Privacy Policy
Last updated: 06 July 2026
This Privacy Policy explains what personal information we collect when you use our website at entire.io or other services ("our services"), how we use and share that information, and what rights you have.
By using our services, you agree to the collection and use of information in accordance with this Privacy Policy.
When we say "we", "us" or "our" in this Privacy Policy, that means Entire Inc, registered in the State of Delaware, United States.
"you" means the individual accessing or using our services (or the company or other legal entity on behalf of which you are accessing or using our services, as applicable).
When we refer to "personal information" we mean any information that relates to an identified or identifiable individual, including information that is "personal data" under the European GDPR and UK GDPR and/or "personal information" under the Californian CCPA (see the GDPR and CCPA specific sections of this Privacy Policy below). We refer to "personal data" in the GDPR sections, as that's the terminology defined and used in the GDPR.
Where we process personal information on behalf of an organization — for example, an organization that provisions accounts for its members or that owns repositories on our services — under a Data Processing Agreement or similar terms, that organization is the controller of that personal information and we act as its processor. In those cases the organization's own privacy notice and its agreement with us govern that processing, and you should direct privacy requests to the organization. This Privacy Policy describes the personal information we process as a controller.
1. Collecting and Using Your Personal Information
1.1 Types of Data Collected
(a) Personal Information
While using our Service — or when you contact us, register for an event, or otherwise inquire about or express interest in our services — we may ask you to provide us with certain personal information that can be used to contact or identify you, for example your name and email address.
(b) Usage Data
Usage data (i.e. data generated by the use of our services or from our services infrastructure itself (for example, the duration of a page visit) is collected automatically when using our services.
usage data may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access our services by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our website or when you access our services by or through a mobile device.
(c) Information from sign-in providers
We allow you to create an account and log in to use our services through third-party sign-in providers. These include GitHub and, through our authentication provider, identity providers such as Google and Microsoft and, for organizations, single sign-on (SSO). If you register or log in through one of these providers, or otherwise grant us access to your account with them, we may collect personal information already associated with that account, such as your name, username, and email address, and (in the case of GitHub) your public profile and activity associated with that account.
You may also have the option of sharing additional information with us through these accounts. If you choose to provide such information and/or personal information, during registration or otherwise, you are giving us permission to use, share, and store it in a manner consistent with this Privacy Policy.
(d) Imported content from third-party sources
If you authorize us to import, mirror, or synchronize Content from a third-party source (for example, a code hosting provider such as GitHub), (called "imported content") we receive and process imported content on your behalf. Imported content may include repository files and contents, commit messages and metadata, issue and pull request titles, descriptions and comments, branch and release metadata, and similar materials made available by the third-party source.
Imported content may contain personal information relating to individuals other than you — for example, the names, email addresses, and usernames of co-contributors, commit authors, issue participants, and reviewers associated with repositories you authorize us to access. We receive this personal information from the third-party source as a necessary consequence of operating the import, mirror, or synchronization you have directed.
Purposes and legal basis. We process imported content to provide and operate our services on your behalf and to perform the integration you have authorized. For purposes of the GDPR, we rely on the performance of a contract with you and, with respect to third-party personal information contained in imported content, on our legitimate interests in operating our services you have requested, balanced against the rights of those third parties. Where required, we will assist you in identifying a lawful basis appropriate to your use of imported content.
Retention and deletion. imported content is retained in accordance with the "Retention of your personal information" section. Revoking your authorization for a third-party source stops future import, mirror, or synchronization from that third-party source; it does not by itself delete imported content that has already been received. You may request deletion of imported content by contacting us at the address in the "Contact us" section.
Rights of third parties. Individuals whose personal information appears in imported content (such as co-contributors) may exercise rights with respect to that personal information. Where we hold such personal information solely as a result of your authorization, you remain primarily responsible for responding to such requests, and we will, on request and where reasonably practicable, assist in forwarding or responding to such requests in accordance with applicable law. Contact: legal@entire.io.
Your responsibilities. You are responsible for ensuring that your authorization of the import, mirror, or synchronization is consistent with your agreements with the third-party source and with any organization, enterprise, or access-control policies that apply. See the "third-party source Integrations" section of our Terms of Service.
(e) Cookies and other Tracking Technologies
We use small files placed on your device known as 'cookies' and similar tracking technologies to track the activity on our services and store certain information. Tracking technologies we use include beacons, tags, and scripts to collect and track information and to improve and analyze our services. The technologies we use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our services.
