Privacy Policy

1. GENERAL STATEMENTS
Welcome to Proper! This Privacy Policy is a legally binding contract between Temerity Media Inc. or its applicable affiliate that owns or controls the applicable Website or provides the applicable Services that you may be accessing or using (“Proper”, “us”, “we” or “our”), on the one hand, and you and your successors and heirs and (if applicable) the corporate entity you represent (“you” or “your”), on the other hand. This Privacy Policy describes our policies on the collection, use, and disclosure of information when you access or use Proper’s (a) websites, portals, mobile applications, channels, and software, including aproperhigh.com, and (b) social media pages and channels (collectively, the “Websites”), including any services, features, media, functions, content, tools, and links contained or offered therein (collectively, the “Services”). We share personal information such as mobile ad ids and/or cookies collected with advertisers and other unaffiliated third parties, including business partners such as advertising businesses who are obligated to comply with applicable laws concerning usage of such information, for their own marketing purposes. Please see the remainder of this Privacy Policy for your opt-out choices. When you use the Websites or Services, you consent to our collection, use, modification, and disclosure of information about you as described in this Privacy Policy. If you do not accept and agree to this Privacy Policy, you may not access or use any of the Websites or Services or create an account or user profile.

We may make changes to this Privacy Policy from time to time. When we make material changes to this Privacy Policy, we will notify you by (i) sending you an e-mail communication to the e-mail address you most recently provided to us, (ii) sending a push notification or in-app notification, (iii) prominently posting a notice of the changes on the Websites, or (iv) requiring you to check a box indicating your assent to the updated terms. Continued use of any of the Websites or Services following any applicable notice of such material changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. We may also post additional privacy policies or statements that apply to certain portions of the Websites or Services, and your access to and use of such Websites or Services shall be deemed to be your approval and consent to such additional privacy policies or statements.

2. INFORMATION WE COLLECT AND HOW WE USE IT

How Proper Uses Your Information
We generally use your information to:

1. Facilitate the creation of and to secure your User Account (as defined below) on the Services;
2. Identify you as a user in our system;
3. Provide, personalize, and improve the Services;
4. Provide feedback and user base demographics to third-party businesses listed on the Websites or Services;
5. Communicate with you about your use of the Services;
6. Develop new products and Services,
7. Track usage of the Websites and Services;
8. Customize the advertising you view and recommend content;
9. Backup our systems and allow for disaster recovery;
10. Fulfill your requests and provide customer support;
11. Send newsletters, surveys, offers and promotional materials related to the Services and your user preferences and behaviors and for other marketing purposes of Proper using your contact information;
12. Protect, investigate, prevent and potentially take action against possible fraudulent, unauthorized, or illegal activities;
13. Respond to claims that Website content is inauthentic, counterfeit, or otherwise violates the rights of third parties;
14. Respond to your requests for customer service;
15. Protect our rights and the rights of other users;
16. Enforce our Terms of Service, this Privacy Policy, and any other policies governing your access to or use of any of the Websites or Services; and
17. As otherwise described in this Privacy Policy or in notices we provided to you.

We may also use your information to verify your geographic location. We may use your geographic location data to personalize and improve our Websites or Services, to recommend content, or determine whether the information you have requested is available in your location.

How Proper Discloses Your Information

1. We may share your personal information with your consent or at your direction, including with third parties fulfilling orders or requests you place on our Websites.
2. We may also share your information with others who perform services on our behalf.
3. We also may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses or to protect Proper, our Websites, and Services; or any rights, property, or personal safety of Proper or others.
4. In the event that Proper is or may be acquired by or merged with another company or involved in any other business deal (or negotiation of a business deal) involving sale or transfer of all or part of our business or assets, we may transfer or assign your information as part of or in connection with the transaction and such acquirer or merged entity may thereafter utilize your personal information in accordance with this Privacy Policy. Finally, in the event of insolvency, bankruptcy, or receivership, information may be transferred as a business asset.
5. We may share your information with any of our affiliates.

