Privacy Policy

Last updated: 05 November 2024

Thank you for visiting Sonara, a Bold LLC and Auxiliant S.à.r.l (the “Provider”, “Provider”, “we”, “us”) offering. For the benefit of our users (the “User”, “Customers,” “you” or “your”), we are providing this notice (the "Policy") explaining our online information practices and the choices you can make about the collection and use of the data and information you submit (the “information”, “Personal information”, “Data”, “User Content” or "Personal Data"), or which we collect through our family of websites that link to this Privacy Policy, as well as our other related mobile websites, mobile Provider applications ("mobile apps" or “Provider Applications”), services, browser extensions, tools, and other applications that link to this Privacy Policy (all of these collectively, the "Site"). The Site is operated by BOLD LLC, City View Plaza II, Suite 6000, 48 Road 165, Guaynabo, Puerto Rico 00968. BOLD LLC is the data controller of your information in the context of the Site.

By visiting the Site, you agree that your information will be handled as described in this Policy. Your use of this Site is subject to this Policy and our Terms of Use. The Provider’s Terms of Use are incorporated by reference into this Policy.

Privacy Policy Highlights

We care, respect, and value your privacy. Please take the time to read our full Privacy Policy which explains what information we process when you use our services/products and describes how that information is collected and used. It also includes more details and information about your rights, how to exercise them, and how to contact us.

• When you become a Registered User, use our services, download, or use any of our mobile apps, use our forum or make a purchase, you voluntarily share certain information with us that we collect, including, but not limited to, your name, email address, address, mobile number, and other information including sensitive information. More details can be found in Section 2 of this document.

• We use tracking technologies such as cookies to measure usage, provide our services and display information that we believe will be of most interest to you.

• We may collect additional information from you if you access our Site through a mobile device (e.g. a unique device identifier, the device’s operating system or the mobile carrier). You can also provide us with information when interacting with our content through or linking to third-party social media sites, plug-ins, or applications.

• We and our service providers may store and retain certain information from you for the time and reasons outlined in this Privacy Policy.

• By using our Site, you agree that we can share the information we collect, to the extent permissible by applicable law, with our subsidiaries and affiliates, with our service providers, third parties and other entities such as job posting third-party websites and Potential Employers or people searching for candidates or jobs, legal authorities, others (in the event of a change of control), and social networks and companies within the mobile app industry.

• We use artificial intelligence language learning models (“AI LLMs”) to search for jobs that match the preferences you have set on your profile and at your request, apply to these jobs on your behalf. As an integral part of our service, we share your personal information, which in some cases may include sensitive personal information. If you do not want us to share your information please discontinue using the service.

• You can control how and when you want to receive information from us, the categories of data we can share, you may object to the processing of your information, request the erasure of the information we have gathered from you and ask for a copy of that information. See the complete list of your privacy rights below.

• You can change your information at any time by editing your Profile, updating, or deleting content that you have posted, or by deleting your account.

• You agree that we can notify you about material changes to this Privacy Policy by posting notices on this Site or displaying a dashboard notification. When required by law, we may also send you an email notice and collect your consent.

• The Provider complies with the CCPA as amended by CPRA and other applicable US state-level privacy laws. As such, United States residents can exercise their respective privacy rights to the extent they are applicable.

• Questions about this Policy may be sent to customersupport@sonara.ai or as otherwise set forth in the Privacy Policy.

Full Privacy Policy

1. Scope

The Service uses AI LLMs to search for job postings that match Users’ preferences, Profile and job aspirations, and applies to these jobs on the User’s behalf at their request. By joining the Service as a Registered User, you will have access to regularly AI curated job queues with job listings that are pre-selected for you, which you can make decisions on and further modify and provide tool feedback on jobs that you find most relevant to your job search. Wherefore, by signing up for any of our services, you agree and request Provider to share the information you have added to your Profile with prospective employers.

2. Information We Collect About You

Information we collect about you depends on how you use our Site.

