Hashtag Expert
Privacy Policy
Last update: 3 August, 2020.

Thank you for visiting Shakd, LLC and our Service (“Shakd Apps”). Your privacy is important to us. This notice explains our online information practices and the choices you can make about the way your information is used at our Service.

The Information We Collect

We do not collect personally identifiable information about you – such as your name, address, telephone number, fax number, e-mail address, etc. – unless you choose to complete registration and become a Member and affirmatively consent to our collection of such personally identifiable information.

We do automatically collect certain non-personally identifiable information when you visit our Service. We call this information “Anonymous Data”. Anonymous Data is non-personally identifiable information about your use or the aggregate use of all users that allows us to provide analytics and information on application or Instagram performance, trends, and other metrics that may be useful to users or us. Anonymous Data includes, but is not limited to, the type of browser you are using, the type of operating system you are using, the domain name of your Internet service provider (e.g. Comcast, Verizon FIOS, etc.), the country a mobile device is used in, the time zone of use, the type of mobile device, non-personally identifiable information about use or performance of an Instagram account, and similar information.

We collect your instagram account ID and username which can be used in some cases to personally identify you. This is used, with your permission, to perform the services of the apps including calculating stats and analyzing your accounts. Your Instagram account username is not publicly accessible to other users unless you affirmatively opt-in for it to be.  

We retain your Instagram account username(s) and id(s) in our database indefinitely. Certain calculated analytics containing your Instagram username will remain in our system including hourly and daily data points. These data points contain snapshots of your accounts’ various stats at given times. For example, the number of followers you have. This information can be erased by request.

Unfortunately, we cannot perform the core services of this app without access to your Instagram id(s) and username(s). If you do not login with your Instagram account, we cannot offer you the analytics and stats the application provides.

We also use your Instagram account username and other self-reported information like niche and account type to analyze how you use the application so we can make the experience better for you.

We will not sell your Instagram account data or statistical information unless you affirmatively opt-in for it. We may anonymize your data and then use it to calculate aggregate statistics. For example, we may use your best time to post, your follower count, account niche, and account type to contribute to an aggregated best time to post. With such analytics, however, your username and personally identifiable information will not be accessible.



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Contact Us

Please, email me personally at zach@shakd.io and I'll help you get this sorted.

Privacy Policy  

Last updated: February 14, 2022

This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the
Service, You agree to the collection and use of information in accordance with
this Privacy Policy.

Interpretation and Definitions  


The words of which the initial letter is capitalized have meanings defined
under the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:

 * Account means a unique account created for You to access our Service or
   parts of our Service.

 * Affiliate means an entity that controls, is controlled by or is under
   common control with a party, where "control" means ownership of 50% or
   more of the shares, equity interest or other securities entitled to vote
   for election of directors or other managing authority.

 * Application means the software program provided by the Company downloaded
   by You on any electronic device, named Hashtag Expert

 * Business , for the purpose of the CCPA (California Consumer Privacy Act),
   refers to the Company as the legal entity that collects Consumers'
   personal information and determines the purposes and means of the
   processing of Consumers' personal information, or on behalf of which such
   information is collected and that alone, or jointly with others,
   determines the purposes and means of the processing of consumers' personal
   information, that does business in the State of California.

 * Company (referred to as either "the Company", "We", "Us" or "Our" in this
   Agreement) refers to Shakd, LLC, 99 Wall Street #2712, New York NY 10005.

   For the purpose of the GDPR, the Company is the Data Controller.

 * Consumer , for the purpose of the CCPA (California Consumer Privacy Act),
   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.

 * Cookies are small files that are placed on Your computer, mobile device or
   any other device by a website, containing the details of Your browsing
   history on that website among its many uses.

 * Country refers to: New Jersey, United States

 * Data Controller , for the purposes of the GDPR (General Data Protection
   Regulation), refers to the Company as the legal person which alone or
   jointly with others determines the purposes and means of the processing of
   Personal Data.

 * Device means any device that can access the Service such as a computer, a
   cellphone or a digital tablet.

 * Do Not Track (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

 * Personal Data is any information that relates to an identified or
   identifiable individual.

