PRIVACY POLICY

Last updated December 12, 2023

This privacy notice for Handy Data Services, LLC (“we,” “us,” or “our“) outlines our practices and reasons for collecting, storing, using, and/or sharing (“processing“) your information when engaging with our services (“Services“), which includes scenarios such as:

• Accessing our website at https://www.handyrecovery.com/, or any of our websites that direct to this privacy notice

• Interacting with us in other ways, including sales, marketing, or events

Have questions or concerns? This privacy notice aims to inform you about your privacy rights and choices. If you disagree with our policies and practices, refrain from using our Services. For any further inquiries or concerns, please reach out to us at help@handyrecovery.com.

KEY POINTS SUMMARY

This brief overview highlights crucial points from our privacy notice. For comprehensive details on any of these topics, click the link provided for each key point or use our table of contents to navigate to the desired section.

• What personal information do we handle? We may process personal information when you visit, use, or interact with our Services, based on your interactions, your choices, and the products and features you use. Discover more at personal information you disclose to us.
• Do we handle any sensitive personal information? We do not process sensitive personal information.
• Do we receive information from third parties? We do not obtain information from third parties.
• How do we utilize your information? Your information is used to deliver, enhance, and manage our Services, to communicate with you, for security and fraud prevention, and to adhere to legal requirements. We may also use your information for other purposes with your consent. Our processing of your information is always based on valid legal grounds. Learn more at how we process your information.
• In which scenarios and with whom do we share personal information? We may share your information under specific circumstances and with particular third parties. Find out more at when and with whom we share your personal information.
• How do we safeguard your information? We employ organizational and technical measures to protect your personal information. However, we must caution that no electronic transmission or storage technology can be entirely secure, and we cannot fully guarantee that our security measures will prevent illicit access, theft, or modification of your information by unauthorized parties. Discover more at how we keep your information safe.
• What rights do you have? Depending on your geographical location, certain privacy laws may grant you specific rights regarding your personal information. Learn more at your privacy rights.
• How can you exercise your rights? The most straightforward method to exercise your rights is by submitting a data subject access request or by contacting us. We will respond to and act upon any such request in accordance with the relevant data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal Information Provided by You

Summary: We acquire personal information that you willingly submit to us.

We gather personal information that you willingly furnish when expressing interest in our information, products, and Services, participating in activities within the Services, or in communications with us.

Sensitive Data Handling. We do not engage in the processing of sensitive data.

It is imperative that all personal information you supply be accurate, complete, and current, and you are obliged to inform us of any modifications to such personal information.

Automated Information Collection

Summary: Certain information, such as your IP address and device specifics, is automatically collected upon your visit to our Services.

Our Services automatically capture specific types of information as you visit, utilize, or navigate them. This data may include but is not limited to, your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, details on usage and interaction with our Services, and other technological data. This collection is essential for maintaining the security and functioning of our Services and for internal analysis and reporting.

Consistent with numerous businesses, we gather information through cookies and similar technologies. Detailed information regarding this can be accessed in our Cookie Notice: https://www.handyrecovery.com/cookie-policy/.

The categories of information we accumulate comprise:

• Log and Usage Data. This encompasses service-related, diagnostic, usage, and performance information that our servers automatically collect and log when you access or use our Services. This log data might encompass your IP address, device specifics, browser type and settings, and details about your interactions with our Services (such as timestamps, viewed pages and files, searches, and features used), along with device event information (like system activity, error reports, and hardware configurations).
• Device Information. We gather data regarding the devices you utilize to access our Services, which may include IP addresses (or proxy servers), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect data regarding your device’s geographic location, which can range from precise to general. The extent of location data collected is contingent on the settings of the device you use to access our Services. For instance, we may utilize GPS and other technologies to ascertain your current location (derived from your IP address). You have the option to prevent us from collecting this information by denying access or deactivating your device’s Location setting. Be advised, that opting out might limit your ability to utilize certain features of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

Summary: We utilize your information for service provision, enhancement, administration, communication, security, fraud prevention, and legal compliance. Additional processing may occur with your consent.

Our processing of your personal information is driven by various factors, based on your interactions with our Services:

• For Critical Interests. When essential to safeguard an individual’s critical interests, such as preventing harm, we may process your information.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

Summary: We process your personal information based on necessary and legally valid reasons under applicable laws, including your consent, legal compliance, service provision, contractual obligations, protection of rights, or legitimate business interests.

