  • "sensitive information" means information or an opinion about an individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional trade or association, membership of a trade union, sexual orientation or practices or criminal record that is also personal information. It also includes health information about an individual and genetic information about an individual that is not otherwise health information.

  • "we", "our" and "us" refers to Silicea Labs:, Silicea Labs, Inc.

  • "you" and "yourself" refers to any person about whom we collect personal information.

3 · What kinds of personal information do we collect?

  • We may collect personal information including, but not limited to your name, email address, geographic location, age, gender, sexual orientation, relationship status, height when you participate in one of our projects or social initiatives or sign up to use our services.

  • We may also collect your personal information, such as: 

    • Photographs & Videos: any pictures, videos, sound recordings and other audio-visual recordings that you provide to us or authorize us to take of you.

    • Geo-Location & Locality Information: when you interact with us, we may collect your current or last known location used to determine your locality from other individuals. We may achieve this through various methods, including collecting your Wi-fi, Guidance Positioning System (GPS), Cellular or other technology in your electronic device or web browser.

    • Interaction & Behavioural Information: your interactions, use, habits, behaviors when dealing with us, our Websites and other applications.

  • We may collect sensitive information, for example mental or physical health information and sexual information. 

  • You can always decline to give us your personal information, but that may mean that we cannot provide you with some or all of your requested products and services.

4 · How do we collect your personal information?

  • We may collect personal information from you if you participate in one of our projects or initiatives in person or via one of our digital platforms. Mainly, we may collect information using software whether it may be collected on mobile or desktop devices.  

  • We may also collect your personal information through third party social media sites (eg Facebook or Gmail) with your consent.

  • Sometimes, we may collect your personal information from a third party, such as where someone who knows you provides us with your information so we can contact you. We may also collect your personal information from public sources.

  • Collection can occur in a number of different ways, such as via online registration, through the use of our apps, social media, email, telephone, in person, and mail.

5 · How do we hold your personal information?

  • We hold personal information in an electronic database which may be hosted by a third party service provider.

  • We take physical and electronic security measures to safeguard personal information from loss, misuse, unauthorized access, modification, or disclosure. This may include restricting access to personal information, entering into confidentiality agreements with third parties and using current technological protection measures.

6 · What are the purposes for which we collect, hold, use, and disclose your personal information?

We collect, hold, use and disclose personal information for the following purposes:

  • responding to your enquiries and communications we receive about our projects and social initiatives (e.g. coaching); 

  • collecting feedback and developing, improving, managing, and administering our projects and social initiatives, including your participation in our projects and initiatives; and

  • telling you about our projects and social initiatives (unless you have told us that you do not want this information).

  • market research purposes and to improve our business offerings. 

  • researching, developing and expanding our facilities, products and services. 

  • for any other purposes (including secondary purposes) that you would reasonably expect. 

  • To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law.

  • if you are part of an organization we may use your de-identified data to provide further services to your organization such as but not limited to: coaching, wellness services, consulting.

The information we collect from projects, user services and social initiatives may also be provided to the general public for the purposes of developing and implementing social impact initiatives or outcomes. Information shared with the general public will always be de-identified, so we do not provide them with your personally identifiable information.

Information shared with partnering organizations may include personally identifiable information.

We may also collect, hold, use and disclose personal information for other purposes which are disclosed at the time of collection or which you consent to or are required by law.

7 · Who do we disclose personal information to?

  • Your personal information may be disclosed to contractors and agents help us to run our projects and social initiatives.

  • We may also disclose your personal information if it is required or authorized by law, where disclosure is necessary to prevent a threat to life, health or safety, or where we are otherwise permitted by the Privacy Act.

  • We do not sell your personal (identifiable) information to anyone.

 

8. Corporate and other community sharing 

Leeloo is also offered through partnerships with organizations. Sometimes corporations, governments, hospitals, universities and other organizations and groups (“Partner(s)”) wish to make Leeloo available to their members, employees and their families, patients, customers, residents or others. For example, employers may offer their employees and their families access to Leeloo and brands that promote wellness may wish to and do offer Leeloo through their loyalty programs. When an entity provides access to Leeloo to others, we call those “Communities.” If you have registered to use the Products through a code, credential, or other means of registration furnished by a Partner (a “Community Account”), the Partner may have access to your name, email address, the date you registered to use the Products, and the date on which you last used the Products. The Partner may also have access to your Community's aggregated and anonymized general usage data (including aggregated and anonymized usage data).


9. Use of Leeloo by minors

You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement of a parent or legal guardian under such person's account.

10 · How do we deal with sensitive information?

  • Some of the information we collect may be sensitive information, such as information relating to religious affiliation and sexual orientation.

  • We will only collect sensitive information with your consent and if that information is reasonably necessary for us to carry out at least one or more of our functions or activities.