   For the purposes of GDPR, Personal Data means any information relating to
   You such as a name, an identification number, location data, online
   identifier or to one or more factors specific to the physical,
   physiological, genetic, mental, economic, cultural or social identity.

   For the purposes of the CCPA, Personal Data means any information that
   identifies, relates to, describes or is capable of being associated with,
   or could reasonably be linked, directly or indirectly, with You.

 * Sale , for the purpose of the CCPA (California Consumer Privacy Act),
   means 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 to another
   business or a third party for monetary or other valuable consideration.

 * Service refers to the Application or the Website or both.

 * Service Provider means any natural or legal person who processes the data
   on behalf of the Company. It refers to third-party companies or
   individuals employed by the Company to facilitate the Service, to provide
   the Service on behalf of the Company, to perform services related to the
   Service or to assist the Company in analyzing how the Service is used. For
   the purpose of the GDPR, Service Providers are considered Data Processors.

 * Third-party Social Media Service refers to any website or any social
   network website through which a User can log in or create an account to
   use the Service.

 * Usage Data refers to data collected automatically, either generated by the
   use of the Service or from the Service infrastructure itself (for example,
   the duration of a page visit).

 * Website refers to Hashtag Expert, accessible from

 * You means the individual accessing or using the Service, or the company,
   or other legal entity on behalf of which such individual is accessing or
   using the Service, as applicable.

   Under GDPR (General Data Protection Regulation), You can be referred to as
   the Data Subject or as the User as you are the individual using the

Collecting and Using Your Personal Data  

Types of Data Collected  

Personal Data  

While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:

 * Email address

 * Usage Data

Usage Data  

Usage Data is collected automatically when using the Service.

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
Service 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 the Service 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 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
Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services  

The Company allows You to create an account and log in to use the Service
through the following Third-party Social Media Services:

 * Google
 * Facebook
 * Twitter

If You decide to register through or otherwise grant us access to a Third-
Party Social Media Service, We may collect Personal data that is already
associated with Your Third-Party Social Media Service's account, such as Your
name, Your email address, Your activities or Your contact list associated with
that account.

You may also have the option of sharing additional information with the
Company through Your Third-Party Social Media Service's account. If You choose
to provide such information and Personal Data, during registration or
otherwise, You are giving the Company permission to use, share, and store it
in a manner consistent with this Privacy Policy.

Information Collected while Using the Application  

While using Our Application, in order to provide features of Our Application,
We may collect, with Your prior permission:

 * Information regarding your location

We use this information to provide features of Our Service, to improve and
customize Our Service. The information may be uploaded to the Company's
servers and/or a Service Provider's server or it may be simply stored on Your

You can enable or disable access to this information at any time, through Your
Device settings.

Tracking Technologies and Cookies  

We use Cookies and similar tracking technologies to track the activity on Our
Service and store certain information. Tracking technologies used are beacons,
tags, and scripts to collect and track information and to improve and analyze
Our Service. 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 Service. Unless you have adjusted
   Your browser setting so that it will refuse Cookies, our Service may use
 * Flash Cookies. Certain features of our Service may use local stored
   objects (or Flash Cookies) to collect and store information about Your
   preferences or Your activity on our Service. Flash Cookies are not managed
   by the same browser settings as those used for Browser Cookies. For more
   information on how You can delete Flash Cookies, please read "Where can I
   change the settings for disabling, or deleting local shared objects?"
   available at <https://helpx.adobe.com/flash-player/kb/disable-local-
 * Web Beacons. Certain sections of our Service 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 the Company, 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

Cookies can be "Persistent" 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. You can learn more
about cookies here: [Cookies by TermsFeed

We use both Session and Persistent Cookies for the purposes set out below:

 * Necessary / Essential Cookies

   Type: Session Cookies

   Administered by: Us

   Purpose: These Cookies are essential to provide You with services
   available through the 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.

 * Cookies Policy / Notice Acceptance Cookies

   Type: Persistent Cookies

   Administered by: Us

   Purpose: These Cookies identify if users have accepted the use of cookies
   on the Website.

 * Functionality Cookies

   Type: Persistent Cookies

   Administered by: Us

   Purpose: These Cookies allow us to remember choices You make when You use
   the 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 the Website.