For EU or UK residents:

We adhere to the General Data Protection Regulation (GDPR) and UK GDPR, which mandate the clarification of legal bases for processing personal information. We rely on the following grounds:

• Consent. Your information may be processed based on your given consent for specified purposes. Consent withdrawal is possible at any time. For details, visit withdrawing your consent.
• Legal Compliance. We process information as necessary to fulfill our legal obligations, cooperate with authorities, defend our legal rights, or provide evidence in legal proceedings we are involved in.
• Protection of Vital Interests. We may process information when it is critical for safeguarding your vital interests or those of another person, particularly in scenarios posing potential risks to individual safety.

For residents of Canada:

Our processing of your information can be based on explicit (express) consent or inferred (implied) consent. You have the option to withdraw consent at any moment.

In certain exceptional situations, legal allowances may enable us to process your information without consent:

• In scenarios where an individual’s interests are paramount and timely consent acquisition is impractical
• For investigatory and fraud detection/prevention purposes
• Within the context of business transactions, subject to specific conditions
• When dealing with witness statements necessary for insurance claim processing
• In identifying individuals who are injured, ill, or deceased, and in communicating with their next of kin
• If there is a reasonable belief of an individual being a victim of financial abuse
• When consent-based collection might compromise information availability or accuracy, and the collection is pertinent to investigating an agreement breach or legal violation
• In compliance with legal orders such as subpoenas, warrants, or court-ordered record production
• When information is produced in a professional or business context and aligns with the purposes for which it was generated
• For journalistic, artistic, or literary purposes exclusively
• When dealing with publicly available information as defined by regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Summary: Information may be shared in particular situations or with designated third parties.

We might need to disclose your personal information under circumstances such as:

• Corporate Transactions. In the context of mergers, asset sales, financing, or acquisitions of our business or a portion thereof, your information may be shared or transferred to another entity.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Summary: Cookies and similar tracking technologies are utilized for information collection and storage.

Cookies and comparable technologies such as web beacons and pixels are employed to gather and store data. Detailed insights on our usage of these technologies and your options regarding specific cookies are outlined in our Cookie Notice: /cookie-policy/.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

Summary: Your information is retained as long as necessary for the objectives stated in this privacy notice, except as required otherwise by law.

Your personal information will be maintained only for the duration needed for the purposes specified in this privacy notice, unless the law mandates or permits a prolonged retention period (for instance, due to tax, accounting, or other legal mandates).

Should there be no continued legitimate business need to process your personal information, we will proceed to delete or anonymize it. In cases where deletion or anonymization is not feasible immediately (for instance, if your information is contained in backup archives), we will securely store and isolate your personal information from any further processing until deletion can be implemented.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

Summary: We implement organizational and technical measures to safeguard your personal information.

We have instituted suitable technical and organizational security measures to protect the personal information we process. However, it is important to recognize that no method of electronic transmission or storage is infallible, and we cannot guarantee absolute security against the potential breaches by hackers, cybercriminals, or other unauthorized entities. While we endeavor to protect your personal information, any transmission to and from our Services is at your own risk. We recommend accessing our Services only within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

Summary: We do not intentionally collect or market to children under 18 years of age.

We do not purposefully solicit or market to children under 18 years of age. By using the Services, you assert that you are over 18 or are the parent or guardian consenting to the use of the Services by a minor dependent. If we discover that we have collected personal information from users under 18 years of age, we will deactivate the account and endeavor to promptly delete such data from our records. Should you become aware of any data we have collected from children under 18, please contact us at help@handyrecovery.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

Summary: In certain regions, like the EEA, UK, Switzerland, and Canada, you possess rights granting more control over your personal information. You may review, modify, or terminate your account anytime.

In regions such as the EEA, UK, Switzerland, and Canada, you have specific rights under the applicable data protection laws. These rights may include (i) accessing and obtaining a copy of your personal information, (ii) requesting correction or deletion; (iii) restricting the processing of your personal information; (iv) if applicable, the right to data portability; and (v) objecting to automated decision-making. You may exercise these rights by contacting us using the contact information in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” section below.

We will respond to and act upon any such requests in accordance with the applicable data protection laws.

If located in the EEA or UK and you believe our processing of your personal information is unlawful, you also have the right to lodge a complaint with your local data protection authority or the UK data protection authority.

For those in Switzerland, the contact point is the Federal Data Protection and Information Commissioner.

Withdrawing Consent: You have the right to withdraw your consent to process your personal information at any time, whether this consent is express or implied, as per applicable law. Withdrawal can be done by contacting us as detailed in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” section. Note that withdrawal does not affect the lawfulness of processing before its withdrawal, nor processing based on other lawful grounds other than consent.