We may also share aggregated and reasonably anonymized data with our partners, advertisers, and other third parties. You acknowledge and agree that the Websites can serve as portals to other businesses and consumers. Any requests, orders, or interactions you engage in with other businesses and consumers may necessitate the provision of information to such other party.

Information We May Collect
This Privacy Policy describes the types of information we collect. Among the information we collect, please note:

1. Account Information: If you create an account on any of the Websites or Services (a “User Account”), we may store and use your full name, e-mail address, home address, phone number, zip code, and other information you may provide with your User Account, such as your gender and birth date. Your first name and last initial, as well as any photo you submit through the registration process, may be publicly displayed as part of your User Account profile. We may also store and use information regarding your means of age verification (e.g., drivers license) or medical marijuana recommendation, including your recommending doctor’s name and license number, contact information, verification methodology, and verification number. We may also store information on your order history and preferences with respect to orders placed from your account.
2. Public Content: The information that you contribute through or post on the Websites or Services is intended for public consumption, including your reviews, tips, photos, videos, check-ins, comments, likes, posts, events, bookmarks, friends, lists, compliments, and basic User Account profile information. We may display this information through the Websites or Services, share it with businesses, and further distribute it to a wider audience through third-party sites and services.
3. Communications: When you sign up for a User Account or use certain features, you are opting to receive messages from other Proper users, businesses, and Proper itself. While you can manage some of your e-mail preferences, please note that you cannot opt out of receiving certain administrative, transactional, or legal messages from Proper. We may also track your actions in response to the messages you receive from Proper or through the Websites or Services, such as whether you deleted, opened, or forwarded such messages. If you exchange messages with others through the Websites or Services, we may store them in order to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to the operation and use of the Websites or Services. We may not deliver messages that we believe are objectionable, such as spam messages or requests to exchange reviews for compensation. If you send or receive messages through the Websites or Services via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, e-mails, and other electronic messages, or in person. If you are a representative of a business listed on Proper, we may contact you, including by phone or e-mail, using the contact information you provide us, make publicly available, or that we have on record for your business.
4. Transactional Information: If you initiate a transaction through any of our Websites or Services, to the extent applicable (the “Transactable Sites”), we may collect and store information about you, such as your name, phone number, address, e-mail, and credit card information, as well as any other information you provide to us, in order to process your transaction, send communications about them to you, and populate forms for future transactions. This information may be shared with third parties for the same purposes. Proper does not disclose your personal information to third parties for the purpose of directly marketing their services to you unless you first agree to such disclosure that may advertise content directly to you on behalf of such parties. When you submit credit card numbers, we encrypt that information using industry standard technology. If you write reviews about businesses with which you transact through the Websites or Services, we may publicly display the fact that you transacted with those businesses.
a. We collect non-personal information from you while you are browsing in the Websites. This information may include IP addresses to help analyze system administration, to gather broad demographic information, to enable ads to reach the right individuals, to report non-personal information to our advertisers, and to monitor the level of activity on Proper. The information we collect from you visiting the Transactable Sites may include the URLs they came from, their IP addresses, the date and time of their visit or order, the number of visits and orders, the number of visits per browsing session, the server type, the operating system and browser type used to come to the site, the country, state, and telephone area code where their servers are located, the pages and page titles of our site that visitors viewed during their visit, whether the visitor’s computer is enabled for Java or cookies, browser language, applications and plug-ins, and any search terms entered on Proper. We may also collect and store data that may be considered personal medical information, including regarding orders you prepare to place or actually place through any of the Transactable Sites.
b. For individuals making purchases through the Transactable Sites, we may collect personal information that is reasonably necessary for third-party sellers to ship the products to you, verify your identity and eligibility to receive such products or services, and to communicate with you regarding purchases and any issues that may arise in connection with your purchase. This personal information includes your “ship to” information and your e-mail address. For product vendors and listing clients, we may collect information that is reasonably necessary for users to communicate with you regarding the purchases and shipment of goods and services purchased from you and any issues that may arise in connection with their purchase. This personal information includes the seller information provided during your listing or vendor registration and your e-mail address. When you make a purchase through the Transactable Sites, we may collect and maintain personal information from you, such as your name, e-mail address, billing address, shipping address, telephone number, product selections, credit card or other payment information, order number, referring URL, IP address, page you bought from, and a password. We collect this information, and other personal information as disclosed in this Privacy Policy, in order to facilitate the fulfillment of your order, to facilitate the communication with you about your order, and to send you promotional materials. Before confirming your order, you will have the opportunity to review the product order form and make changes and additions to the information it contains, and these changes will be automatically kept for future use. We may require additional verifications or information from you before accepting any order.
5. Activity: We may store information about your use of the Websites or Services, such as your search activity, the pages you view, the actions you take, the date and time of your visit, businesses you call or e-mail using our mobile applications, and purchases you make through the Transactable Sites. We also may store information that your computer or mobile device provides to us in connection with your use of the Websites, Services, or Transactable Sites, such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, phone number, unique device identifier, advertising identifier, location (including geolocation, beacon based location, and GPS location), and requested and referring URLs. You may be able to disallow our use of certain location data through your device or browser settings, for example by disabling “Location Services” for the Proper application in iOS privacy settings. We note that disabling Location Services may adversely impact the Website or Services experience and functionality and enabling such services may be necessary in some cases to allow certain transactions.