 * Tracking and Performance Cookies

   Type: Persistent Cookies

   Administered by: Third-Parties

   Purpose: These Cookies are used to track information about traffic to the
   Website and how users use the 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 the
   Website. We may also use these Cookies to test new pages, features or new
   functionality of the 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

Use of Your Personal Data  

The Company may use Personal Data for the following purposes:

 * To provide and maintain our Service , including to monitor the usage of
   our Service.

 * To manage Your Account: to manage Your registration as a user of the
   Service. The Personal Data You provide can give You access to different
   functionalities of the Service that are available to You as a registered

 * For the performance of a contract: the development, compliance and
   undertaking of the purchase contract for the products, items or services
   You have purchased or of any other contract with Us through the Service.

 * 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.

 * To provide You with news, special offers and general information about
   other goods, services and events which we offer that are similar to those
   that you have already purchased or enquired about unless You have opted
   not to receive such information.

 * To manage Your requests: To attend and manage Your requests to Us.

 * For business transfers: We may use Your 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 Data held by Us about our Service users is among the assets

 * 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 Service,
   products, services, marketing and your experience.

We may share Your personal information in the following situations:

 * With Service Providers: We may share Your personal information with
   Service Providers to monitor and analyze the use of our Service, for
   payment processing, to contact You.
 * 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 Affiliates: We may share Your information with Our affiliates, in
   which case we will require those affiliates to honor this Privacy Policy.
   Affiliates include Our parent company and any other subsidiaries, joint
   venture partners or other companies that We control or that are under
   common control with Us.
 * With business partners: We may share Your information with Our business
   partners to offer You certain products, services or promotions.
 * With other users: 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. If You
   interact with other users or register through a Third-Party Social Media
   Service, Your contacts on the Third-Party Social Media Service may see
   Your name, profile, pictures and description of Your activity. Similarly,
   other users will be able to view descriptions of Your activity,
   communicate with You and view Your profile.
 * With Your consent : We may disclose Your personal information for any
   other purpose with Your consent.

Retention of Your Personal Data  

The Company will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use Your
Personal Data 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.

The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time

Transfer of Your Personal Data  

Your information, including Personal Data, is processed at the Company's
operating offices and in any other places where the parties involved in the
processing are located. It means that this information may be transferred to —
and maintained on — computers located outside of Your state, province, country
or other governmental jurisdiction where the data protection laws may differ
than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data
is treated securely and in accordance with this Privacy Policy and no transfer
of Your Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.

Disclosure of Your Personal Data  

Business Transactions  

If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement  

Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).

Other legal requirements  

The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:

 * Comply with a legal obligation
 * Protect and defend the rights or property of the Company
 * Prevent or investigate possible wrongdoing in connection with the Service
 * Protect the personal safety of Users of the Service or the public
 * Protect against legal liability

Security of Your Personal Data  

The security of Your Personal Data 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 acceptable means to protect
Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data  

The Service Providers We use may have access to Your Personal Data. These
third-party vendors collect, store, use, process and transfer information
about Your activity on Our Service in accordance with their Privacy Policies.


We may use third-party Service providers to monitor and analyze the use of our

 * Google Analytics

   Google Analytics is a web analytics service offered by Google that tracks
   and reports website traffic. Google uses the data collected to track and
   monitor the use of our Service. This data is shared with other Google
   services. Google may use the collected data to contextualize and
   personalize the ads of its own advertising network.

   You can opt-out of having made your activity on the Service available to
   Google Analytics by installing the Google Analytics opt-out browser add-
   on. The add-on prevents the Google Analytics JavaScript (ga.js,
   analytics.js and dc.js) from sharing information with Google Analytics
   about visits activity.

   You may opt-out of certain Google Analytics features through your mobile
   device settings, such as your device advertising settings or by following
   the instructions provided by Google in their Privacy Policy:

   For more information on the privacy practices of Google, please visit the
   Google Privacy & Terms web page: <https://policies.google.com/privacy>

 * Firebase

   Firebase is an analytics service provided by Google Inc.

