GDPR & CCPA Privacy Addendum
Effective Date: 2026-01-08
This GDPR & CCPA Addendum supplements our Privacy Policy and applies to individuals located in the European Economic Area (“EEA”), the United Kingdom, Switzerland, and the State of California.
1. Scope & Applicability
This Addendum applies only to personal information processed by our platform. It does not apply to third-party websites, services, or partners that you may interact with through promotional offers.
2. Data Controller & Business Status
For purposes of applicable data protection laws:
● We act as a data controller (GDPR) and business (CCPA) for personal information
collected directly through our platform.
● Third-party partners act as independent controllers for information collected on their own platforms.
3. Lawful Bases for Processing (GDPR)
We process personal data under the following lawful bases:
● Performance of a contract (to provide membership services)
● Legitimate interests (to operate, secure, and improve our platform)
● Legal obligations (compliance with applicable laws)
● Consent, where required
4. Categories of Personal Information Collected
We may collect:
● Identifiers (name, email address, IP address)
● Account and subscription information
● Usage and interaction data
● Technical and device information
We do not knowingly collect sensitive personal data as defined by GDPR or CCPA.
5. Your Rights Under GDPR
If you are located in the EEA or UK, you may have the right to:
● Access your personal data
● Request correction or deletion
● Restrict or object to processing
● Request data portability
● Withdraw consent where applicable
Requests may be subject to verification and legal limitations.
6. Your Rights Under CCPA (California)
California residents may have the right to:
● Request disclosure of categories and purposes of personal information collected
● Request deletion of personal information
● Opt out of the “sale” or “sharing” of personal information (if applicable)
● Not be discriminated against for exercising privacy rights
We do not sell personal information as defined under CCPA.
7. Exercising Your Rights
Requests must be submitted through our Contact Us page.
We may require verification of your identity before processing requests.
We reserve the right to deny requests where permitted by law, including where requests are excessive, unfounded, or conflict with legal obligations.
8. Data Retention
Personal information is retained only as long as necessary to:
● Provide services
● Comply with legal requirements
● Resolve disputes
● Enforce agreements
9. International Data Transfers
Personal information may be processed and stored in jurisdictions outside your country of residence. We implement reasonable safeguards to protect such data.
10. Service Providers & Processors
We may share personal information with service providers (e.g., payment processors, hosting providers, analytics services) solely to operate our platform. These providers are contractually obligated to protect personal information and use it only for
authorized purposes.
11. Automated Decision-Making
We do not engage in automated decision-making or profiling that produces legal or similarly significant effects.
12. Limitation of Liability
To the maximum extent permitted by law, we disclaim liability for privacy practices of third-party partners, services, or websites linked from our platform.
13. Changes to This Addendum
We may update this Addendum from time to time. Updates will be posted with a revised effective date.
14. Contact
For privacy-related inquiries or rights requests, please contact us through our Contact Us page.
This Addendum supplements our Privacy Policy and does not create rights beyond those provided by applicable law.