3. COOKIES
We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Websites or Services, third-party websites, Transactable Sites, and mobile applications. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in e-mails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Websites or Services, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

Our uses for these technologies fall into one of the following general categories:

1. Operationally Necessary: We may use cookies, web beacons, or other similar technologies that are required for the proper operation of our Websites, Services, and relevant applications, features, and tools. This includes technologies that allow you to access our Service, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity, and improve security; or that allow you to use our other ancillary functions such as shopping carts, saved searches, or similar features.
2. Performance-Related: We may use cookies, web beacons, or other similar technologies to assess the performance of our Websites, Services, and relevant applications, features, and tools, including, as part of our analytic practices, (i) to help us understand how our visitors use our Websites, (ii) to determine if you have interacted with our messaging, (iii) to determine whether you have viewed an item or link, (iv) to improve our Website content, applications, products, Services, or tools, and (v) to create new Website content, applications, products, Services, or tools.
3. Functionality-Related: We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Websites, applications, products, Services, features, and tools. This may include identifying you when you sign into our Websites or Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Websites or Services or create new Website content, applications, products, Services, features, or tools.
4. Advertising or Targeting-Related: We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third-party sites. This involves using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
5. New Products and Services: We may use cookies, web beacons, or other similar technologies to help develop new content, Websites, applications, products, Services, features, and tools. This may include keeping track of your preferences, interests, and behaviors and data relating to advertisements that have been displayed to you or that you have clicked on.

Managing Cookies: It may be possible to disable some (but not all) Cookies through your device or browser settings, but doing so may affect the functionality of the Websites, Services, and Transactable Sites. The method for disabling Cookies may vary by device and browser, but can usually be found in preferences or security settings. For flash cookies, you can manage your privacy settings by visiting the Adobe Macromedia site, located here.

