Privacy Policy

This Privacy Notice (“Privacy Notice”) describes how Helium Development LLC (“Helium”) may collect information about you through your interactions with our products, services, mobile applications (the “Applications”), and websites heliumdev.com and customerfields.com (the “Sites”) (collectively, the “Services”). It is our policy to respect your privacy regarding any information we may collect while operating the Services.

By using any of Helium’s Services, you confirm you have agreed to the Terms of Service located at Terms of Service and read and understood this Privacy Notice and our Cookie Policy located at Cookie Policy. We take the privacy of users very seriously, and we will not share personal information of users in ways unrelated to those described in this Privacy Notice.

Table of Contents

1. General information
2. What Data do We Collect, and Why
3. Our Use of Your Information
4. How We Collect Your Information
5. Sharing Of Information
6. Your Choices
7. How We Protect Personal Information
8. How we Retain Your Personal Information
9. Customer’s Personal Information
10. International Data Transfers
11. Other Important Information
12. Other Jurisdictions
13. Contact Information

General information

In this Privacy Notice, when we refer to “Merchants”, we mean our merchant customers who use our Services, including without limitation visitors to our Sites. The users, visitors and customers of our Merchant’s sites or applications are referred to herein as “Customers”. Any other capitalized terms not defined in this Privacy Notice have the meanings in our Terms of Service.

This Privacy Notice describes what we do with personal information that we collect and use for our own purposes (i.e., where we are a controller), such as your account information and information about how you use and interact with the Sites and our Services, including without limitation information you submit to our customer support as well as certain information relating to Customers.

We also host and process Merchant Content on behalf of our Merchants. Our Merchants tell us what to do with Merchant Content, and we follow their instructions. This Privacy Notice does not describe what we do with Merchant Content on our Merchant’s instructions (i.e., as their processor or service provider). If you are a Customer of one of our Merchant’s and want to know how a Merchant handles your information, you should check their site’s privacy notice, if applicable. If you want to know about what we do for our own purposes, read this Privacy Notice.

If you are a Merchant, see our Data Processing Addendum to learn more about how we process Merchant Content or other personal information on your instructions or with your permission.

What data do we collect, and why

We collect various information regarding you or your device. The following provides examples of the type of information that we collect from you and how we use that information.

Merchant Information

Types of Data

We collect the name, username, and contact information, of our Merchants and their employees with whom we may interact.

Primary purpose for collection and use of data

We have a legitimate interest in contacting our Merchants and communicating with them concerning normal business administration such as projects, services, and billing. In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

Merchant User Account information

Types of Data

We collect information you provide to create an account, specifically email address, first name and last name.

Primary purpose for collection and use of data

We have a legitimate interest in providing account related functionalities to our Merchants, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to fulfill our contract to provide you with Services.

Customer User Account information

Types of Data

We collect information Customers provide to Merchants create an account, specifically email address, first name and last name. Based on how the Merchant has configured the Application, Merchants may collect additional information from Customers.

Primary purpose for collection and use of data

We have a legitimate interest in providing account related functionalities to our Customers, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to fulfill our contract to provide you with Services.

Cookies and first party tracking

Types of Data

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information.

Primary purpose for collection and use of data

We have a legitimate interest in making our Sites and Services operate efficiently.

Cookies and Third Party Tracking

Types of Data

We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our Sites and Services so that they can provide advertising about products and services tailored to your interests on our Sites, Services or on

Primary purpose for collection and use of data

We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics.

Email Interconnectivity

Types of Data

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

Primary purpose for collection and use of data

We have a legitimate interest in understanding how you interact with our communications to you.

Employment

Types of Data

If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.

Primary purpose for collection and use of data

We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.

Feedback/Support

Types of Data

We collect personal data from you contained in any inquiry you submit to us regarding our Sites or Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script.

Primary purpose for collection and use of data

We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries.

Mailing List

Types of Data

When you sign up for one of our mailing lists, we collect your email address or postal address.

Primary purpose for collection and use of data

We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

Mobile Devices

Types of Data

We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our Sites or using an Application or Services.

Primary purpose for collection and use of data

We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

Subscription Information

Types of Data

When you sign up for the Services, we collect information from Shopify including your name, billing address, e-mail address, phone number.

Primary purpose for collection and use of data

We use your information to perform our contract to provide you with products or services.