(a) Registration, Services and Account information. You can browse the Site as a Visitor, without registering an account with us. In this case we may collect information regarding your device, geolocation data, behavioral, target job, We may also collect your IP address, areas of interest, target jobs and reasons for your interest in our services. If you provide us with your social media details, we may retrieve publicly available information about you from social media. We also gather data about the length of time you spend on our website, the pages clicked, and information about your computer, such as your browser type, referring/exit pages, and operating system.

When you become a Registered User, create a Profile, upload your resume, search for or purchase services, we will also collect User Content and target profile. You must provide certain information such as a username and a valid email address otherwise, you will not be able to create an account. In that instance we may collect, as provided by you, first and last name, postal and email addresses, phone number, job title, salary preferences and other career information.

You must provide payment information such as credit or debit card information, name and billing address in order to sign up for our services. Provider does not store credit card information and uses an external service provider to help us process your transaction. This information is only associated with your account after you have signed in as a Registered User.

We will also collect other Data you voluntarily provide, such as sensitive information (i.e. nationality, employment visa status, if you have prior criminal offenses) and any other voluntary information you enter on the Site, when creating documents (for example employment status and education) (“User Content”).

(b) Information to Respond to Your Requests. You may give us contact information (for example, your email address) so we can respond to your questions and requests, as well as to send you newsletters and other communications. Details of how you can opt-out of receiving communications from us are detailed in Section 15(c)

(c) Third-party log-in. We may collect some basic information when you access the Site with third-party login, when available, credentials such as your name, username, and your email address.

(d) User Interaction information. We can also receive other information from your interaction with our Site (e.g. content viewed and information about advertisements within the content you have been shown or have clicked on, etc.) To the extent permissible by the law, you agree that we can share your interaction information with, or obtain information about your interaction from, analytics providers, advertising partners, third-party partners, and social media sites until you withdraw your consent, for the purpose of providing or improving our services. The sharing of this information may or may not include monetary compensation.

Certain information that we may have access to from third-party service providers may be controlled using your privacy settings on that service and by managing your consent. Information can be passed to analytics providers and advertising partners via cookies and tracking technologies.

Please see our Cookies and Tracking Technology Policy for further information, including your choices in relation to some of these technologies.

(e) Information from other Sources. To the extent permissible by the law the information we collect can be combined with publicly available information.

(f) Mobile information. By agreeing to this Policy, you consent to us collecting additional information from you if you access our Site through a mobile device, if available (e.g. your unique device identifier, the device’s operating system, mobile carrier, location or GPS/geo-location).

(g) Inputs and Outputs. The Provider’s AI Tools enable you as a Registered User to upload various types of text, files, documents, photos, images, and other materials, along with their associated metadata. You will be asked to voluntarily provide personal information to complete job applications (collectively referred to as “Inputs”). These Inputs are used to generate responses, content, recommendations (referred to as “Outputs”) in the job hunting process. If your Inputs contain personal information, be advised that we will collect and process that information, and it will be included in the resulting Outputs.

3. Uses, Retention and Storage

We process your information for the following purposes and legal bases:

(a) to Operate our Site and Provide you with our Services. We use the information we collect to (i) respond to your questions and requests; (ii) fill out job applications on your behalf, as previously consented by you, on third party sites (iii) provide customer service (e.g., to fulfill your product and service orders, give you information about your account in order to resolve disputes or problems with your Profile or the Site, administer contests, sweepstakes or promotions, or to provide information to third parties at your request, such as employers that have been matched to your Profile preferences by making a job position available which generally meets the job preferences you have set on your Profile (“Potential Employer”), job matching services or third-party websites, or other career-related services); (iv) personalize your experience by providing content on the Site, including targeted advertising or job-related advertising that we believe may be of most interest to you; (v) improve the Site and our Services, (vi) provide you with a safe, efficient, and customized experience; (vii) store your Profile and job application history and (viii) share it with third parties that help us deliver career enhancing tools and a wider set of services to help in your career development.