  • We will only use and disclose your sensitive information for the purpose for which it was provided or a directly related secondary purpose, unless agreed otherwise by you, or the use or disclosure of that sensitive information is required or authorized by law a court/tribunal order (eg preventing a serious threat to life, health or safety).

11 · Do we disclose personal information to overseas recipients? 

  • Our services are mainly provided from USA and Canada. The only circumstance in which we disclose personal information to an overseas recipient is where your information stored in an electronic database operated by our service provider (currently USA).

  • We will take reasonable steps to ensure that overseas recipients do not breach the APPs in relation to your personal information. 

12 · How can you access, update or seek correction of your personal information? 

  • You can contact us to ask for access to your personal information held by us, or request to have it updated or corrected. To protect your personal information, we will always confirm your identity before giving access or making any change. In limited circumstances, we may decline your request to access or update your personal information (e.g. once you have entered your information via one of our apps and that information has been de-identified, we are unable to give you access or make any change to that information). In such circumstances, we will provide you with a written reason for our decision. 

  • Generally, there is no cost for accessing your personal information unless the request is complex, resource intensive, or we incur additional costs in providing you with access. If there is a charge, it will be reasonable and we will let you know in advance to receive your approval before we proceed.

  • If you wish to have your personal information removed from our records, you may request that your personal information be removed or destroyed. It may not always be possible to comply with your request.

13 · Can you deal with us anonymously?

  • In many cases, you will be able to deal with us anonymously (e.g. by using an email address or username that does not identify you). There may be situations where it is not practicable for us to deal with you anonymously. In those situations, if we cannot collect personal information about you, we may not be able to provide you with our services or you may not be able to participate in our projects or social initiatives.

14 · How do you make a complaint?

  • If you have any questions or concerns about this Policy or how your personal information is handled by us, you may contact us.

  • We will aim to respond to your request or complaint promptly. We take all complaints seriously and are committed to a quick and fair resolution.

  • You may also make a complaint to the USA Federal Trade Commission. If you do so, the FTC may recommend that you try to resolve your complaint directly with us in the first instance. The FTC can be contacted on 202 326 2222 or via the USA Federal Trade Commission website. The website also contains further information about making complaints relating to privacy.

15 · How do we change this Policy?

  • We may change this Policy at any time without notice to you. We recommend that you visit this webpage regularly to keep up to date with any changes.

16 · How do you contact us?

This privacy policy was last updated 10 March 2022. 


CCPA ADDENDUM

This California Consumer Privacy Act (“CCPA”) Addendum for California residents supplements the information contained in the above Privacy Policy and applies solely to all visitors, users and others who reside in the State of California. We adopt this CCPA Addendum to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Addendum.

 

INFORMATION WE MAY COLLECT FROM YOU

Our Products 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, whether collected online or offline (“personal information”). In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months:

CATEGORY

EXAMPLES

COLLECTED

Identifiers: Yes

Examples: First and last name, email address, Internet Protocol address, online identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Yes

Examples: First and last name

Internet or other similar network activity: Yes

Examples: Browsing history or information on a consumer’s interaction with the Products or our advertisements on third-party platforms.

The specific types of personal information we collect are described more fully in section 2 of the Privacy Policy. Personal information does not include: (1) de-identified or aggregated consumer information; (2) publicly available information from government records; or (3) information excluded from the CCPA’s scope. We obtain the categories of personal information listed above from the following categories of sources: Directly from you. For example, from forms you complete when registering for the Products. Indirectly from you. For example, from observing your actions on our Products. 

 

USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for the purposes described in section 6 of the Privacy Policy.

 

SHARING PERSONAL INFORMATION

We may disclose your personal information to third parties for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Category 1: Identifiers

  • Category 2: Personal Information

  • Category 3: Internet activity

Specific examples of such sharing activities can be found in sections 7 and 8 of the Privacy Policy.

 

YOUR RIGHTS AND CHOICES

Access to Specific Information and Data Portability Rights

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.

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 that personal information.

  • The categories of third parties with whom we share that personal information.

  • The categories of personal information we share with third parties.

  • The specific pieces of personal information we collected about you (also called a data portability request).

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 permanently and irrevocably anonymize your personal information, unless an exception applies.

We may deny your deletion request if certain CCPA exemption apply, including but not limited to, if retaining the information is necessary for us or our service provider(s) to:

  • 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.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • 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:

  • Emailing us at leeloo@silicealabs.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. 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. 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.

Notice of Right To Opt-Out

We currently do not partner with third parties, such as Facebook and Google, to manage our marketing or advertising. 

Changes to our CCPA Addendum

We reserve the right to amend this CCPA Addendum at our discretion and at any time. When we make changes to this CCPA Addendum, we will post the updated notice on the Website and update the effective date. Your continued use of our Products following the posting of changes constitutes your acceptance of such changes.

 

Contact Information

If you have any questions or comments about this CCPA Addendum, the ways in which we collect and use your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

 

Inquiries: it@silicealabs.com 

This CCPA Addendum was last updated 10 March 2022.