Sleeptracker-AI Privacy Notice

Last updated on May 18, 2023

This Privacy Notice (“Notice”) applies to the Sleeptracker®-AI App, Sleeptracker®-AI Cloud, Sleeptracker®-AI Premium Services, Sleeptracker®-AI Sleep Coach, the Sleeptracker Google Assistant Action, and the Sleeptracker Amazon Alexa Skill (collectively, “Sleeptracker-AI”). Fullpower Technologies, Inc. (“Fullpower,” “we,” or “us”) is the developer of Sleeptracker-AI and is responsible for this Notice and the collection of data from Sleeptracker-AI.

This Notice explains our practices for the collection and processing of user information collected from or about the users of Sleeptracker-AI (i.e., “you”). This Notice is unique to Sleeptracker-AI and differs from other privacy policies of Fullpower, affiliates of Fullpower, and data collected separately by business partners of Fullpower, including, but not limited to, Tempur World, LLC. Please carefully review this Notice.

1. Overview of Personal Information We Collect

We collect information that can be used to identify you or that we can link directly or indirectly to you (“Personal Information”) in connection with your use of Sleeptracker-AI. The chart below provides an overview of:

the categories of Personal Information we collect and receive;
the sources from which we collect your Personal Information;
the purpose for which we collect your Personal Information; and
the persons or entities with whom we share your Personal Information.

This chart is for summary purposes only. For additional details, please refer to Sections 2 through 4 below.

Categories of Personal Information we collect	Where we get your Personal Information See section 2 for more information	Why we collect your Personal Information See section 3 for more information	Who we share your Personal Information with See section 4 for more information
Identifiers. Such as a name, email address, or other similar identifiers	Directly from you Automatically from your computer or mobile device/apps Our business partners	To provide, configure, customize, and improve your use of Sleeptracker-AI services To receive and respond to customer support inquiries for Sleeptracker-AI To communicate with you To market our products and services to you	Amazon Web Services Other third parties, with your consent
Activity Data. Such as Sleeptracker-AI under-the-mattress sensor (i.e., your heart rate, breathing rate, and movements while sleeping); your bedroom environment: air temperature, humidity, and purity (relative level of volatile organic compounds).	Automatically from Sleeptracker-AI devices	To provide, configure, customize, and improve your use of Sleeptracker-AI services	Amazon Web Services Other third parties, with your consent
Protected Classification Characteristics. Such as age (e.g. 40 years or older), or sex (including gender, gender identity, gender expression).	Directly from you	To provide, configure, customize, and improve your use of Sleeptracker-AI services	Amazon Web Services Other third parties, with your consent
Internet or other similar network activity. Such as information on a consumer’s interaction with a website or application.	Automatically from your computer or mobile device/apps Automatically from Sleeptracker-AI devices	To provide, configure, customize, and improve your use of Sleeptracker-AI services	Amazon Web Services Flurry analytics Other third parties, with your consent
Inferences drawn from other Personal Information. Such as a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Automatically from Sleeptracker-AI devices	To provide, configure, customize, and improve your use of Sleeptracker-AI services	Amazon Web Services Other third parties, with your consent

Sensitive Information

In some jurisdictions, some of the Personal Information described above may be considered “sensitive” or a “special category” of information (“Sensitive Information”) because certain information may: relate to your health, including heart rate and sleep patterns; identify your sex (including gender, gender identity, gender expression); or include approximate geolocation.

For clarity, Sleeptracker-AI does not collect or process cookies.

2. How We Collect and Store Your Personal Information

We collect information as follows.

Directly From You

Your sleeper profile: When you set up your sleeper profile in Sleeptracker-AI, we may collect your name, email address, encrypted password, height, weight, gender, date of birth, location of the Sleeptracker-AI unit, type of bed, type of mattress.
Behavioral insights: If you opt in, we collect information you may volunteer about the behavioral categories you select in the app, such as your stress level, the quality of your sleep, your physical activity, your use of tobacco or caffeine products, and others.
When you contact us: If you email or call us, we may collect your name, email address, mailing address, telephone number, and any other Personal Information you voluntarily provide.