To provide you with the highest quality of service and due to the nature of job applications, your personal data will be shared with a given Potential Employer. You have been duly informed of this fact, and it is also clear within the context of the application. Please note that we are not responsible for any responses from Potential Employers, as they act as a separate business/data controller in their own capacity. Provider has no control over how Potential Employers process your information and they are solely responsible for complying with all their responsibilities under applicable data protection rules with respect to the collection, processing, and storage of your personal data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.

(b) to Analyze and Aggregate Non-Personal Data. We use aggregated information about our users and their non-Personal Data to analyze Site and user behavior and to prepare aggregated reports.

(c) to Prevent Fraud and Comply with the Law. We use information from the Site to prevent, detect and investigate fraud, security breaches, and potentially prohibited or illegal activities, and to establish, exercise or defend any legal claims, and enforce our Terms of Use. We also use information in response to requests by government or law enforcement authorities, or in response to complaints where we are under a legal or regulatory obligation to adhere to a complaint handling procedure.

(d) for Marketing & Communications. We use your information to contact you, to maintain the Site, your account, to comply with your stated communication preferences, to provide other services described at the time when we collect the information from you, or to contact you for other purposes authorized by law.
The information you share with us can be provided to third parties such as (i) employers or recruiters who can contact you about career opportunities, (ii) employers or other individuals or companies seeking candidates, and/or (iv) other career service providers.

(e) for Mobile Data. When you access the Site on a mobile device, we can use the information collected for any purpose set out in this Privacy Policy. For example, we can use this information to provide you with location-based services, such as advertising, search results, and other personalized content. To the extent permissible by applicable law, we retain the information for as long as it is necessary to fulfill the purpose(s) for which it was collected, our business purposes and/or to comply with the applicable laws and regulations. This includes but is not limited to the purposes stated in the previous paragraphs of this Section 3.

(f) to train our AI Tools. We use de-identified and/or aggregated information about our users and your non-Personal Data to train and improve our AI Tools enabling us to provide more accurate and relevant results (“Outputs”).

4. Disclosure

The information we collect can be shared with:

(a) The Provider’s Corporate Family. We may disclose the information we collect about you with the Provider’s corporate family (our affiliates and subsidiaries). If we disclose your information with them, their use and disclosure of your information will be subject to this Policy.

(b) Service Providers. We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, bill collection, payment processing, site analytics and the operations as detailed in Section 8 below). For a full list of processors and sub processors please contact us by sending email to privacy@bold.com.

(c) Third-party websites. If you sign up for our AI-augmented job application services we will, according to your settings or preferences, provide information about you to third parties that have been identified as Potential Employers, or parties working on their behalf, in order to execute your request. The job matching will depend on the preferences you set in your profile that can be modified at any time.

To provide our Services, we may share your information which may involve in some cases a monetary compensation to third parties which help us deliver career services to you. Your information may be shared with third parties such as employers, recruiters or job posting third-party websites, third parties in the career building industry or that are looking to enter that industry, or other third parties who are interested in receiving information that we collect about you in the Site. You have the option to opt-out from this type of sharing at any time by modifying your settings in your account (when available) or contacting our Customer Service team. Please note that sharing your information with third-party employers may be essential for us to provide the service.

(d) Legal and Law Enforcement. We may disclose the information that we collect if we believe it is necessary to comply with the law, judicial proceedings, a court order, or other legal process, such as in response to a court order or a subpoena.

(e) Change of Control. We may share your information if there are bankruptcy proceedings, if substantially all our assets are transferred to another company, or if we merge with or are acquired by another business entity. If any of these events take place, we will make reasonable efforts to request that the new service provider follows this Privacy Policy with respect to your information.

(f) Ad Networks. On the Site, we work with third parties to provide advertising, data collection, reporting, ad response measurement, Site analytics and assistance with the delivery of relevant marketing messages and advertisements. These third parties can view, edit or set their own tracking technologies/cookies.