Regarding Cookies and Similar Technologies: Most web browsers accept cookies by default, but you can typically modify your browser settings to remove or reject cookies. Opting out of cookies may impact the functionality of our Services. For more information, please refer to our Cookie Notice: #.

For any questions or concerns about your privacy rights, feel free to email us at help@handyrecovery.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Many web browsers, along with certain mobile operating systems and mobile applications, offer a Do-Not-Track (“DNT”) option that you can enable to express your preference against having your online browsing activities monitored and recorded. Currently, there is no consistent technological standard for recognizing and implementing DNT signals. Consequently, we do not presently acknowledge or act on DNT browser signals or any similar mechanism that conveys your decision against online tracking. Should a standard for online tracking emerge that necessitates our compliance, we will update you about this practice in a revised version of this privacy notice.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Summary: Residents of certain states in the United States, including Virginia, Utah, Connecticut, Colorado, and California, have specific rights regarding their personal information.

Categories of Personal Information Collected

Over the past twelve (12) months, we have collected the following types of personal information:

We retain and use the collected personal information as necessary to deliver our Services or for specific purposes such as:

• Category B – This type of information is not collected or retained by us.
• Category G – Managed in accordance with Google Analytics policy.

Additionally, we may collect personal information through direct interactions with you in various contexts, including, but not limited to:

• Assistance provided through our customer support channels;
• Participation in surveys or contests conducted by us; and
• Facilitating the delivery of our Services and responding to inquiries.

Usage and Sharing of Personal Information

For details on how we use your personal information, refer to the section, “HOW DO WE PROCESS YOUR INFORMATION?“.

Third-Party Sharing of Personal Information

Your personal information may be shared with service providers under a written contract between us and each provider. For more information on how we disclose personal information, see the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?“.

We may utilize your personal information for our internal business objectives, such as research for technological advancement. This is not considered as “selling” your personal information.

In the past twelve (12) months, we have not disclosed, sold, or shared any personal information to third parties for business or commercial purposes. We commit not to sell or share personal information of website visitors, users, and consumers in the future.

California Residents

Under California Civil Code Section 1798.83, also known as the “Shine The Light” law, California residents can annually request and obtain information free of charge about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. California residents wishing to make such a request should submit it in writing using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request the removal of unwanted data publicly posted on the Services. To request removal, contact us using the provided contact information, including the email associated with your account and stating you reside in California. We will ensure the data is not publicly displayed on the Services, but note that it may not be completely or comprehensively removed from our systems (e.g., backups).

CCPA Privacy Notice

This notice is specifically for residents of California, in line with the California Consumer Privacy Act (CCPA). As a California resident, you are entitled to certain rights as listed below.

According to the California Code of Regulations, a “resident” is defined as:

(1) an individual in California for purposes other than temporary or transitory, and

(2) an individual domiciled in California but currently outside the state for a temporary or transitory purpose.

Individuals not meeting these criteria are considered “non-residents.”

If you fall under the definition of “resident,” specific rights and responsibilities regarding your personal information apply to you and us.

Your Personal Data Rights

Right to Request Deletion of Data: You have the right to ask for the removal of your personal information. We will honor such requests and delete your personal information, except where legal exceptions apply, such as when it’s necessary for free speech, legal compliance, or to prevent illegal activities.

Right to Be Informed: You have the right to be informed about:

• our collection and use of your personal information;
• the types of personal information we collect;
• the purposes for using the collected personal information;
• any sale or sharing of personal information with third parties;
• the types of personal information we have sold, shared, or disclosed;
• the categories of third parties to whom the information was sold, shared, or disclosed;
• our business or commercial purposes for collecting, selling, or sharing the information; and
• specific personal information we have collected about you.

We are not required to provide or delete consumer information that is de-identified or to re-identify individual data for consumer request verification purposes under applicable law.

Right to Non-Discrimination: Exercising your CCPA rights will not result in discriminatory treatment.

Right to Limit Use and Disclosure of Sensitive Personal Information: We do not process sensitive personal information of consumers.

Verification Process: To process your request, we must verify your identity. We may ask for information to match with our existing records, or contact you via methods you have previously provided. Personal information provided in your request will be used solely for verification purposes. If necessary, we may request additional information for identity verification and security purposes, which will be deleted after verification.