Automatically From Your Computer or Mobile Device/Apps

Mobile device data: Sleeptracker-AI may request access to other data or applications on your mobile device. It can connect to the camera, location service, and health information database, but only with your permission. Personal Information from your mobile device is processed for the purpose of assisting you in setting up and configuring Sleeptracker-AI. Once Sleeptracker-AI is fully installed and configured, you can revoke the Sleeptracker-AI’s access to these services. You can also install Sleeptracker-AI without them.
Health apps: We may ask you to share your Apple HealthKit and/or Google Fit data with Sleeptracker-AI. We collect and process information received through your smartphone and connected device(s) via the Apple HealthKit and/or Google Fit application with your consent. Personal Information collected or processed from Apple HealthKit and/or Google Fit is used for the purpose of enhancing your experience with Sleeptracker-AI. If you do not want to provide this information, please do not utilize these applications or do not provide consent for us to receive and process the HealthKit and/or Google Fit application data.

Automatically from Sleeptracker-AI Devices

Device information: This information includes under-the-mattress sensor device identifiers, and the date and time of your request.
Under-the-mattress sensor data for your side of the bed: Your heart rate, breathing rate, and movements while sleeping
Under-the-mattress sensor data for the other side of the bed: If another person or a pet sleeps in your bed, Sleeptracker-AI will use their heart rate, breathing rate, and movements to better isolate your signal and improve sensor accuracy for you
Your bedroom environment: Air temperature, humidity, and purity (relative level of volatile organic compounds)

Third Parties

Business partners: Our business partners, including Tempur, may disclose your Personal Information to us to respond to Sleeptracker-AI customer service inquiries you make to such partners. Such Personal Information may include your contact information and any other information you provide our business partners.

Please note that you may have the right, under your local laws, to suspend our processing of your Personal Information from third parties. Please see Section 6 (“Your Rights to Your Personal Information”), for more information regarding these and other rights you may have over your Personal Information.

With Separate Consent

We may obtain your consent to collect and use certain types of Personal Information—particularly Sensitive Information—when we are required to do so by law. If we ask for your consent to process your Personal Information, you may withdraw your consent at any time by contacting us using the details in Section 11 of this Notice. If you refuse to consent to collect and use of your Personal Information (including Sensitive Information), you may not be able to use Sleeptracker-AI.

3. How and Why We Use Your Personal Information

We use Personal Information to provide Sleeptracker-AI services to you. We also use the Personal Information we collect to contact you, provide you with customer service, conduct research, improve our products and services, and customize your experience with our products and services. We may aggregate, de-identify, and/or anonymize Personal Information such that it is no longer considered Personal Information under your local laws. For the purposes of this Notice, “Anonymized Information” means Personal Information that has been aggregated, de-identified, and/or anonymized such that it is no longer considered Personal Information under your local laws.

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, where required by law, we will notify you, explain the legal basis which allows us to do so, and, if required by law, obtain your consent. Please note that we may process your Personal Information without your knowledge or consent, where this is required or permitted by law.

