Endor wants you to understand how we use, collect, share and protect your personal data. At Endor Global AS (collectively, “Endor”, “we”, “us”, and “our”), we respect and value your privacy and integrity. We therefore ask you to familiarize yourself with this Privacy Policy and its content.

It describes our policies and procedures on the collection, use and disclosure of your Personal Data when you use our Services and otherwise interact with Endor, and tells you about your privacy rights and how the law protects you.

By using the Services, you agree to the collection and use of Personal Data in accordance with this Privacy Policy.

Our Privacy Policy is reviewed on a regular basis and may be updated from time to time.  You will always find the latest version of our Privacy Policy on our webpage https://endor.global.

If we have provided you with another Privacy Policy or notice, then this Policy is intended to supplement, and not override them.

Collecting and Using Your Personal Data

The Types of Data We Collect

Personal Data

While using our Service, we ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Endor processes the following categories of Personal Data when you use our Services:

Contact data: email address, first name and last name, phone number, delivery address and billing address. If you interact with Endor through a social media platform we may also collect Personal Data that is already associated with your Third-Party Social Media Service's account, like your social media username. You provide us with this information when you create an Account, place and order or sign up for a subscription or our newsletter. 

Account data: Login details, services purchased and/or subscribed to and customer preferences. 

User provider information: Information you choose to provide us with in your Account, including height, weight, lifestyle information like energy and exercise, nutrition, habits, medications, female health tracking, logging, comments, responding to a questionnaire, queriers and feedback.

Demographic information: Gender/pronoun, age, ethnicity, and GPS (accurate location).

Measured data: Including but not limited to physiological metrics such as heart rate variability, temperature, respiration, movement, sleep and type of physical activity.

Calculated data: Based on the measurements we do, for example, sleep phases, activity and energy levels throughout the day and recovery. 

Usage Data: Usage Data is collected automatically when using the Services. Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile Device, we may collect certain information automatically, including, but not limited to, the type of mobile Device you use, Your mobile Device unique ID, the IP address of your mobile Device, your mobile operating system, the type of mobile Internet browser you use, unique Device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile Device.

Sharing with other Endor users

Please note that if you give your consent through our Services to make your information available to the Endor community, then you may share certain personal information like sleep and recovery score with other Endor users. When you are choosing to make Personal Data visible to other Endor users, it may be collected by anyone.

Data of children

Endor does not knowingly allow children under the age of 18 to purchase our Services or to send us Personal Data, as set out in the Terms and Conditions. 

If we learn that we have collected Personal Data from someone under 18, we will delete the information as soon as possible.

Anonymized data

We may create aggregated and anonymized data from the Personal Data we have collected. Data that cannot be linked with an identifiable individual is no longer considered Personal Data. We will not try to re-identify the information.

We may use anonymized data for business purposes, such as analyzing, developing and enhancing our current and future products and services, as well as to promote our business – so long as the data remains anonymous. The data is not subject to a specific retention schedule, and you should assume that we will retain it.

Retention of Your Personal Data

Endor will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, based on the amount, sensitivity and nature of the information, the potential risk to harm from unauthorized use of the data and the purposes for which we process the data and to what extent we can achieve that purpose without through other means. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Endor’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We may share your Personal Data in the following situations:

• With Service Providers: We may share your Personal Data with Service Providers to monitor and analyze the use of our Service, to hosting- and other technology- and communication providers, to advertise on third party websites to you after you visited our Service, for payment processing, for security consultants, or other personnel that provides services to us. 

• With Affiliates: We may share your information with our Affiliates, in which case we will require those Affiliates to honor this Privacy Policy. 

• With business partners: We may share your information with our business partners to offer you certain products, services or promotions.

• With your consent: We may disclose your Personal Data for any other purpose with your consent.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Endor will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, based on the adequacy of the protections in those countries, such as an adequacy decision, SCCs or binding corporate rules in place, as well as contractual obligations to comply with GDPR

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Application may give you the ability to delete certain information about you from within the Application.

You may update, amend, or delete your information at any time by  contacting Us to request access to, correct, or delete any personal information that you have provided to us. You can also delete Your Personal Data at any time by deleting the Application and unpairing your device.

Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of your Personal Data

Business Transactions

If Endor is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, Endor may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

Endor may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of Endor

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Security of your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Processing of biometric data requires strong protections, and We take our responsibility very seriously. All biometric data is encrypted in transit, and governed by strict access controls. Endor continuously assesses the adequacy of the protections in place for the processing of biometric and health data and performs penetration testing on a regular basis.

Endor commits to inform users within 72 hours of a security breach in accordance with GDPR.

Detailed Information on the Processing of Your Personal Data

The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use Email Marketing Service Providers to manage and send emails to you.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Pushwoosh

Pushwoosh is a push notification service used for welcome pop-ups in the Endor app, provided by Pushwoosh Inc.

For more information on the privacy practices of Pushwoosh, please visit their Privacy policy: https://www.pushwoosh.com/privacy-policy/

Payments

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Apple Store In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

RevenueCat

Their Privacy Policy can be viewed at https://www.revenuecat.com/privacy/

Hosting services and error tracking

Endor uses third-party service providers to store data and to track errors in the Application. These third-party vendors include:

Fly.io

Their Privacy Policy can be viewed at https://fly.io/legal/privacy-policy/

Sentry.io

Their Privacy Policy can be viewed at https://sentry.io/privacy/

Behavioral Remarketing

The Company uses remarketing services to advertise to you after you accessed or visited our Service. We and our third-party vendors use cookies and non-cookie technologies to help us recognize your Device and understand how you use our Service so that we can improve our Service to reflect your interests and serve you advertisements that are likely to be of more interest to you.