Additional Privacy Rights:

• You may object to the processing of your personal information.
• You may request correction of your personal data or ask to restrict its processing.
• You can appoint an authorized agent to submit a CCPA request on your behalf, provided they have valid authorization under the CCPA.
• You may opt out from the future sale or sharing of your personal information to third parties. We will process such opt-out requests promptly, but no later than fifteen (15) days from the date of the request.

To exercise your rights, contact us via a data subject access request, email, or the contact details provided at the end of this document. We welcome any complaints about our handling of your data.

Colorado Residents

This section is dedicated to Colorado residents. Under the Colorado Privacy Act (CPA), you possess the rights outlined below. However, these rights are subject to limitations, and we may refuse your request as allowed by law.

• Right to know whether your personal data is being processed
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of personal data you’ve shared with us
• Right to opt out of the processing of your personal data for targeted advertising, sale of personal data, or profiling

To exercise these rights, please email help@handyrecovery.com or submit a data subject access request. If your request is declined, and you wish to appeal our decision, contact us at help@handyrecovery.com. We will respond to your appeal within forty-five (45) days, including an explanation of our decision.

Connecticut Residents

Exclusively for Connecticut residents, the Connecticut Data Privacy Act (CTDPA) grants the rights listed below. We may decline your request in certain cases as permitted by law.

• Right to know whether your personal data is being processed
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of personal data you’ve shared with us
• Right to opt out of the processing of your personal data for targeted advertising, sale of personal data, or profiling

To exercise these rights, please email help@handyrecovery.com or submit a data subject access request. If we decline your request, you can appeal our decision by contacting us. We will respond within sixty (60) days with our decision and its rationale.

Utah Residents

This section is applicable to Utah residents. The Utah Consumer Privacy Act (UCPA) endows you with the rights below. However, we may refuse your request in certain situations as allowed by law.

• Right to know whether your personal data is being processed
• Right to access your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of your personal data shared with us
• Right to opt out of the processing of your personal data for targeted advertising or the sale of personal data

To submit a request, email help@handyrecovery.com or use the data subject access request link.

Virginia Residents

For Virginia residents, as per the Virginia Consumer Data Protection Act (VCDPA):

“Consumer” refers to a natural person residing in Virginia acting in an individual or household capacity, excluding commercial or employment contexts.

“Personal data” is any information linked or linkable to an identified or identifiable natural person, excluding de-identified data or public information.

“Sale of personal data” is the exchange of personal data for monetary consideration.

If you are a “consumer” under this definition, specific rights and obligations regarding your personal data apply.

Your rights with respect to your personal data

• • Right to know whether your personal data is being processed

• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of personal data you’ve shared with us
• Right to opt out of the processing of your personal data for targeted advertising, sale of personal data, or profiling

Exercising Your Rights Under the Virginia VCDPA

To exercise your rights, you are welcome to reach out to us via email at help@handyrecovery.com or submit a data subject access request.

In cases where you are utilizing an authorized agent to exercise your rights, we reserve the right to deny the request if the agent fails to provide valid authorization evidence to act on your behalf.

Verification Process

We may need you to supply additional information, which is reasonably necessary, to confirm your identity and the authenticity of your request. If the request is made through an authorized agent, we might require further details to verify your identity before proceeding with the request.

Upon receipt of your request, we will respond promptly, but no later than forty-five (45) days from receipt. There may be an extension of an additional forty-five (45) days when necessary, in which case we will inform you of this extension and the reasons for it within the first 45-day period.

Right to Appeal

If we decide not to act on your request, we will communicate our decision and provide the reasons for it. Should you wish to appeal this decision, please contact us at help@handyrecovery.com. We will respond to your appeal within sixty (60) days, detailing any action taken or not taken, along with a written explanation for our decisions. If your appeal is not successful, you may file a complaint with the Virginia Attorney General.

12. DO WE MAKE UPDATES TO THIS NOTICE?

Summary: We periodically update this notice to ensure compliance with applicable laws.

Our privacy notice may undergo updates from time to time. The “Revised” date will indicate the latest update, and the new version becomes effective upon being accessible. Should there be significant changes to our privacy notice, we will either prominently post a notice regarding these changes or directly notify you. We recommend regularly reviewing this notice to stay informed about how we safeguard your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

For any inquiries or feedback regarding this notice, you may contact us via email at help@handyrecovery.com or by mail at:

• Handy Data Services, LLC
• 32 N. Gould St.
• Sheridan, WY 82801
• United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You are entitled to review, amend, or request the deletion of the personal information that we have collected. To initiate this process, please complete and submit a data subject access request.