(g) Analytics Providers. We may disclose information we have collected through our Site to our analytics providers such as Google Analytics, to evaluate the usage of our Site, and to help us improve our services, performance and user experiences.

(h) To Protect Us and Others. We may share your information where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any person, violations of our Terms of Use, or this Policy, or as evidence in litigation in which we are involved.

(i) Aggregate and De-Identified Information. We may share information that has been aggregated and de-identified with third parties for marketing, advertising, research, or similar purposes.

(j) Your Consent. By agreeing to this Privacy Policy, we have obtained your consent, when required, for the disclosure of the information we collect.

5. Accessing, Reviewing, and Changing Your Personal Data

Registered Users can review and change the information at any time by accessing their accounts on the Site (through the My Account tab). You should promptly update your information if it changes or becomes inaccurate.

6. Your Choices

(i) Opting Out of Promotional Messages.

You can choose not to receive our promotional communications by clicking the "My Account" tab and clicking the "My Settings" and "Preferences" tabs.
You can also click the unsubscribe link in the footer of any email or newsletter you receive or email us with your request to unsubscribe at privacy@bold.com

(ii) Update/Delete or Change Your account information or documentation.

To change or delete your account information or documentation that you have uploaded to the Site, login to your account or contact Customer Service.

(iii) Site Privacy Settings.

Information that you disclose while participating on the Site may be public and subject to redistribution by us and any third party that reviews your Profile or information that you post, depending on your privacy settings.
You can change your preferences by logging into your account and clicking on settings, or by contacting us as set out in Section 17.
Please be aware that the Provider is not responsible for the use, disclosure or copies of your public postings on or through the Site that you make public and that are downloaded by third parties.

(iv) Administrative/Transactional Messages Cannot Be Turned Off.

As we provide an online service, you cannot opt-out of administrative or transactional emails (for example emails about your transactions or Policy changes) for your registered account.

(v) Deletion of Your User Content/Account.

You may ask us to delete your account and/or certain personal identifiable information we have collected from you from our systems. You can do so by using any of the options made available to you by us throughout the Site for this purpose, or by sending us an email at privacy@bold.com.
When you ask for your account or your personal identifiable information to be deleted, we will delete that data and it will no longer be available to you or visible to others. However, if the information you provided was previously accessed by others, we will not be able to delete the information from their systems. After deletion, your information will not be accessible by you or third parties, but might be used by us for recordkeeping and internal purposes, including enforcing this Policy. To the extent permitted by applicable law, we may retain information from deleted accounts so that we can comply with the law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account or membership is terminated or suspended, we may maintain information to prevent re-registration.

(vi) Third-Party Ad Network.

We may use third-party network advertisers to serve advertisements on third-party websites or other media (e.g. social networking platforms). This enables us and these third parties to target advertisements to you for services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. We may provide these third-party advertisers with information about you as part of providing our Service.

(vii) Other Data Options.

Unless otherwise required by the law, you may request: (i) a copy of the specific pieces of personal identifiable information that we have collected about you in the last 12 months from the date of your request, and; (ii) that we disclose certain information about how we have handled your personal identifiable information in the prior 12 months. You can make such requests, if you have created an account with us, by using any of the options made available to you by us throughout the Site for this purpose, or if you have not created an account, by sending us an email at privacy@bold.com.

(viii) SMS.

If you opt-in to our SMS alert service, when available, you acknowledge that message or data charges may apply.
If you wish not to continue with the SMS alert service, you may opt-out by replying “STOP” to the SMS text you received or contact our customer service team by any of the options available here. Please allow three to five business days to process your request. Consent to being contacted by telephone is not required as a condition of using the services or purchasing and products from us.

(ix) Timing and Third Parties.

We will endeavor to comply with your requests as soon as reasonably possible, but please note that requested changes are not always effective immediately. Additionally, in certain situations, and subject to applicable law, the Provider will not be able or obliged to comply with part or all of your individual requests. Please note that we have the right to refuse and/or charge a monetary fee for requests that are manifestly unfounded or excessive.
Unless required by law, we are not responsible for informing third parties with whom we have already shared your information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such third parties.