   You may opt-out of certain Firebase features through your mobile device
   settings, such as your device advertising settings or by following the
   instructions provided by Google in their Privacy Policy:

   We also encourage you to review the Google's policy for safeguarding your
   data: <https://support.google.com/analytics/answer/6004245>

   For more information on what type of information Firebase collects, please
   visit the How Google uses data when you use our partners' sites or apps
   webpage: <https://policies.google.com/technologies/partner-sites>

 * Mixpanel

   Mixpanel is provided by Mixpanel Inc.

   You can prevent Mixpanel from using your information for analytics
   purposes by opting-out. To opt-out of Mixpanel service, please visit this
   page: <https://mixpanel.com/optout/>

   For more information on what type of information Mixpanel collects, please
   visit the Terms of Use page of Mixpanel: <https://mixpanel.com/terms/>


We may provide paid products and/or services within the Service. In that case,
we may use third-party services for payment processing (e.g. payment

We will not store or collect Your payment card details. That information is
provided directly to Our third-party payment processors whose use of Your
personal information is governed by their Privacy Policy. These payment
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure
the secure handling of payment information.

 * Apple Store In-App Payments

   Their Privacy Policy can be viewed at

GDPR Privacy  

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 the Company is 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 the Company.
 * Legitimate interests: Processing Personal Data is necessary for the
   purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis
that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.

Your Rights under the GDPR  

The Company undertakes to respect the confidentiality of Your Personal Data
and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the
EU, to:

 * Request access to Your Personal Data. The right to access, update or
   delete the information We have on You. Whenever made possible, you can
   access, update or request deletion of Your Personal Data directly within
   Your account settings section. If you are unable to perform these actions
   yourself, please contact Us to assist You. This also enables You to
   receive a copy of the Personal Data We hold about You.
 * 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 Data 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 the

Exercising of Your GDPR Data Protection Rights  

You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify Your
identity before responding to such requests. If You make a request, We will
try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our
collection and use of Your Personal Data. For more information, if You are in
the European Economic Area (EEA), please contact Your local data protection
authority in the EEA.

CCPA Privacy  

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.

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. 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.

 * Category A: Identifiers.

   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.

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

   Examples: A name, signature, Social Security number, physical
   characteristics or description, address, telephone number, passport
   number, driver's license or state identification card number, insurance
   policy number, education, employment, employment history, bank account
   number, credit card number, debit card number, or any other financial
   information, medical information, or health insurance information. Some
   personal information included in this category may overlap with other

   Collected: Yes.

 * Category C: Protected classification characteristics under California or
   federal law.

   Examples: Age (40 years or older), race, color, ancestry, national origin,
   citizenship, religion or creed, marital status, medical condition,
   physical or mental disability, sex (including gender, gender identity,
   gender expression, pregnancy or childbirth and related medical
   conditions), sexual orientation, veteran or military status, genetic
   information (including familial genetic information).

   Collected: No.

 * Category D: Commercial information.

   Examples: Records and history of products or services purchased or

   Collected: Yes.

 * Category E: Biometric information.

   Examples: Genetic, physiological, behavioral, and biological
   characteristics, or activity patterns used to extract a template or other
   identifier or identifying information, such as, fingerprints, faceprints,
   and voiceprints, iris or retina scans, keystroke, gait, or other physical
   patterns, and sleep, health, or exercise data.

   Collected: No.

 * Category F: Internet or other similar network activity.

   Examples: Interaction with our Service or advertisement.

   Collected: Yes.

 * Category G: Geolocation data.

   Examples: Approximate physical location.

   Collected: Yes.

 * Category H: Sensory data.

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

   Collected: No.

 * Category I: Professional or employment-related information.

   Examples: Current or past job history or performance evaluations.

   Collected: No.

 * 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)).

   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.

 * Category K: Inferences drawn from other personal information.

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

   Collected: No.

Under CCPA, personal information does not include:

 * Publicly available information from government records
 * Deidentified or aggregated consumer information
 * Information excluded from the CCPA'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
   Service, preferences You express or provide through our Service, or from
   Your purchases on our Service.
 * Indirectly from You. For example, from observing Your activity on our
 * Automatically from You. For example, through cookies We or our Service
   Providers set on Your Device as You navigate through our Service.
 * From Service Providers. For example, third-party vendors to monitor and
   analyze the use of our Service, third-party vendors for payment
   processing, or other third-party vendors that We use to provide the
   Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes  

We may use or disclose personal information We collect for "business purposes"
or "commercial purposes" (as defined under the CCPA), which may include the
following examples:

 * To operate our Service and provide You with our Service.
 * To provide You with support and to respond to Your inquiries, including to
   investigate and address Your concerns and monitor and improve our Service.
 * To fulfill or meet the reason You provided the information. For example,
   if You share Your contact information to ask a question about our Service,
   We will use that personal information to respond to Your inquiry. If You
   provide Your personal information to purchase a product or service, We
   will use that information to process Your payment and facilitate delivery.
 * 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.
 * 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.