These third-party vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies and to enable us to:

• Measure and analyze traffic and browsing activity on our Service

• Show advertisements for our products and/or services to you on third-party websites or apps

• Measure and analyze the performance of our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver you ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors we use are:

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

GDPR Privacy

Processing purposes under GDPR 

Endor will only process your Personal Data for the purposes informed in this Privacy Policy and to the extent we have lawful basis to do so. Endor may use your Personal Data for the following purposes:

• To provide Endor Services: We process Personal Data to provide you with our Services, to process orders, memberships and other transactions, including to satisfy the reason you provided the information to us. The development, fulfillment and execution of the purchase of products, items or services that you have bought from us, or any other contract you have entered into with us through the Service.

• To create and manage your Account:  Your registration as a user of the Service and other user profiles. 

• To contact you and provide you with news: To contact you via email, phone, SMS, or similar electronic means—such as app push notifications—regarding updates, product or service information, and necessary security notices as well as providing support and assistance for the Services.

• To deliver targeted advertising: We may use your information – along with trusted third-party partners – to develop and deliver content and advertising tailored to your interests and location and to measure its effectiveness.

• To improve our Services: to provide, operate, evaluate, develop, understand, improve and personalize the Services, our business and our product, including data analysis, identifying usage trends and determining the effectiveness of our promotional campaigns.

• For analyses and research: We process personal data related to performance and well-being to enhance our Services and deliver personalized insights. Some features use third party automated technologies to tailor your experience based on your responses. Where possible, we ensure data is processed in ways that protect your privacy.

• To comply with legal obligations: In some cases, we must process certain data to comply with laws and regulations, such as accounting, taxes or legal claims. Endor will reject any request for user data that’s meant for surveillance or prosecution and will notify users of any such request where the law allows.

• For protection of your privacy: To protect your privacy, as well as protect against harmful or fraudulent actions and to maintain the security of the Services.

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: To the extent we collect Personal Data that is considered health data or other special category of data under GDPR, such as biometric data collected by the Device, we ask for your explicit consent to process the data in the Application . We may also request your consent to collect your Personal Data for marketing purposes. When we process data based on your consent, you can withdraw the consent at any time. You can do this by deleting your user Account and unpairing the Endor device. 

• Performance of a contract: We process Personal Data to create, maintain and manage Endor accounts and to provide our Services, in accordance with the agreement we have with you and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Endor is subject.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Endor, such as to contact you and provide you with information, to analyze the use of our Services, for research and development, for the protection of your privacy and to maintain the security of the Services, and to the extent consent is not required by law, for marketing our business. 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

• Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your Account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.

• Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.

• Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

• Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.

• Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

Endor is the Data Controller of your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/profile.php?id=61570727520686, Endor and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Meta Platforms, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of personal information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or Device. In addition to the list of personal information set out in the chapter “The Types of Data We Collect”, please note the following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Category A: Identifiers.

Examples: A real name, alias, postal address, Internet Protocol address, email address, account name or other similar identifiers.

Collected: Yes.

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

Examples: A name, physical characteristics or description, address, telephone number, credit card number, debit card number. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).

Collected: Yes. 

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information or other physical patterns, and sleep, health, or exercise data.

Collected: Yes.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

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

Collected: Yes.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: Yes.

Category 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)).

Examples: 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.

Collected: No.

Category K: Inferences drawn from other personal information.

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

Collected: Yes.

Category L: Sensitive personal information.

Examples: Account login and password information, geolocation data.

Collected: Yes.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA/CPRA's scope, such as: 

• 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

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.

• Indirectly from You. For example, from observing Your activity on our Service.

• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

• To operate our Service and provide You with Our Service.

• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.

• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.

• 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/CPRA.

• For internal administrative and auditing purposes.

• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

• Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers

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

• Category D: Commercial information

• Category F: Internet or other similar network activity

• Category G: Geolocation data

• Category L: Sensitive personal information

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial 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.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers

• Payment processors

• Our Affiliates

• Our business partners

• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers

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

• Category D: Commercial information

• Category F: Internet or other similar network activity

• Category G: Geolocation data

• Category L: Sensitive personal information

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

• The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, 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 purposes 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

• If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You: 

• The categories of personal information categories sold

• The categories of personal information categories disclosed

• The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Us.

• The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.

• The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.

• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, 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 Providers 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.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by: 

• Denying goods or services to You

• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

• Providing a different level or quality of goods or services to You

• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

By email: post@endor.global

By visiting this page on our website: https://endor.global/

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us 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 the required information if We cannot:

• Verify Your identity or authority to make the request

• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Service to review Your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.

Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your Account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, and we will respond as soon as possible, and at the latest within one month, with possible extensions, as per GDPR. You can contact the data protection officer:

By email: post@endor.global

By visiting this page on our website: https://endor.global/

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application refers to Endor Global, the software program provided by the Company.

Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Endor Global AS, Tjuvholmen allé 1, 0252 Oslo, Norway.

For the purpose of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Facebook Fan Page is a public profile named Endor Global specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/profile.php?id=61570727520686

GDPR refers to EU General Data Protection Regulation.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

• Service refers to the Endor Application, the Endor strap or any other Endor wearable, subscribe to the Endor newsletter, participate in an Endor study, or to any Endor feature, content or a visit to Endor’s webpage.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).

You means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.

Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.