7. Information You Share on the Site

(a) Public information. If you participate in the Provider’s services, when available, that permit you or the Provider, on your behalf, to post your information publicly in our family sites or on third-party sites (e.g. websites, bulletin boards and personal URLs) by posting information or content (such as by posting your employment history, photos, or participating in online forums or communities), or when you interact with our Site through social media sites, post your resume, use plug-ins or other sites or applications, the information posted will be publicly available and searchable by individuals. Provider reserves the right to aggregate and /or share that information with third parties to perform our Service.
We may not be able to prevent the further use of this information. You may review, correct, update, or change your user account at any time. From your user account, you may also opt-out of receiving newsletters and certain other information from Provider. To change your user account information, log into your account, go to Account Settings, review your account information and, if you wish, edit it with the options provided. Through Account Settings, you can also cancel your subscription at any time. If you would like your Profile to no longer be accessible to the Provider you should request your account to be deleted by contacting our customer service team. If you have any questions make sure to contact us. Please also remember to refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices.

(b) Job application services. As a Registered User, you may store in our database your work profile, which may include your resume, cover letter(s), job preferences, and/or work samples (“Profile”). Your Profile is completely hidden from the public as a default but you may choose to make it public, if that option is available. The Profile information will be used to provide you with the job application services you have requested us to complete on your behalf. You therefore acknowledge and agree for us to share your personal information, including in some cases sensitive information, with third parties that have been matched by our system according to your job preferences and the job positions available.

You may remove your resume from the Site or delete your Profile at any time, and it will no longer be available for the Provider services. If you want employers who have had access to your Profile to delete their copies of your information, you will need to contact them directly and request that they do so. Such parties’ privacy policy applies to the services provided and information processed by them. We are not responsible for their use of or privacy of your information. You agree that employers and the Provider can use the contact information you have provided to contact you, and you understand that this consent is not a condition to having access to the Site or the Provider’s services.

8. Tracking Technologies (Cookies)

When you first access this Site, you may be prompted to set your cookie preferences. Your cookie settings will be saved in accordance with applicable privacy laws for 12 months. Otherwise, when you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site. This includes, but is not limited to, video-viewing, site views, keystroke data, mouse movement, scrolling, clicks, and typing ("Usage information"). Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster login process.

We use tracking technologies (including cookies, flash cookies, unique device identifiers, web beacons/GIFs, embedded scripts, e-tags/cache browsers and cross-device tracking) to collect Usage information. We can use tracking technologies for a variety of purposes, including:

(a) Essential. These are tracking technologies required for system administration, to prevent fraudulent activity, to improve site security or allow you to make use of shopping cart functionality. We are not required to obtain your consent for tracking technologies that are operationally necessary.

(b) Analytics. These tracking technologies are used to assess the performance of the online services, including as part of our analytic practices to improve the content offered through the online services. For example, as set out in detail in our Cookies and Tracking Technologies Policy, we use Google Analytics to perform Site analytics.

(c) Performance and Personalization. These tracking technologies are used to tell us, for example, whether you have visited the Site before or if you are a new visitor, and to help us identify the features in which you have the greatest interest.

(d) Advertising. These tracking technologies are used to deliver content, including ads, relevant to your interests in our online service and third-party sites, based on how you interact with our advertisements or content, and can track the content you access (including video viewing).

Further information on this, and your opt-out choices, can be found in the “Your Choices” section above.
During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information. When you visit the Site, we and our business partners can use tracking technologies to enhance your online experience or customize our offerings.

For some customers, a privacy settings option will be available to set your cookie preferences.