- Web Beacons. Certain sections of our services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent Cookies" or "Session Cookies". Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
Where required by law, we use non-essential cookies (such as analytics, advertising, and remarketing cookies) only with your consent. You can withdraw or change your consent at any time using our cookie preferences tool (if available) or through your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.
We use both Session and Persistent Cookies for the purposes set out below:
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Necessary / Essential Cookies
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Type: Session Cookies
Administered by: us
Purpose: These Cookies are essential to provide you with services available through our website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
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Cookies Policy / Notice Acceptance Cookies
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Type: Persistent Cookies
Administered by: us
Purpose: These Cookies identify if users have accepted the use of cookies on our website.
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Functionality Cookies
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Type: Persistent Cookies
Administered by: us
Purpose: These Cookies allow us to remember choices you make when you use our website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use our website.
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Tracking and Performance Cookies
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Type: Persistent Cookies
Administered by: Third Parties
Purpose: These Cookies are used to track information about traffic to our website and how users use our website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our website. We may also use these Cookies to test new pages, features or functionality of our website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
1.2 Use of Your Personal Information
We may use personal information for the following purposes:
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To provide and maintain our services, including to monitor the usage of our services.
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To manage your account: to manage your registration as a user of our services. The personal information you provide can give you access to different functionalities of our services that are available to you as a registered user.
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For the performance of a contract: the development, compliance and undertaking of the purchase contract for the services you have purchased or of any other contract with us through our services.
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To contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
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To send you sales and marketing communications: such as news, events, and general information about our services, where you are a user of, or have inquired about or expressed interest in, our services. We send these communications only where you have opted in to receive them, and you can withdraw your consent at any time.
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To manage your requests: To attend and manage your requests to us.
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For business transfers: We may use your personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
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For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services, products, services, marketing and your experience.
We may share your personal information in the following situations:
- With our service providers: We may share your personal information with our service providers to provide and operate our services, to monitor and analyze the use of our services, and to communicate with you, including by email.
- For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
- With our subsidiary companies: We may share your personal information with subsidiary companies, in which case we will require those affiliates to honor this Privacy Policy.
- With other users: If our services offer public areas, when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. Where our services provide user profiles, other users may be able to view your profile, including your name, username, and a summary of your activity on our services.
- With your consent: We may disclose your personal information for any other purpose with your consent.
2. Retention of Your Personal Information
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Where possible, we apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and we may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of personal information based on the purpose of processing and legal obligations:
- Repository content
- Git repository data you post or import — including files, commit history, and the names and email addresses recorded in commit metadata — is retained for as long as the relevant repository exists on our services, and is deleted when the repository (or the relevant history) is deleted. Because a repository's history is an immutable record of your project, we generally cannot remove individual entries from it while the repository exists.
- Account Information
- user accounts: retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes.
- Customer Support Data
- Support tickets and correspondence: up to 24 months from the date of ticket closure to resolve follow-up inquiries, track service quality, and defend against potential legal claims
- Chat transcripts: up to 24 months for quality assurance and staff training purposes.
- Usage Data
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Website analytics data (cookies, IP addresses, device identifiers): up to 24 months from the date of collection, which allows us to analyze trends while respecting privacy principles.
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Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting purposes.
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Usage data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.
We may retain personal information beyond the periods stated above for different reasons:
- Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
- Legal claims: Data is necessary to establish, exercise, or defend legal claims.
- Your explicit request: You ask us to retain specific information.
- Technical limitations: Data exists in backup systems that are scheduled for routine deletion.
You may request information about how long we will retain your personal information by contacting us.
When retention periods expire, we securely delete or anonymize personal information according to the following procedures:
- Deletion: Personal information is removed from our systems and no longer actively processed.
- Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
- Anonymization: In some cases, we convert personal information into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.
3. Data Residency and Location of Processing
We aim to store and process your personal information within your own jurisdiction rather than transferring it elsewhere.
Because you may use our services from, or act across, more than one jurisdiction, some personal information generated by your activity in a particular jurisdiction may be stored in that jurisdiction. In addition, we store your user activity data in your home jurisdiction (the jurisdiction in which your account was created) so that your account and activity remain available to you.
Where any storage or processing does take place outside your jurisdiction — for example, because a service provider we use operates across regions — we will ensure it is subject to appropriate safeguards and that your personal information is treated securely and in accordance with this Privacy Policy.
4. Right to delete Personal Information
You have the right to delete or request that we assist in deleting the personal information that we have collected about You.