4. How We Share Your Personal Information

Personal Information

We share your Personal Information with Amazon Web Services (“AWS”) on servers in the United States to host the Personal Information processed in connection with Sleeptracker-AI.
We use Flurry Analytics (a Yahoo! company) to monitor and analyze the use of Sleeptracker-AI. To the extent we disclose your Personal Information to Flurry Analytics, we do so to improve the Sleeptracker-AI services. You can opt out from the Flurry Analytics service to prevent Flurry Analytics from using and sharing your information by visiting Flurry's opt-out page: https://developer.yahoo.com/flurry/end-user-opt-out/. For more information on the privacy practices and policies of Yahoo!, please visit their Privacy Policy page: https://policies.yahoo.com/xa/en/yahoo/privacy/.
Some third parties also collect information on other websites or mobile applications. If you have downloaded the Sleeptracker-AI mobile application, these third parties may include the mobile application marketplace (such as the Apple App Store or the Google Play Store) from which you downloaded the application. Similarly, you may have downloaded the Sleeptracker Google Assistant Action or the Sleeptracker Amazon Alexa Skill for your smart device. Please refer to your relevant marketplace’s privacy policy to understand how they collect and use your Personal Information.
When permitted by applicable law, we also disclose Personal Information to third parties such as law enforcement agencies and government authorities; subject to a court order or subpoena; to respond to and resolve claims or complaints; to prevent fraud or for risk management purposes; for research and analytics purposes; and to comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity.
In the event that we are contemplating selling, assigning, or transferring all or part of our assets, including at bankruptcy, we may transfer information, including your Personal Information, to the potential or actual buyer. In this event, we will notify you in advance of any transfer of your Personal Information and, if we process your Personal Information with your consent, we will provide you the method and procedure to withdraw the consent if you do not want your Personal Information transferred. Please note that if you withdraw your consent, you may not be able to continue using Sleeptracker-AI.
We may also share your Personal Information in other circumstances with your consent and in accordance with applicable law.
If you connect Sleeptracker-AI with a health app on your mobile device (such as Apple Health or Google Fit), we can share sleep analysis, height, weight, heart rate, and breathing rate information with that app based on the permissions you set in the health app settings.
We will not disclose any of your Personal Information to advertising platforms, data brokers, or information resellers, or for advertising, marketing, or use-based data mining purposes. We will not disclose such information to other third parties without your consent. We do not use automatic decision-making (i.e., making decisions solely by automated means without any human involvement) or profiling (i.e., automated processing of Personal Information to evaluate certain aspects of an individual) in a manner that produces legal effects on you or for the purposes of advertising. As discussed in the California section below, we do not “sell” or “share” your personal information as those terms are defined under California privacy law.

Anonymized Information

We share Anonymized Information with Tempur World LLC, our bedding manufacturer partner, and its agents, contractors and affiliated entities, including Tempur Sealy International, Inc. ("Tempur"). Tempur and Fullpower may use such Anonymized Information to develop and improve new and current products and services, analyze trends, conduct research, and analyze and publish data related to use of the Sleeptracker-AI and Tempur products.

From time to time, we publish Anonymized Information, including facts and statistics derived from Personal Information, on our website and other social or traditional media outlets.

From time to time, we will share Anonymized Information with our scientific research partners, and may publish from time to time results of the research in scientific journals.

5. How We Will Notify You If Our Notice Changes

We keep this Notice under regular review to make sure it is up to date and accurate.If we change this Notice, we will post the updated Notice and its last updated date on this page. If Fullpower makes material changes that reduce your privacy rights, Fullpower will notify you in advance by sending you an email and/or by posting a notice in the Sleeptracker-AI services.

6. Your Rights to Your Personal Information

Access, portability, amendment, deletion, restriction of processing, accounting of disclosures

You may request to:

review your Personal Information;
obtain portable copies of your Personal Information;
make amendments to your Personal Information;
have your Personal Information deleted;
suspend or restrict certain processing of your Personal Information;
obtain an accounting of disclosures of your Personal Information; or
otherwise exercise your rights, under applicable privacy laws, over your Personal Information that we hold, subject to certain limitations under applicable law.

You may submit a request to us related to your Personal Information by emailing us at privacy@fullpower.com. Please note that we may maintain copies of Personal Information that you have updated, modified, or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law. Your access to or correction of your Personal Information is subject to applicable legal restrictions and the availability of such information. Further, we may take reasonable steps to verify your identity before granting such access or making corrections.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality that we owe to others, if we are legally entitled to deal with the request in a different way, or if relevant exemptions apply to some or all of the Personal Information subject to the request.

Right to non-discrimination

In some jurisdictions, you may have the right not to be subject to discriminatory treatment for exercising your rights under applicable privacy laws. We will not discriminate against you for exercising any of the rights described in this section.

Additional information for certain jurisdictions

Fullpower is committed to respecting the privacy rights of individuals under all privacy laws applicable to us. At the end of this Notice, we provide specific information for individuals in certain jurisdictions, as required under certain privacy laws:

General Data Protection Regulation (“GDPR”) – EEA/UK: Section 12 below provides information about data subject rights under the EU and UK GDPR and UK Data Protection Act.

