Privacy Notice for California Residents

Effective Date: July 28th 2020

This Privacy Notice for California Residents supplements and is expressly made part of the information Vitruvi Corporation’s privacy policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA).  Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Our Websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Websites have collected the following categories of personal information from its consumers within the last twelve (12) months:

• Identifiers: YES
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): YES
• Protected classification characteristics under California or federal law: NO
• Commercial information: NO
• Biometric Information: NO
• Internet or other similar network activity: YES
• Geolocation data: YES
• Sensory data: NO
• Professional or employment-related information: NO
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): NO
• Inferences drawn from other personal information: YES

Where Vitruvi Corporation may obtain your personal information

We may obtain personal information about you in the following manner:

• Directly from you from forms you complete and submit on our website or other online interactions.
• Indirectly from you by tracking or observing actions you take on our website.
• From third-party business partners such as social media sites, ad networks, and analytics providers.

How Vitruvi Corporation may use your personal information

We may use, or disclose the personal information we collect from or about you in the following ways:

• To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our websites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

How Vitruvi Corporation shares your personal information

Vitruvi Corporation does not sell your personal information. However, Vitruvi Corporation may disclose your personal information to a third party for a business purpose allowed by law or regulation. When we disclose information for a business purpose, we may enter a contract that describes the purpose for which the information is being disclosed and require the recipient to:

• Protect the personal information by applying appropriate privacy and security safeguards,
• Maintain its confidentiality and prohibit further disclosure, and
• Only use the information for the business purpose for which it was intended.

In the preceding twelve (12) months, Vitruvi Corporation has not sold any personal information, but has disclosed the following categories of personal information for a business purpose:

Category A — Identifiers

Category B — California Customer Records

Category F — Internet history

Category G — Geolocation

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers
• Data brokers or aggregators
• Advertisers
• Affiliates
• Internet cookie data recipients, like Google Analytics

Your Consumer Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Vitruvi Corporation disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Vitruvi Corporation delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at +1.844.484.8788, or
• Sending a letter to us at Vitruvi Corporation 329 Railway St, Vancouver, BC, V6A 1A4, Canada

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.