Our services may give you the ability to delete certain information about you from within our services.
you may update, amend, or delete your information at any time by signing in to your account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information that you have provided to us.
Some personal information forms part of the content you post to or import into our services — for example, the author and committer names and email addresses recorded in commit metadata. This information is retained for as long as the relevant repository exists and is removed when the repository (or the relevant history) is deleted; because a repository's history is an immutable record, we may be unable to delete individual entries from it while the repository exists.
Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.
5. Disclosure of Your Personal Information
(a) Business Transactions
If Entire is involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.
(b) Law enforcement
Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
(c) Other legal requirements
We may disclose your personal information in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend our rights or property
- Prevent or investigate possible wrongdoing in connection with our services
- Protect the personal safety of users of our services or the public
- Protect against legal liability
6. Security of Your Personal Information
The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security.
7. Detailed Information on the Processing of Your Personal Information
Our service providers may have access to your personal information. These third-party vendors collect, store, use, process and transfer information about your activity on our services in accordance with their Privacy Policies.
We may use service providers to operate and secure our services (including authentication), to monitor and analyze the use of our services, and to send communications such as marketing emails.
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PostHog
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Their Privacy Policy can be viewed at https://posthog.com/docs/privacy/.
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Honeycomb
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Their Privacy Policy can be viewed at https://www.honeycomb.io/privacy.
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Datadog
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Their Privacy Policy can be viewed at https://www.datadoghq.com/legal/privacy/.
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HubSpot (sales and marketing communications)
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Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy.
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WorkOS (authentication and single sign-on)
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Their Privacy Policy can be viewed at https://workos.com/legal/privacy.
8. Children's Privacy
Our services are not aimed at anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.
9. Links to Other Websites
Our services may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
10. General Data Protection Regulation (GDPR)
This section 10 applies specifically in relation to the processing of personal data of individuals who are subject to the protections of the European GDPR and UK GDPR - i.e. residents of the European Economic Area ("EEA") and the UK.
In this section we refer to "personal data" instead of "personal information", because "personal data" is what's defined and referred to in the GDPR. Whilst the European GDPR and UK GDPR are not identical, they are the same in all material respects for the purpose of the provisions below, so when we refer to "GDPR" we mean both the European and UK GDPR.
To the extent of any inconsistency between the provisions of this section 10 and the other provisions of this Privacy Policy, this section 10 prevails in relation to the processing of personal data of EEA and UK residents.
10.1 Legal Basis for Processing Personal Data under GDPR
We may process personal data under the following conditions:
- Consent: you have given your consent for processing personal data for one or more specific purposes.
- Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
- Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.
- Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
- Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests that we pursue.
You can contact us to find out which legal basis applies to a specific processing activity, and whether providing your personal information is required by law or to enter into a contract.
10.2 International Transfer of Personal Data
We aim to store and process the personal data of EEA and UK residents within the EEA or the UK, consistent with the data-residency approach described in section 3.
Where personal data is nonetheless transferred outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, we rely on appropriate safeguards, such as:
- The European Commission's Standard Contractual Clauses ("SCCs") and/or the UK International Data Transfer Agreement ("IDTA") or the UK Addendum to the SCCs (as applicable)
- Supplementary measures where appropriate, such as encryption in transit and at rest, access controls, data minimisation, and vendor security reviews.
Where we do transfer personal data internationally, we do so only as needed to provide our services and to work with our service providers (for example, hosting, analytics, email delivery). You may contact us by using the details in the "Contact us" section of our Privacy Policy to request further information about the safeguards we use for international transfers, including copies of relevant contractual protections (redacted where necessary).
10.3 Your Rights under the GDPR
Entire undertakes to respect the confidentiality of your personal information and to guarantee you can exercise your rights.
You have the right under this Privacy Policy, and by law if you are within the EEA, to:
- Request access to your personal data. The right to access, update or delete the information we have on You. You can request a copy of the personal information that we hold about you. Where possible, you can also access Your data directly in your account settings. If you are unable to perform these actions yourself, please contact us to assist you.
- Request restriction of processing. You have the right to ask us to restrict processing of your personal data in certain circumstances (for example, while we verify accuracy or consider an objection).
- Request correction of the personal data that we hold about You. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
- Request the transfer of your personal data. We will provide to You, or to a third-party you have chosen, Your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with You.
- Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our services.