4. THIRD PARTIES
Third parties may receive information about you as follows:

1. Advertisers: We may allow third parties to use Cookies through the Websites or Services to collect the same type of information for the same purposes that Proper does for itself. In doing so, Proper adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Third parties may be able to associate the information they collect with other information they have about you from other sources. We do not necessarily have access to or control over the Cookies they use, but you may be able to opt out of some of their practices by visiting the following links: Network Advertising Initiative, Omniture, and Digital Advertising Alliance. Please note that opting out does not prevent the display of all advertisements to you. Additionally, we may share non-personally identifiable information from or about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common User Account identifier (such as an e-mail address), to facilitate the display of targeted advertising. You may be able to limit our sharing of some of this information through your mobile device settings, as described in Section 2 above.
2. Service Providers: We may rely on third-party providers to support or provide some of the features and options that are available through the Websites, Services, or Transactable Sites. We may also rely on third-party providers to perform certain services for us in connection with your use of the Websites or Services, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, our own marketing of the Websites or Services, promotional and contest features, Transactable Sites’ product listings and brand management, and other functions. We may share information from or about you with these third-party providers so that they can perform their services or complete your requests. These third-party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third-party providers may also share this information with their subsidiaries, joint ventures, affiliates, partners, or other companies under common control. Some of our web pages utilize framing techniques to serve content to you from our third-party providers, while preserving the look and feel of the Websites or Services. In such cases, please note that the information you provide is being provided to the third party.
3. Aggregate Information: We may share user information in the aggregate with third parties, such as advertisers, brand managers, and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertisements, or certain products available in the Transactable Sites or the general characteristics of such users.
4. Business Transfers: We may share information from or about you with our subsidiaries, affiliates, partners, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy. If another company acquires Proper or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information, as described in this Privacy Policy.
5. Businesses on Proper: We may share information from or about you (such as your age and gender, your devices, and your use of the Websites, Services, and/or Transactable Sites (such as which businesses you bookmark or call)) with businesses listed on Proper. You may adjust your settings to increase or decrease the amount of information we share. Keep in mind that businesses may see your Public Content (as defined in Section 2 above) and receive information about your transactions with them in the Transactable Sites, regardless of your settings. Additionally, if you make a phone call to a business through or in connection with your use of the Websites or Services, we may share basic information about your call with the business that you contacted, such as the date and time of your call and your phone number (and other information that would have been available to the business had you contacted them directly, and not through the Websites or Services). You may be able to limit our ability to collect and share your phone number through your phone’s settings or phone service provider.
6. Investigations: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (a) is reasonably necessary to comply with federal, state, or local legal process and legally binding law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Websites, Services, or Transactable Sites; or (c) protects our rights, reputation, property, or that of our users, affiliates, clients, partners, or the public, such as disclosures in connection with our Consumer Alerts program. If you flag or otherwise complain to Proper about content available through the Websites, Services, or items on the Transactable Sites, we may share the substance of your complaint with the contributor of that content or product in order to provide an opportunity for the contributor to respond and/or remedy the situation.
7. Links: The Websites or Services may contain links to unaffiliated third-party services. Except as set forth herein, we do not share your personal information with them and are not responsible for their privacy practices. We suggest you read the privacy policies on or applicable to all such third-party services. Some portions of the Websites and Services use the Google Maps API and this Privacy Policy therefore incorporates Google’s Privacy Policy by reference.
8. Sweepstakes, Contests and Promotions: We may sometimes offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Websites or Services that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including allowing the sponsor of the Promotion to use your name, voice, and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
Please Note: If you agree to accept a Promotion from our third-party service providers or any third-party merchant, then you will receive e-mails separately from them and all information that you choose to disclose to them will be subject to their individual and separate privacy policies. If you later decide that you no longer want to receive their e-mails, then you will need to follow their own specific opt-out instructions. Following our directions for opting out of e-mail notifications and disclosure of personal information will not opt you out of third-party disclosures and related promotional communications.

5. CHANGES TO YOUR PROFILE AND EMAIL PREFERENCES
We believe you should have the ability to access and edit the personal information you provide to us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information that was provided as part of your registration with our Websites or Services. The Websites or Services may allow you to review, correct, or update personal information you have provided through the Websites or Services’ forms or otherwise. We will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Also, any public postings or other communications you have made on the Websites or Services such as in forums or blogs cannot generally be removed. When you edit your personal information or change your preferences on the Websites or Services, information that you remove may persist internally for our own administrative purposes.

You may cancel or modify the e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your User Account and changing your communication preferences. This will not affect subsequent subscriptions, and if your opt-out preferences are limited to certain types of e-mails, the opt-out will be so limited. Subsequent or different subscriptions will remain unaffected. Please note that we reserve the right to send you certain communications relating to your User Account or use of our Websites or Services, such as administrative and service announcements, and these transactional User Account messages may be unaffected even if you choose to opt out from receiving our marketing communications.