California Consumer Privacy Act (“CCPA”) – California Residents: Section 13 below sets forth additional information for California residents, about their rights under the CCPA.

7. Retention of Your Personal Information

Fullpower retains Personal Information in identifiable form only for as long as necessary to fulfill the purposes for which the Personal Information was provided to Fullpower as described above in Sections 1 and 3. We may retain Personal Information for a longer period to comply with legal obligations, resolve disputes, enforce agreements, and for similar essential purposes. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.We have established internal policies and procedures regarding retention periods applicable to your Personal Information.

If we share your Personal Information with third parties as described in Section 4, unless prohibited under local law, we enter into agreements that allow recipients to retain your Personal Information for as long as necessary to fulfill the purposes for which the Personal Information was provided to them.

8. Transfers and Storage of Your Personal Information

Fullpower and its servers are located in the United States. If you are located outside of the United States—such as in the European Economic Area (“EEA”), the United Kingdom (“UK”), Switzerland, Japan, Australia, New Zealand, Singapore, or the Republic of Korea—your Personal Information will be transferred to and stored in the United States and other jurisdictions in which we or our vendors operate. The data protection laws in these jurisdictions may not be equivalent to those in your jurisdiction of residence. We transfer your Personal Information from your location to the United States for data storage related to Sleeptracker-AI, which is necessary to provide you the services under our End User License Agreement.

Additionally, we will take steps to ensure that your Personal Information is subject to appropriate safeguards, including, where required, by implementing appropriate adequacy measures, such as the EU standard contractual clauses (as approved by the European Commission) for the transfer of Personal Information to processors established in third countries. The current forms for the standard contractual clauses can be found at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN.

Regardless of where your Personal Information is stored, it is subject to the retention periods (see Section 7) and security measures (see Section 10) explained in this Notice.

For additional information regarding the mechanism under which your Personal Information is transferred across national borders, you may contact us as set forth below in Section 11 (Contact and Comments).

9. Children's Privacy

Sleeptracker-AI is not intended for and may not be used by children under the age of 16. We do not knowingly collect Personal Information from children under the age of 16. If we learn that we have collected Personal Information from or about a child under the age of 16, we will delete that Personal Information from our systems.

10. Security of Information

Fullpower takes precautions intended to help protect information that we process, but no system or electronic data transmission is completely secure. Any transmission of your Personal Information is at your own risk, and we expect that you will use appropriate security measures to protect your Personal Information.

You are responsible for maintaining the security of your account credentials for the Sleeptracker-AI services. Fullpower will treat access to the Sleeptracker-AI services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. As set forth in the End User License Agreement, we may suspend your use of all or part of the Sleeptracker-AI services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

If we become aware of a breach that affects the security of your Personal Information, we will provide you with notice where required by applicable law. To the extent permitted by applicable law, Fullpower will provide any such notice that Fullpower must provide to you under applicable law at your account’s email address. By using the Sleeptracker-AI services, you agree to accept notice electronically.

11. Contact and Comments

If you have any questions or concerns related to this Notice or our Personal Information practices, please email us at privacy@fullpower.com or by phone at +1.831.460.7070. You may also contact us via postal mail at:

David Shanes

Data Protection Officer
Fullpower Technologies, Inc.
1200 Pacific Avenue, Suite 300
Santa Cruz, California 95060
United States of America

12. For Users in the European Union (“EU”) European Economic Area (“EEA”) and the United Kingdom (“UK”)

To the extent that the EU and UK GDPR or the UK Data Protection Act applies to our processing of your Personal Information, we are the data controller in respect of the Personal Information that we collect and use for the purposes indicated in Sections 1, 2, and 3 of this Notice.

Our Obligations

Under EU and UK GDPR, as a data controller, we are obligated to implement appropriate technical and organisational measures:

to ensure and to be able to demonstrate that processing of your Personal Data is performed in accordance with the applicable law;
for ensuring that, by default, only Personal Data which are necessary for each specific purpose of the processing are processed; and
which are designed to implement data-protection principles.