10.4 Exercising Your GDPR Rights
To exercise any of your GDPR rights, please contact us. We may need to verify your identity before responding. We will respond within one month and may extend by a further two months where necessary, as permitted by law. If you are in the EEA, you have the right to complain to a data protection authority about our collection and use of your personal data. If you are in the United Kingdom you have the right to complain to the Information Commissioner's Office (ICO)
11. US State Information
Sections 11 to 14 provide extra information for residents of US States that have specific privacy laws. Specifically in relation to such residents, the provisions of sections 11 to 14 take precedence over the other sections of this Privacy Policy (i.e. in the event of any inconsistency).
The rights below are common to across US State privacy laws:
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Right to Knowledge and Correction: You have the right to request details on the specific personal information we've collected about you and the right to correct inaccurate information. You can exercise this right by contacting us. You can also access and edit certain information in your account settings.
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Right to Know Data Recipients: We share your information with service providers for legitimate business operations, as described in section 1.2 above.
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Right to request Deletion: You reserve the right to request the deletion of your personal; information (with a few exceptions - e.g. where we're required to retain information to comply with legal obligations or detect fraudulent activity or other violations of our Terms of Service. Upon receiving your verified request, we will promptly delete your personal information (unless an exception applies), and instruct our service providers to do the same.
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Right to a Timely Response: You are allowed to make two free requests in any 12-month period. We commit to responding to your request within 45 days. In complex cases, we may extend our response time by an additional 45 days.
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Non-Discrimination: We will not treat you any differently if you exercise your privacy rights.
We may collect various categories of personal information about our website visitors and users of our services, as described in detail in section 1 above. Section 1 also describes the purposes for which we collect your personal information.
To make an access, deletion, correction, or opt-out request, please send an email to us at legal@entire.io. We may need to verify your identity before processing your request. If you choose to use an authorized agent to submit a request on your behalf, please ensure they have your signed permission or power of attorney as required.
12. California Residents
12.1 CCPA/CPRA Privacy Notice (California Privacy Rights)
In this section 12:
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CCPA and/or CPRA refers to the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (the "CPRA"); and
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Consumer means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
12.2 Categories of Personal Information Collected
We 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. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if you provided such personal information directly to us.
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Category A: Identifiers.
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Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes.
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Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
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Examples: A name, signature, 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.
Collected: Yes.
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Category C: Protected classification characteristics under California or federal law.
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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).
Collected: No.
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Category D: Commercial information.
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Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: No.
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Category E: Biometric information.
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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.
Collected: No.
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Category F: Internet or other similar network activity.
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Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected: Yes.
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Category G: Geolocation data.
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Examples: Approximate physical location, physical location or movements.
Collected: No.
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Category H: Sensory data.
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Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
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Category I: Professional or employment-related information.
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Examples: Current or past job history or performance evaluations.
Collected: No.
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Category 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)).
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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.
Collected: No.
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Category K: Inferences drawn from other personal information.
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Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
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Category L: Sensitive personal information.
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Examples: Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.
Collected: No.
Under CCPA/CPRA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA/CPRA's scope, such as:
- 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
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from You. For example, from the forms you complete on our services, preferences you express or provide through our services.
- Indirectly from You. For example, from observing your activity on our services.
- Automatically from You. For example, through cookies we or our services Providers set on your device as you navigate through our services.
- From service providers. For example, third-party vendors to monitor and analyze the use of our services, or other third-party vendors that we use to provide our services to You.
Use of Personal Information
We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
- To operate our services and provide you with our services.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our services.
- To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our services, we will use that personal information to respond to your inquiry.
- 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/CPRA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
- Other purposes consistent with the context in which the information was collected, or as otherwise disclosed to you at the time of collection.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Information" section.
If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.
Disclosure of Personal Information
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
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Category A: Identifiers
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Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
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Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When we disclose personal information for a business purpose or a commercial 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.
Sharing of Personal Information
We may share, and have shared in the last twelve (12) months, your personal information identified in the above categories with our subsidiary companies, service providers, business partners and third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Sale of Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by us to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not "sell" or "share" information as most people would commonly understand these terms – meaning we do not, and will not, disclose your personal information in direct exchange for money or some other form of payment.
We allow our service providers to use your personal information for the business purposes described in our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a "sale" under CCPA/CPRA. For example, when we promote our services, we use service providers that market our services online, measure the marketing efforts, identify users that are interested in our services, etc. This is done by placing tracking technologies on our website such as cookies, tags, pixels, or similar, and by placing these technologies, online identifiers and online behavior information is shared with such vendors, including for "cross-context behavioral advertising". Under the CCPA, these practices are defined as "sharing" or "selling" personal information.