For those users utilizing the Transactable Sites’ online ordering feature, you can review, change, or delete the information you have submitted. You may ask to have information on your User Account deleted or removed; however, because we keep track of past purchases, you cannot delete information associated with past purchases. Also, as a security measure, we “back up” the data stored on our systems, ensuring that such prior information cannot be completely removed from our databases. As a result, you should not expect that all of your personal information will be completely removed from our backed-up or archived databases.

6. DATA RETENTION AND USER ACCOUNT TERMINATION
After you have confirmed the closing of your User Account we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Websites, Services, or Transactable Sites or to comply with legal obligations. Please note that if a business is removed, and then reinstated at a later date, it will retain all of its previous reviews, ratings, and associated comments.

7. CUSTOMER DATA
As part of using the Services, users may submit electronic data or information they possess about their customers to the Websites and/or Services (“Customer Data”) for various purposes, including hosting and processing purposes in connection with the Services. Customer Data may include personal information, including, but not limited to, the name, location, and e-mail address of such customer. Any uses of the Customer Data by Proper are conducted pursuant and subject to the terms of Proper’ Terms of Use and this Privacy Policy, or as required by law. If personal information pertaining to you as an individual has been submitted to us by a user of any of the Services as Customer Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the user (or his/her organization) directly. If an authorized user requests that we update or remove the Customer Data in question and the user has no ability to do so via use of the Services, we will acknowledge their request within 30 days. All inquiries relating to this Section 7 should be directed to us in accordance with Section 10 below.

8. CHILDREN USING THE WEBSITES OR SERVICES
The Websites or Services are intended for adults only and require that users be no less than twenty-one (21) years of age. Individuals under the age of twenty-one (21) are prohibited from creating a User Account and profile, accessing the Websites or Services, and/or purchasing products on the Transactable Sites. If you become aware that an underage user has created a User Account using false, stolen, or otherwise misleading information, please contact us immediately at support@aproperhigh.com.

9. SECURITY
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. This includes using Secure Sockets Layer (SSL) software, which is software that encrypts the information you input. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Within the Transactable Sites, your information is kept on password-protected, limited access servers. Wherever possible and applicable, the Transactable Sites’ servers reside behind a corporate firewall that maintains controls on access to the system from both our internal network and the Internet.

10. CONTACT INFORMATION
If you believe that Proper has not adhered to this Privacy Policy, you may contact us via e-mail at support@aproperhigh.com.

11. INTERNATIONAL DATA TRANSFER
If you are located outside of the United States, please be aware that information we collect, including, but not limited to, personal information, will be transferred to, and processed, stored, and used within the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Websites or Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing, and storage of your information, including personal information, in the United States as set forth in this Privacy Policy.

Please note that we take the privacy of our users seriously and therefore take steps to safeguard your personal information, including assuring an adequate level of data protection in accordance with international standards. If you would like additional information about your personal data and its use in connection with the Websites and Services, including revising any incorrect information, please contact the Data Privacy Manager at the address in Section 10 above. We will take such steps as we deem necessary to confirm your identity before sharing any personal data with you. We will attempt to respond to proper and confirmed requests relating to personal data within thirty (30) days, or as otherwise required by applicable law. If you are not satisfied with the way your request was handled, you may refer your request to your country’s data management authority. In the European Union, any such request should be directed to the Data Protection Authority in your EU Member State.

12. YOUR CALIFORNIA PRIVACY RIGHTS

Proper (“Temerity Media” or the “Company”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Proper’s services 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, aproperhigh.com (the “Website”) and related services have collected the following categories of Personal Information from its Users within the last twelve (12) months:

Category Examples Collected

A. Identifiers. 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. [NO]

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 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, or any other financial information, medical information, or health insurance information.