A few additional important things you should know about our use of tracking technologies:

• We offer certain features that are available only through the use of tracking technologies.
• There are two types of cookies: session cookies and persistent cookies. We use both session and persistent tracking technologies. Tracking technologies can either be persistent (i.e. they remain on your computer until you delete them) or temporary/session (i.e. they last only until you close your browser). You may be able to decline tracking technologies if your browser permits, although doing so can interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
• We encode and protect the tracking technologies that the Provider sets, so that only we can interpret the information stored in them.
• You can encounter tracking technologies from our third-party service providers that we have allowed on our Site. These assist us with various aspects of our Site operations and services, such as Google Analytics.
• You can also encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized (for example, if you view a web page created by another user, there can be a cookie placed by that web page).
• Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.
• We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage.

We and our third-party service providers may also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. For more information about the use of cookies and similar technologies on our Site, please review this Privacy Policy and our Cookies and Tracking Technologies Policy.

9. Residents around the world

Provider will afford all data subjects their respective data privacy rights to the extent they are applicable in compliance with the law of their country. All rights listed on Section 16(b) shall be afforded to other residents of the world respectively. If you have any questions, requests, or concerns please contact us by sending an email to legal@bold.com.

10. Third Parties

Our Site may contain links to other third-party websites and the Provider can provide products and services that share information with third-party sites for your job search. We are not responsible for the privacy practices or the content of these third-party sites, so it is important to look through their privacy policies before providing your information.

11. Information Security

We maintain appropriate technical, physical, and administrative security measures designed to protect the security of your information against loss, misuse, unauthorized or accidental access, disclosure, copying, use or alteration. However, no method of transmission over the internet or method of electronic storage is totally secure. Therefore, we cannot guarantee its absolute security.

12. Children's Privacy

The Site is a general audience site and it is not intended for children under the age of 18. We do not knowingly collect information via our websites, applications, services, or tools from users in this age group. If you become aware that a child under 18 has provided us with information, please contact us immediately so we can delete such information from our system.

13. Storage and International Transfer

As we operate internationally, and many of our computer systems are currently based globally, for the purposes set out in this Privacy Policy your information can be stored and processed elsewhere by us, our affiliates or an unaffiliated service provider.

The data protection and privacy regulations do not always offer the same level of protection in all parts of the world. Nonetheless, we have ensured that our service providers and affiliates have been subjected to strict contractual provisions in their contract, to guarantee that an adequate level of data protection for your data is met. When you create an account/profile or otherwise provide us with your information, you consent to the collection, storage, use of some tracking technologies as described above, and/or processing of your information, including Personal Data, in the United States and other countries. If you have any questions or concerns of how we process your data please contact us.

14. Notification Regarding Review and Updates

From time to time, and at least once every twelve (12) months, we review this Privacy Policy, and we may choose to update its terms. The Privacy Policy posted at any time or from time to time via the Site will be deemed to be the Privacy Policy then in effect. You agree that we can notify you about updates made to this Policy by placing a notice on the Site. We encourage you to check the Site frequently for updates. That way you will always know our current privacy practices.

In addition, we have provided the Privacy Policy Highlights section to offer a summary of the main points of our full Privacy Policy for your convenience. In the event of a conflict between the Privacy Policy Highlights and the full Privacy Policy, the full Privacy Policy will prevail.

15. Privacy Disclosures for United States Residents

This section provides additional information to United States residents of US states that have adopted comprehensive consumer data privacy laws in effect (collectively “US State-level Privacy Laws”).

“Personal information” is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified below to the extent that they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

(a) Categories of Personal Information that We Collect and Disclose.

We may collect and disclose for business purposes the following Personal information from California Consumers:

• account information name, contact information and identifiers (real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers);
• customer records such as electronic customer records containing Personal information, such as name, signature, physical characteristics or description, address, telephone number, education, employment, employment history);
• protected classifications (characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information);
• purchase history and tendencies (commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• usage data (internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a California consumer’s interaction with an internet website, application, or advertisement);
• geolocation data (precise geographic location information about a particular individual or device);
• employment history (professional or employment-related information);
• education information (information about education history or background),
• Audio/Visual: audio, electronic, visual, thermal, olfactory, or similar information, and;
• profiles and inferences (inferences drawn from any of the information identified above to create a profile about a California consumer reflecting the California consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes);
• sensitive personal information such as information about racial or ethnic origin, religious or philosophical beliefs, or union membership.
• Other information you provide to us such as the content of your communications with us, including interactions with customer service or when you participate in our surveys.