Surveys

Types of Data

When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

Primary purpose for collection and use of data

We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.

Website & Application Interactions

Types of Data

We use technology to monitor how you interact with our Services. This may include: IP addresses, preferences, web pages you visited prior to using our Applications or Services, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and Applications (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).

Primary purpose for collection and use of data

We have a legitimate interest in understanding how you interact with our Sites and Services to better improve it, and to understand your preferences and interests to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

Web logs

Types of Data

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

Primary purpose for collection and use of data

We have a legitimate interest in monitoring our networks and the visitors to our Sites. Among other things, it helps us understand which of our services is the most popular.

Our use of your information

In addition to the purposes and uses described above, we use information in the following ways:

• Provision of the Services. Create and manage your account, provide, and personalize our Services, process payments, and respond to your inquiries.
• Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.
• Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs, and promotions of Helium and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your subscription plan or what we think may interest you based on other information we hold about you.
• Advertising. Analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for paid Services or we may choose to serve you a particular advertisement based on your subscription plan or what we think may interest you based on other information we hold about you.
• Customizing the Services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information.
• Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate, and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most Merchants of paid Services use a particular integration or feature, we might wish to expand on that integration or feature.
• Security. Ensure the security and integrity of our Services. Third party relationships. Manage our vendor and partner relationships.
• Enforcement. Enforce our Terms of Service and other legal terms and policies.
• Protection. Protect our and others’ interests, rights, and property (e.g., to protect our Merchants from abuse).
• Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts, and law enforcement requests.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you sign up for Services, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your Services. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

How we collect your information

We obtain personal information from various sources. We do this in three main ways:

• When you give it us. You provide some of it directly (such as by registering for an account). For instance, we ask you to provide your name and email address to register and manage your account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.

• When you use our Services. We record some of your information automatically when you use our Services or Applications (including with technologies like cookies). we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our Sites, what pages on our Sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our applications. If you are Customer of a Merchant we may also get information about your interactions with a Merchant’s site, though we use this in anonymous, aggregated or pseudonymized form which does not focus on you individually. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services). Some of this information is collected automatically using cookies and similar technologies when you use our Services or Applications. We let our Merchants control what cookies and similar technologies are used through their sites (except those we need to use to properly provide the Services, such as for performance or security related reasons). You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.

• From Third Parties. We receive some of it from third parties like when you register for an account using a Third-Party Service. If you use a Third-Party Service (such as Shopify) to register for an account, the Third-Party Service may provide us with your Third-Party Service account information on your behalf, such as your name and email address (we don’t collect or store passwords you use to access Third Party Services). Your privacy settings on the Third-Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third-Party Service.

Sharing of information

In addition to the specific situations discussed elsewhere in this Privacy Notice, we share personal information in the following ways:

• Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
• Merchants. We share with our Merchants data regarding usage by Customers of their sites. For example, we provide a Merchant with information about how a Customer interacted with their site. This is so Merchants can analyze the usage of their sites and improve their services.
• Business partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third-Party Services, but only when you have been informed or would otherwise expect such sharing.
• Third Party Plugins and Social Networks. We may share personal information with website plugins, social media platforms or similar Third-Party Services to improve your experience, at your direction, or when you intentionally interact with the plug-in. For example, when you use a Third-Party Service to create or log in to your account, we may share your personal information with that Third Party Service.
• Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage. See our Subprocessors
• Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of Helium or our Merchants or Customers. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
• Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third-party social media platform on which we advertise to avoid serving Helium ads to people who already use Helium.
• Business transfers. If we’re involved in a reorganization, merger, acquisition, or sale of some or all of our assets, your personal information may be transferred as part of that deal or the negotiation of contemplated deals.

Your choices

You can make the following choices regarding your personal information:

1. Access to your personal information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. We will provide this information in a portable format, if required. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
2. Changes to your personal information. We rely on you to update and correct your personal information. Our Sites allow you to modify or delete your account profile. If our Sites do not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
3. Deletion of your personal information. As described below, we retain your personal information for the period necessary to provide the Services, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
4. Objection to certain processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
5. Online tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
6. Promotional emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
7. Revocation of consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Please address written requests and questions about your rights to privacy@heliumdev.com.