Some Personal Information included in this category may overlap with other categories. [NO]

C. Protected classification characteristics under California or federal law. 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). [NO]

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

E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or 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, or other physical patterns, and sleep, health, or exercise data. [NO]

F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. [YES]

G. Geolocation data. Physical location or movements. [YES]

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. [NO]

I. Professional or employment-related information. Current or past job history or performance evaluations. [NO]

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)). 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. [NO]

K. Inferences drawn from other Personal Information. Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. [YES]

Personal information does not include:

* Publicly available information from government records.

* Deidentified or aggregated consumer information.

* 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.

Information Sources

Proper obtains the categories of Personal Information listed above from the following categories of sources:

* Directly from you. For example, from forms you complete or products and services you purchase.

* Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use, sell, or disclose the Personal Information we collect for one or more of the following business purposes:

* To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry.  If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery.  We may also save your information to facilitate new product orders or process returns.

* To provide, support, personalize, and develop our Website, products, and services.

* To create, maintain, customize, and secure your account with us.

* To process your requests, purchases, transactions, and payments and prevent transactional fraud.

* To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

* To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

* To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

* For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

* To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

* As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

* To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Proper’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Proper about our Website users is among the assets transferred.

* Proper 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.

Sharing Personal Information

Proper may disclose your Personal Information to a third party for a business purpose or sell your Personal Information, subject to your Right to Opt-Out (defined below) of those sales (see Personal Information Sales Opt-Out and Opt-In Rights, below).  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 use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your Personal Information with the following categories of third parties:

* Service providers.

* Data aggregators.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Proper has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers. [NO]

Category B: California Customer Records Personal Information categories. [NO]

Category C: Protected classification characteristics under California or federal law. [NO]

Category D: Commercial information. [YES]

Category E: Biometric information. [NO]

Category F: Internet or other similar network activity. [NO]

Category G: Geolocation data. [YES]

Category H: Sensory data. [NO]

Category I: Professional or employment-related information. [NO]

Category J: Non-public education information. [NO]

Category K: Inferences drawn from other Personal Information. [YES]

 

Sales of Personal Information

In the preceding twelve (12) months, Proper has sold the following categories of Personal Information:

Category A: Identifiers. [NO]

Category B: California Customer Records Personal Information categories. [NO]

Category C: Protected classification characteristics under California or federal law. [NO]

Category D: Commercial information. [YES]

Category E: Biometric information. [NO]

Category F: Internet or other similar network activity. [NO]

Category G: Geolocation data. [YES]

Category H: Sensory data. [NO]

Category I: Professional or employment-related information. [NO]

Category J: Non-public education information. [NO]

Category K: Inferences drawn from other Personal Information. [YES]

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information.  This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Proper 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 (see Exercising Access, Data Portability, and Deletion Rights, below), 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).

* If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

* sales, identifying the Personal Information categories that each category of recipient purchased; and

* disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Proper 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 Exercising Access, Data Portability, and Deletion Rights), 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:

* 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.).

* 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.

* 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:

* Emailing us at info@aproperhigh.com

* 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. 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.

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.

For instructions on exercising Personal Information sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights below.

Response Timing and Format

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

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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). We do not sell the Personal Information of Users we actually know are less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt-In”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Users who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us: info@aproperhigh.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by contacting Proper at the email address or phone number provided in this notice.

You do not need to create an account with us to exercise your Right to Opt-Out.  We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.  We currently provide the following financial incentives:

COMING SOON

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@aproperhigh.com or write us at: 1507 7th Street #176 Santa Monica CA 90401

Changes to Our Privacy Notice

Proper reserves 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 notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Proper collects and uses your information described below [and in the Privacy Policy], or your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: aproperhigh.com

Email: info@aproperhigh.com

Postal Address:

Proper

Attn: Customer Support

1507 7th Street #176

Santa Monica CA 90401

You may also access our do not sell form to request your information not be sold here - https://aproperhigh.com/do_not_sell/new

13. DO NOT TRACK
Proper does track its customers over time and across third-party websites to provide intelligent advertising, and does not respond to Do Not Track (“DNT”) signals. In addition, some third-party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. Please review your web browser’s internet options for more details.

Updated March 9, 2021