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 Data" 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 for Business Purposes or Commercial

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:

 * Category A: Identifiers
 * Category B: Personal information categories listed in the California
   Customer Records statute (Cal. Civ. Code § 1798.80(e))
 * Category D: Commercial information
 * Category F: Internet or other similar network activity
 * Category G: Geolocation data

Please note that the categories listed above are those defined in the CCPA.
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.

Sale of Personal Information  

As defined in the CCPA, "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 the business 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

Please note that the categories listed below are those defined in the CCPA.
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.

We may sell and may have sold in the last twelve (12) months the following
categories of personal information:

 * Category A: Identifiers
 * Category B: Personal information categories listed in the California
   Customer Records statute (Cal. Civ. Code § 1798.80(e))
 * Category D: Commercial information
 * Category F: Internet or other similar network activity
 * Category G: Geolocation data

Share of Personal Information  

We may share Your personal information identified in the above categories with
the following categories of third parties:

 * Service Providers
 * Payment processors
 * Our affiliates
 * Our business partners
 * 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 of Minors Under 16 Years of Age  

We do not knowingly collect personal information from minors under the age of
16 through our Service, 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 either the Consumer who is between 13 and 16 years of age, or
the parent or guardian of a Consumer less than 13 years of age. 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 13 (or 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  

The CCPA provides California residents with specific rights regarding their
personal information. If You are a resident of California, You have the
following rights:

 * The right to notice. You have the right to be notified which categories of
   Personal Data are being collected and the purposes for which the Personal
   Data is being used.
 * The right to request. Under CCPA, 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 purpose for collecting or selling that
     personal information
   * The categories of third parties with whom We share that personal
   * 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 of Personal Data (opt-out). You have the
   right to direct Us to not sell Your personal information. To submit an
   opt-out request please contact Us.
 * The right to delete Personal Data. You have the right to request the
   deletion of Your Personal Data, 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
   * 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 Data Protection Rights  

In order to exercise any of Your rights under the CCPA, and if You are a
California resident, You can contact Us:

 * By email: support@hashtag.expert

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
 * 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 My Personal Information  

You have the right to opt-out of the sale of Your personal information. Once
We receive and confirm a verifiable consumer request from You, we will stop
selling Your personal information. To exercise Your right to opt-out, please
contact Us.

The Service Providers we partner with (for example, our analytics or
advertising partners) may use technology on the Service that sells personal
information as defined by the CCPA 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 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.


You can opt out of receiving ads that are personalized as served by our
Service Providers by following our instructions presented on the Service:

 * 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:

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.

"Do Not Track" Policy as Required by California Online Privacy Protection Act

Our Service does 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

Children's Privacy  

Our Service does not address anyone under the age of 13. We do not knowingly
collect personally identifiable information from anyone under the age of 13.
If You are a parent or guardian and You are aware that Your child has provided
Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from anyone under the age of 13 without verification
of parental consent, We take steps to remove that information from Our

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.

Your California Privacy Rights (California's Shine the Light law)  

Under California Civil Code Section 1798 (California's Shine the Light law),
California residents with an established business relationship with us can
request information once a year about sharing their Personal Data with third
parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light
law, and if You are a California resident, You can contact Us using the
contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions
Code Section 22581)  

California Business and Professions Code Section 22581 allows California
residents under the age of 18 who are registered users of online sites,
services or applications to request and obtain removal of content or
information they have publicly posted.

To request removal of such data, and if You are a California resident, You can
contact Us 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.

Links to Other Websites  

Our Service 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

We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.

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 Service, 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

Contact Us  

If you have any questions about this Privacy Policy, You can contact us:

 * By email: support@hashtag.expert