We may disclose or may have disclosed in the last twelve (12) months the following categories in a manner that may be considered a "sale" or "sharing" as defined in CCPA/CPRA:
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Category A: Identifiers
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Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
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Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
Retention of Personal Information
We retain California residents' Personal Information for as long as reasonably necessary to achieve the purposes described in this Privacy Policy (including the purposes disclosed in this CCPA/CPRA notice), taking into account: (i) how long we need the information to provide and maintain our services and your account; (ii) whether you have requested deletion (subject to applicable exceptions); (iii) our legal, tax, accounting, and regulatory obligations; (iv) security, fraud prevention, and abuse monitoring needs; and (v) the time periods needed to resolve disputes and enforce our agreements.
Specific retention periods for major data categories are described in the "Retention of your Personal Information" section of our Privacy Policy, and we may retain certain information longer where required or permitted by law (for example, to comply with recordkeeping obligations or to establish, exercise, or defend legal claims).
Sale of Personal Information of Minors Under 16 Years of Age
We do not knowingly collect personal information from minors under the age of 16 through our services, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the Personal Information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from the parent or guardian of a Consumer less than 16 years of age. Consumers who opt-in to the sale of personal information 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 by contacting us.
If you have reason to believe that a child under the age of 16 has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.
Your Rights under the CCPA/CPRA
If you are a resident of California, you have the following specific rights under the CCPA/CPRA:
- The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
- The right to know/access. Under CCPA/CPRA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
- The categories of personal information we collected about You
- The categories of sources for the personal information we collected about you
- Our business or commercial purposes 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
- If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale or sharing of Personal Information (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request, please see the "Do Not Sell or Share My Personal Information" section or contact us.
- The right to correct Personal Information. You have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our services Providers to correct) your personal information, unless an exception applies.
- The right to limit use and disclosure of sensitive Personal Information. You have the right to request to limit the use or disclosure of certain sensitive personal information we collected about You, unless an exception applies. To submit, please see the "Limit the use or Disclosure of My Sensitive Personal Information" section or contact us.
- The right to delete Personal Information. You have the right to request the deletion of your Personal Information under certain circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- 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.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA/CPRA Data Protection Rights
Please see the "Do Not Sell or Share My Personal Information" section and "Limit the use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, you can contact us:
- By email: legal@entire.io
Only You, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.
Your request to us 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 the required information if we cannot:
- Verify your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Do Not Sell or Share My Personal Information
Our service providers (for example, analytics or advertising partners) may use technology on our services that sell personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of your Personal Information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
Website
If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell or Share My Personal Information" buttons listed on our services to review your privacy preferences and opt out of cookies and other technologies that we may use. Please note that you will need to opt out from each browser that you use to access our services.
Additionally, you can opt out of receiving ads that are personalized as served by our services Providers by following our instructions presented on our services:
- The NAI's opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA's opt-out platform http://www.youronlinechoices.com/
- The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt-out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Mobile devices
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
you can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Limit the Use or Disclosure of My Sensitive Personal Information
If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to provide our services. For more information on how we use your personal information, please see the "use of your Personal Information" section or contact us.
To submit a request to limit the use or disclosure of sensitive personal information, please contact us by using the methods listed in the "Contacting Us" section of our Privacy Policy.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
"Do Not Track" (or DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Our services do not respond to Do Not Track signals.
However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Your California Privacy Rights (California's Shine the Light law)
If you are a California resident who has an account with us, then you can request information once a year about our sharing your personal information with third parties for the third parties' direct marketing purposes.
If you're a California resident and you'd like to request more information under the California Shine the Light law, and if you can contact us by using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
If you are a California resident under the age of 18 who has an account with us, you can request and obtain removal of any content or information that you have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us by using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
13. Colorado, Connecticut & Virginia
If you live in Colorado, Connecticut, or Virginia you have some additional rights:
If we deny your rights request, you have the right to appeal that decision. We will provide you with the necessary information to submit an appeal at that time.
You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not engage in such profiling as defined by Colorado law, so there's no need to opt out.
14. Nevada
We do not sell your covered information, as defined under Chapter 603A of the Nevada Revised Statutes. If you still have questions about your covered information or anything else in our Privacy Statement, please send an email to legal@entire.io.
15. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our services, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
you are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
16. Contacting Us
If you have any questions about this Privacy Policy, you can contact us by email at legal@entire.io