We are also obligated to:

maintain a record of processing activities under our responsibility;
cooperate, on request, with the supervisory authority in the performance of our tasks; and
notify, in some instances, the supervisory authority and/or you in the event of a Personal Data breach; and
designate a data protection officer.

Legal bases of processing

Certain laws, including the GDPR and the UK Data Protection Act, require that we inform you of the legal bases for our processing of your Personal Information. Pursuant to the GDPR (and other similar relevant laws, such as the UK Data Protection Act), we may process Personal Information for the following legal bases:

Performance of contract: processing of your Personal Information which is required for us to perform obligations or exercise rights under contracts that you may have with us (for example, if you use our services).
Compliance with laws: to comply with our legal obligations (for example, maintaining information in accordance with tax, audit, or company law requirements and responding to legal process).
Our legitimate business interests: in furtherance of our legitimate business interests including:
- to facilitate your participation in interactive features you may choose to use on our websites and services and to personalize your experience with the services by presenting content tailored to you;
- to correspond with you, notify you of events or changes to our services, or otherwise respond to your queries and requests for information, which may include marketing to you;
- to provide and personalize the services;
- for data analysis, audits, fraud monitoring and prevention, and developing new products, enhancing, improving or modifying our websites, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities; and
- to protect and defend our legal rights and interests and those of third parties.
With your consent: Where applicable laws require that we obtain your consent to collect and process your Personal Information, we will obtain your consent accordingly. When we obtain your consent, the GDPR (where it applies) and other applicable laws give you the right to withdraw your consent without penalty. You can do this at any time by contacting us using the details in this Notice. If you withdraw your consent, you may not be able to use Sleeptracker-AI.

Your rights

You may have the following rights, in relation to Personal Information that we collect and use for the purposes indicated in Sections 1, 2, and 3 of this Notice, under the EU and UK GDPR and UK Data Protection Act:

to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and where that is the case, to request access to the Personal Information. The accessed information includes – among others – the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. You have the right to obtain a copy of the Personal Information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs;
to correct any Personal Information that we hold about you;
to have your Personal Information removed under certain circumstances unless continued processing is necessary by law;
to have the processing of your Personal Information restricted where you dispute its accuracy, if you think its processing is unlawful, or if you otherwise object to its processing, or when Fullpower no longer needs your Personal Information and you need it in relation to a legal claim;
to object at any time to any processing of your Personal Information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded;
to request that your Personal Information is provided to you or is transferred to another organization (right to data portability);
to withdraw your consent to direct marketing or request that we change the manner in which we contact you for marketing purposes. You can withdraw your consent so that we do not transfer your Personal Information to unaffiliated third parties for the purposes of direct marketing or any other purposes;
to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside the EU/EEA/UK. We may redact data transfer agreements to protect commercial terms;
to complain to your national data protection regulator if you feel that any of your Personal Information is not being processed in accordance with the GDPR; and
to withdraw your consent, where the processing of your Personal Information is based on consent (see the How We Collect and Store Your Personal Information section above); if you withdraw your consent, Fullpower will stop processing your Personal Information.

You may submit a request to us regarding your Personal Information held by Fullpower by email at privacy@fullpower.com. You may also submit a request to us by phone at +1.831.460.7070. Please note that we may rely on applicable exemptions under EU, Member State, or UK law in order to deny part or all of your request. If we do so, we will inform you when responding to your request. If you are not satisfied with our response, you may lodge a complaint with your supervisory authority.