(b) Consumer Rights.

United States state laws grant consumers certain rights and impose restrictions on particular business practices as set out below.

(i) Do not Sell or Share my Personal Information

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Regulations Act (CPRA), affords all California residents the right to opt-out of the selling or sharing of their personal information. CCPA defines “personal information” as information that identifies, relates to, or could reasonably be linked to a person or his/her household. Provider uses your personal information to perform the contract and provide our Services. When you use our Services, we may drop data collection tools (i.e. cookies, web beacons, and other similar technologies) and share some of your digital activity information with third parties in order to receive information about the performance of our marketing campaigns and the usage of our web sites and applications. Details about how we use your information and for what purposes can be found on our Privacy Policy. You may request us to stop sharing your personal information and we will honor your request for at least twelve (12) months before asking you to opt back in. You have the right to exercise this right personally or through an authorized agent, who will have to provide the necessary evidence to confirm his/her agent status. Your request will be subject to an identification process, and we will not fulfill your request unless you have provided all the information required.

To make a Do Not Sell or Share my Personal information request, please submit your information using the form available here or by contacting us at privacy@bold.com and following the instructions.

Other US state residents that have Do Not Sell or Share my Personal information effective regulations, please note that Provider will also honor your Do Not Sell or Share my information request(s), in compliance with these state privacy regulations.

Our sites detect and comply with the Global Privacy Control ("GPC") signal for applicable US jurisdictions. By using our website, you acknowledge and agree that we will process your browser’s GPC signal in accordance with the applicable state law requirements. Specifically, we process the GPC signal as a request to not share your information with our advertisers. If a GPC signal is detected from your browser, we will not display a cookie banner during your visit and instead, we will automatically apply the relevant privacy settings to your data according to applicable regulations and pursuant to our Privacy Policy.

(c) Exercising your privacy rights

Subject to certain exceptions, as a United States resident, you have the right to make the following requests at no charge, up to two times, every 12 months:

(i) Deletion. You have the right to request the deletion of Personal Information that we have collected about you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).

(ii) Copy. Consumers have the right to request a copy of the specific pieces of Personal Information that we have collected about them in the prior 12 months.

(iii) Right to Know. Consumers have the right to ask us to disclose certain information about how we have handled Personal Information in the prior 12 months, including the:

• i. categories of Personal Information collected
• ii. categories of sources of Personal Data
• iii. business and/or commercial purposes for collecting and selling their Personal Data
• iv. categories of third parties with whom we have disclosed or shared their Personal Data
• v. categories of Personal Information that we have disclosed or shared with a third party for a business purpose
• vi. categories of third parties to whom the consumer’s Personal Information has been sold and the specific categories Personal Information sold to each category of third party

(iv) Right to Correct. You have the right to request correction of any inaccurate Personal Information we hold about you.

(v) Right to limit the use and disclosure of sensitive personal information that you have provided, and we have collected about you.

(d) Submitting Requests

You can make a copy, deletion and right-to-know request online by sending a request through your account in case you are registered on the Site, by emailing us at privacy@bold.com, by using any of the options made available to you by us throughout the Site for this purpose, or by contacting us at the free phone number in Contact Us.

(e) Incentives and Discrimination

Subject to certain exceptions, the CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their Personal Information.

16. Contact Us

This Site is controlled and operated by the Provider. Whether you access the services through any of our family sites, you may contact the Provider by any of the means in the Contact Us section on the Site. If your questions are not answered online, you can email us at privacy@bold.com or write to us at Auxiliant S.à.r.l, 1A, rue Thomas Edison, L-1445 Strassen, Luxembourg or to BOLD LLC at City View Plaza II, Suite 6000, 48 Road 165, Guaynabo PR 00968.