PRIVACY POLICY

Last modified: December 22, 2020

Introduction

At Citizens Reserve, Inc., a Delaware corporation (“CRI” or “we”), we respect your privacy and are committed to protecting it through our compliance with this privacy policy (the “Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you download, install, register with, access or use our services, including our various websites, SMS, APIs, email notifications, applications, buttons, widgets, ads, commerce services, NFC tags, and other covered services that link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy applies to all of the information we collect:

●        Through use of the Services by you or persons with access to your device (e.g., PC, laptop, mobile phone) (the “Device”).

●        Through use of the Services by you or persons with access to your account that you create with us (the “Account”).

●        By phone, email, text message (SMS) and/or other electronic means between the Services and you or persons with access to your Account or Device.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, access or use our Services. By downloading, registering with, accessing or using the Services, or by allowing others to access or use the Services through your Account or Device, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Services or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We may collect several types of information from and about you through the Services, including information: (i) by which you may be personally identified, such as name, postal address, e-mail address, phone number or any other identifier by which you may be contacted online or offline (“personal information”); (ii) that you provide, upload or create; (iii) that is about your approximate location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers; (iv) that is about your internet connection and usage details; (vii) the equipment/device you use to access our Services based on an anonymous fingerprinting algorithm (e.g., https://panopticlick.eff.org); and (viii) that you otherwise provide directly, such as communications between you and us.

We collect this information: (i) directly from you or from persons with access to your Account or Device, in each case, when your Account or Device is accessed to login to or use our Services, (ii) directly from you or from persons with access to your Account or Device, in each case when provided to us or created for us, (iii) automatically as you or persons with access to your Account or Device navigate through the site, including usage details, IP addresses, and information collected through cookies, and (iv) from third parties.

When you download, access, and use our Services, they may use technology to automatically collect: (i) certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services; (ii) information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number; (iii) metadata and other information associated with other files stored on your device, which may include, for example, photographs, audio and video clips, personal contacts, and address book information; and (iv) real-time information about the location of your device.

If you do not want us to collect this information do not download, access or use our Services, and delete our Services from your device.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). The technologies we use for automatic information collection may include small files placed on your device (cookies) and/or small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs).

When you use our Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include analytic companies, your mobile device manufacturer and your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. We do not control these third parties' tracking technologies or how they may be used.

How We Use Your Information

We do not share your personal information with third parties other than as disclosed in this Privacy Policy.

We use information that we collect about you or that is provided to or created for us, including any personal information:

●        To present our Services and its contents to you.

●        To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

●        To notify you about changes to our Services or any services we offer or provide though it.

●        To allow you to participate in interactive features on our Services.

●        To survey you and other users about how we can improve our Services.

●        In any other way we may describe when you provide the information.

●        For any other purpose with your consent.

In addition, if you have enabled the device location services on your mobile device, you may enable CRI to share your location with other users from the time that you access our Services.

Certain third-party companies and individuals provide or facilitate certain aspects of the Services on our behalf. We provide these third-party service providers with access to your information, including your phone number, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your personal information similar to the ones that we provide.

For example, we may periodically send you text messages through a third-party cloud communications service provider. If you respond to these text messages by text message, the service provider may receive your phone number and text message in real time and store certain data, including the content, date and time of your text message.

We may use videos and other content you upload for marketing purposes.  In addition, all videos and content uploaded by you are property of CRI, as permitted by law.

This Privacy Policy will be applied to any personal information received from third parties, unless we have disclosed otherwise.

Disclosure of Your Information

We may disclose personal information that we collect or that is provided to or created for us as described in this Privacy Policy:

●        To our subsidiaries and affiliates.

●        To contractors, service providers, and other third parties we use to support our business.

●        To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CRI’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CRI about our users is among the assets transferred.

●        To fulfill the purpose for which we provide the Services.

●        For any other purpose disclosed by us when you provide the information.

●        With your consent.

We may also disclose your personal information:

●        To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

●        To enforce or apply our terms of service (getinfinite.io/terms).

●        If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CRI, our customers, or others.

Accessing and Correcting Your Personal Information

If you believe that your personal data has been stored, you may send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. We adopt this notice to comply with the California Consumers Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Our mobile application has collected the following categories of personal information from its consumers within the last 12 months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

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

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 categories.

YES

C. Protected classification characteristics under California or federal law.

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).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

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.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

NO

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

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)).

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.

NO

K. Inferences drawn from other personal information.

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

NO

Personal information does not include:

●        Publicly available information from government records.

●        Deidentified or aggregated consumer information.

●        Information excluded from the CCPA's scope, like:

·       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.

CRI obtains the categories of personal information listed above from the following categories of sources:

●        Directly from you. For example, from the completion of your profile data using any of our Services.

We may use or disclose the personal information we collect for one or more of the following purposes:

●        To fulfill or meet the reason you provided the information.

●        To provide, support, personalize, and develop our Services.

●        To create, maintain, customize, and secure your account with us.

●        To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.

●        For testing, research, analysis, and product development, including to develop and improve our 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.

●        To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CRI's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CRI about our mobile application users is among the assets transferred.

CRI 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.

California – Sharing Personal Information

CRI 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.

California – Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, Company has not disclosed personal information for a business purpose.

California – Sales of Personal Information

In the preceding 12 months, Company had not sold personal information.

California – Your Rights and Choices

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.

California – Access to Specific Information and Data Portability Rights

You have the right to request that CRI 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 California – 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.

California – Deletion Request Rights

You have the right to request that CRI 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 California – 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:

·       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 activities.

·       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.

California – 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:

·       Visiting: www.suku.world/

·       Contacting: [email protected]

Only you, or someone legally authorized 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.

For instructions on exercising sale opt-out rights, see California – Personal Information Sales Opt-Out and Opt-In Rights.

California – Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 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 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.

California – Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

·       Deny you goods or services.

·       Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

·       Provide you a different level or quality of goods or services.

·       Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California – Other California Privacy Rights

California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us at: 481 N Santa Cruz Ave #105, Los Gatos, California 95030.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Changes to Our Privacy Policy

The date the Privacy Policy was last revised is identified at the top of the Privacy Policy. You are responsible for periodically visiting this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: 481 N Santa Cruz Ave #105, Los Gatos, California 95030 or [email protected].