Data Protection Officer (“DPO”)

You may contact our DPO at:
+1.831.460.7070
privacy@fullpower.com

Our EU Representative:

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:

Company: Instant EU GDPR Representative Ltd
Name: Adam Brogden
Email: contact@gdprlocal.com
Tel: +353 15 549 700
Reporting link: https://fullpowertechnologiesinc.gdprlocal.com/eu
Address: Instant EU GDPR Representative Ltd, Office 2 12A Lower Main Street, Lucan Co Dublin K78 X5P8 Ireland

Our UK Representative:

Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is:

Company: GDPR Local Ltd
Name: Adam Brogden
Email: contact@gdprlocal.com
Tel: +441 772 217 800
Reporting link: https://fullpowertechnologiesinc.gdprlocal.com/uk
Address: GDPR Local, Ltd,1st Floor Front Suite 27-29 North Street, Brighton, England BN1 1EB

13. California Residents

In this section, we provide information for California residents in connection with the CCPA. Fullpower does not currently qualify as a “business” as defined under the CCPA and is not subject to the CCPA’s requirements, enforcement mechanisms, or any private right of action arising under the CCPA. Fullpower has, however, voluntarily provided the following disclosures in line with the CCPA’s relevant provisions.

Categories of Personal Information We May Collect and Disclose.
Our collection, use, and disclosure of Personal Information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. In particular, the Sleeptracker-AI services collect, or may have collected in the last twelve (12) months, the categories of Personal Information as described in Section 1 above.

Use of Personal Information. We may use or disclose the Personal Information we collect for one or more of the business purposes indicated in Section 3 above.

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.

Categories of Personal Information Sold. The CCPA defines a “sale” as disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration. We do not sell Personal Information or share Personal Information for the purposes of cross-context behavioral advertising.

Sources of Personal Information. We have collected the above categories of Personal Information from the following sources:

directly from you;
automatically from your computer or mobile device;
automatically from third-party apps on your mobile device, subject to your permission
automatically when you use Sleeptracker-AI;
third parties.

Disclosures of Personal Information: We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business 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. We share your Personal Information with the categories of third parties listed in Section 4 above.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

Identifiers;
Activity Data;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
Protected Classification Characteristics;
Internet or other similar network activity;
Geolocation data;
Sensory data; and
Inferences drawn from other Personal Information.

We do not sell Personal Information or share Personal Information for the purposes of cross-context behavioral advertising. In the event that we do sell any Personal Information or share Personal Information for the purposes of cross-context behavioral advertising, we will update this Notice to list the categories of consumers’ Personal Information sold or shared for the purposes of cross-context behavioral advertising.

CCPA Rights: California law grants California residents certain rights as set forth below.

Do Not Sell/Do not Share: California residents have the right to opt out of the sale of their Personal Information and the sharing of their Personal Information for the purposes of cross-context behavioral advertising. We do not sell Personal Information or share it for the purposes of cross-context behavioral advertising, including Personal Information about residents who we know are younger than 16 years old.
Requests to Delete: Subject to certain exceptions, California residents have the right to, at no charge, request deletion of their Personal Information that we have collected about them and to have such Personal Information deleted, except where an exemption applies.
Requests to Correct Inaccurate Personal Information: California residents have the right to request that we correct any inaccurate Personal Information about them.
Requests to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of Personal Information that we have collected about them in the prior 12 months and to receive information about how we have handled their Personal Information in the prior 12 months, including the:
- categories of Personal Information collected;
- categories of sources of Personal Information;
- business and/or commercial purposes for collecting and selling their Personal Information;
- categories of third parties to whom we have disclosed or shared their Personal Information;
- categories of Personal Information that we have disclosed or shared with a third party for a business purpose; and
- categories of third parties to whom the residents’ Personal Information has been sold and the specific categories of Personal Information sold to each category of third party.

California residents may make a Request to Know up to twice every 12 months.

Right to Non-discrimination: California residents have the right not to be subject to discriminatory treatment for exercising their rights under the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

Submitting Requests. To exercise the access, data portability and deletion rights described above, you may email us at privacy@fullpower.com or via our contact form.

When processing a request by email or phone, we will take steps to verify your request by matching the information provided by you with the information we have in our records. To verify a request, we may ask for your name, email address, and any other information you have submitted to us. If we are unable to adequately verify a request, we will notify the requestor. In some cases, we may request additional information in order to verify your request or where necessary to process your request.

Only you, or a person 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 such a 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, and 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 endeavor 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. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. 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 useable 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.