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:

1. A completed written notice indicating that you have authorization to act on the consumer’s behalf signed by you and the consumer.
2. If you are a business, proof that you are registered with the appropriate Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

How we protect personal information

While no service is completely secure, we have a security team dedicated to keeping personal information safe from alteration, disclosure and/or destruction. Helium has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Your account is protected by password for your privacy and security. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

Because the internet is not a completely secure environment, Helium cannot warrant the security of any information a user transmits to Helium or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. User is responsible for maintaining the secrecy of its unique password and account information, and for controlling access to emails between a user and Helium, at all times. Users should limit access to its computer and/or mobile device and/or browser and sign off after a user has finished accessing its account. We are not responsible for the functionality, privacy and/or security measures of any other organization and are not responsible for the practices employed by any websites and/or services linked to and/or from the Services, including the information and/or content contained therein.

How we retain your personal information

Generally, we will hold your personal data for as long as you are a customer and use Services to ensure accuracy and to help maintain quality of service or if we are obliged to retain such information for legal, regulatory, fraud prevention and legitimate business purposes.

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice to a user. We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide Helium with requested information, you may not be able to use and/or access all of the Services. You can request further details of retention periods for different aspects of your personal data by contacting us.

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.

Customer’s personal information

Our Merchants who use the Services are responsible for what they do with the personal information they collect, directly or through Helium, about their Customers. This Section is directed to such Customers.

• Merchant relationship with Customers. If you are one of our Merchants, you will collect personal information about Customers. For example, you may ask Customers to provide their name, address, email address and payment information so that you can complete their orders. You may also use cookies and similar technologies to analyze usage and other trends. You are solely responsible for complying with any laws and regulations that apply to your collection and use of Customer’s information, including personal information you collect about them from us or using Helium functionality or cookies or similar technologies. You must publish your own privacy and cookie policies and comply with them. We’re not liable for your relationship with Customers or how you collect and use personal information about them (even if you collect it from us or using Helium functionality or cookies or similar technologies) and we won’t provide you with any legal advice regarding such matters.

• Helium’s relationship with Customers of the Merchant. As described in the Data Processing Agreement, Helium functions as a processor or subprocessor as determined by the function of Merchant. Helium does not sell or use for advertising purposes any personal information collected from Customers.

International data transfers

We are a global business. The personal data which we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including the United States of America. You acknowledge the transfer to, and storing, or processing outside of the EEA, of your personal data as set out in this Privacy Notice.

If you are located in the EEA, the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your data to the US. Where applicable law requires that a data transfer legal mechanism, we use one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal method available to us under applicable law.

Your personal data may also be processed by staff operating outside the EEA and Switzerland who work for us, one of our Merchants, or one of our third-party service providers. Such staff may be engaged in, among other things, the fulfilment of your transaction, the processing of your payment details, improving our Websites and Services, technical support, fraud review, and the provision of other support services. Helium will take all reasonably necessary steps to ensure that where your personal data is transferred, it is treated securely and in accordance with this Privacy Notice.

While no-longer self-certified, Helium continues to adhere to the principles of the US-EU Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from EEA member countries collected during the period Helium was certified. Helium does not rely on these frameworks for the transfer of personal data to the U.S.

Other important information

The following additional information relates to our privacy practices:

• Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
• Children. The Sites and Services is not directed at children, and we do not knowingly collect personal information directly from users under the age of 13 or from other web sites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will not knowingly request or collect personal information from any child under age 13 without obtaining the required parental consent.
• Changes to this privacy notice. We reserve the right to change this Privacy Notice at any time. Any changes to the Privacy Notice will be either posted on this page or communicated to you in writing by us, where we are legally required to do so. Changes to this Privacy Notice shall be applicable on the effective date set out in the updated Privacy Notice. The latest version of this Privacy Notice will be available to view on our Sites.
• Conflict between this privacy notice and our terms of service or other terms. Where there is a conflict between this Privacy Notice and an explicit provision of the Terms of Service, this Privacy Notice will prevail over those other Terms.
• Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.

Other jurisdictions

Personal information that you submit through the Services may be transferred to countries other than where you live. We also store personal information locally on the devices you use to access the Services. Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. The following provisions may apply to you depending on where you are located.

European Economic Area (EEA) and the United Kingdom (UK)

Transmission Of Information To Other Countries.

Our service providers and other third parties you may interact with in connection with our Services may be located in the United States and other countries around the world. To the extent personal information is collected and subsequently transferred out of the EEA, the transfer will take place consistent with:

The Standard Contractual Clauses. We transfer, in accordance with Article 46 of the GDPR, personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.

Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding, enforceable commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.

Complaints. If you are a resident of the EEA, and believe we process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. To exercise your privacy rights set forth in this Privacy Notice, you may contact us as set forth in the Contact us section.

Nevada

This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing customers, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at privacy@heliumdev.com or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov.

Texas

If you have a complaint, first contact us by visiting our Site at privacy@heliumdev.com. If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity, please direct your complaint to the Texas Department of Banking: 2601 North Lamar Boulevard, Austin, TX 78705-4294; 1-877-276-5554 (toll free); www.dob.texas.gov.

Vermont

In accordance with Vermont law, we will not share information we collect about you with companies outside of Helium except as required or permitted by law. For example, we may share information to service your accounts, complete requested transactions, or to provide rewards or benefits to which you are entitled.

California – California Consumer Privacy Act (“CCPA”)

This Section applies solely to all visitors, users, and others who reside in the State of California, and only applies to personal information for which Helium is a “Business” (as defined in the CCPA). This does not apply to personal information we collect from you in the course of our provision of services to you where you are an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. It applies to personal information we collect from California Residents on or through our Services and through other means (such as information collected offline or in person). Any terms defined in the CCPA have the same meaning when used in this notice.

Our Website collects 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”). What Data Do We Collect and Why? section describes the personal information we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the Our Use of Your Information section. Helium uses cookies, including advertising cookies, as described in our Cookie Policy.

A. IDENTIFIERS

Examples: 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.

Is this collected? YES

B. PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE § 1798.80(E))

Examples: 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.

Is this collected? YES

C. PROTECTED CLASSIFICATION CHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LAW

Examples: 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).

Is this collected? YES

D. COMMERCIAL INFORMATION

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

Is this collected? YES

E. BIOMETRIC INFORMATION

Examples: 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.

Is this collected? NO

F. INTERNET OR OTHER SIMILAR NETWORK ACTIVITY

Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Is this collected? YES

G. GEOLOCATION DATA

Examples: Physical location or movements.

Is this collected? NO

H. SENSORY DATA

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Is this collected? NO

I. PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION

Examples: Current or past job history or performance evaluations.

Is this collected? 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))

Examples: 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.

Is this collected? NO

INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Is this collected? NO

Your Rights and Choices.

• Right to know - You have the right to request disclosure about our personal information collection practices during the prior 12 months, including the categories of personal information we collected, the sources of the information, our business purposes for collecting or sharing the information and the categories of third parties with whom we shared such information; You may request a copy of the specific pieces of personal information we may have collected about you in the last 12 months.
• Right to Delete - You may request that we delete (and direct our service providers to delete) your personal information, subject to certain exceptions.
• Right to Opt-Out - You have the right to opt-out of any “sales” of your personal information, if a business is selling your information
• Non-Discrimination - You have the right to not be discriminated against for exercising these rights. Unless permitted by the CCPA, we will not: i) deny you goods or service; ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, iii) provide you a different level or quality of goods or services, or iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Rights

If you have questions or concerns about this, we want to talk with you. To exercise your rights described above, please submit a verifiable consumer request to us as described in the Contact Us section. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Verifiable Consumer Request. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. You may be required to provide additional information necessary to confirm your identity before we can respond to your request, and we will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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 (up to 90 days), we will inform you of the reason and extension period in writing. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

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, specifically via secure email. For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if (1) the information is necessary for us to (a) complete a transaction for you or otherwise perform a contract; or (b) detect, protect against, or prosecute security incidents, fraud or illegal activity; (2) we use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and (3) we are required to retain the information to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.

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.

Using an Authorized Agent

You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us, and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Sales of Personal Information

Helium does not sell or lease the data we collect and does not disclose your information for other valuable consideration. In the preceding twelve (12) months, Helium has not sold your personal information. If, in the future, we enter into arrangements that fall within the definition of a “sale” under the CCPA, we will update this Privacy Notice and our compliance with the CCPA. While Helium does not sell personal information, by law, we have to provide this a opt-out link: Do Not Sell My Personal Information . You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

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, see Contact Information below

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

privacy@heliumdev.com
ATTN: Privacy Feedback
6659 Kimball Drive
Ste. D402
Gig Harbor, WA 98335

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority as set forth in this Privacy Notice.