Privacy Policy

Privacy Policy

Effective Date: February 27, 2020.

RAPCHAT PRIVACY POLICY

Rapchat respects your privacy and is committed to letting you know how we will collect and use your information. This Privacy Policy ("Policy") describes the privacy practices we follow in connection with the Rapchat websites and mobile applications that link to it (collectively the "Services"), as well as the related consumer services offered through the Services. It also describes the options you have regarding our collection, use, and disclosure of your personal information when accessing the Services.

By using our Services and/or registering as a Rapchat user you are accepting the privacy practices described in this Policy and consenting to our collection, use and disclosure of your personal information as described below. If you do not agree with this Policy, please do not use the Services. We reserve the right to modify the terms of this Privacy Policy at any time. We will post any changes to our website. Your continued use of our Services following the posting of changes will mean you accept those changes.

Information Collection And Use

Information You Provide Us Or From You Through Other Sources: We collect a variety of information from you when you provide it to us directly or when you tell us to get it from a third party source. The particular kinds of information we gather usually depend on how you interact with us. For example:

  • Registration Information: We collect basic account information such as your email address, phone number, username and password. We need this information to create your account and it helps secure and provide access to our Services. We also obtain or infer demographic information. If you use Facebook or Google to register for or log in to the Services (or later connect your accounts), you authorize Facebook or Google, as the case may be, to share your personal information with us, including your email address, age and publicly available information about you and your Facebook friends, if you use Facebook for signup. Similarly, if you access the Services with another third party social network we will collect information that you have agreed to make available, such as your name, user ID/URL, profile picture, age, list of friends, email address and/or phone number, and/or your birthday, language selected, and/or geolocation.
  • Profile Information And Use Information: In addition to your name and username, which are automatically displayed on your profile page, you may voluntarily provide Information on your profile page such as your profile picture (if not already available via your sign up using your social network information), date of birth, gender, location and other information about yourself and your interests. Any such information which you add to your profile page (except for date of birth and gender) on the Services becomes publicly available. We gather information from the actions you take to recommend, create, communicate and share content. This includes messages you send, information about the content you create yourself, the people you follow, the songs you mark as favorites or share, and the comments you post. In addition, we track social interactions in our Services (e.g. what you listened to, what you loved, and your comments and invites). Please exercise personal discretion in how much information you choose to share. Content which you upload to the Services, which allows others to identify you (e.g. photos of you, audio recordings or text containing your name, status updates, comments on content which refer to you). Communications between you and Rapchat (e.g. your reply to our service updates, emails to you, and support tickets). To be clear, we don’t ask you to provide us with any sensitive personal information, such as information relating to your race or ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, physical or mental health, genetic or biometric information, sexual life or sexual orientation. However, if you decide to share this kind of information on the Services, you explicitly consent to us displaying it or sharing it in accordance with your selection.

Information Other Users May Provide About You: Content which others upload to the Services which allows you to be identified (e.g. photos of you, audio recordings or text containing your name, status updates, content posts, comments on content which refer to you).

Information We Collect:

  • Analytics Information: We use third-party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information sent by your device including the web pages you visit, add-ons, and other information that assists us in improving the Services. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual user. Additionally, we collect information about your visit to and use of the Services, such as your IP address and the location of your IP server, device IDs, device type, wi-fi connection information, general and precise geo-location data, type of browser and operating system used, date and time you access the services, pages you visit, and, if you came to the Services from another website or app store, the address of that website or app store.
  • Information From Your Device and Browser: We collect information from your browser, computer, or mobile device, which provide us with technical information when you use the Services, including:
    • Contacts: If you choose to find your friends on Rapchat, we will access your contacts on your device (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list) and send your contacts to our servers to check if any of them are on the Services. If they are, we’ll suggest you follow them.
    • Log Data Information: When you use the Services, we automatically collect certain log data, including your IP address, browser type, hardware type, unique device ID, the version of your operating system and your activity within the Services. We use log data for security purposes (such as preventing content from being improperly accessed) and to improve our Services (such as enhancing site performance in certain regions).
    • Device Identifiers: We receive device identifiers like Apple’s IDFA, IDFV and Google’s AdID. These are used for online advertising and marketing purposes, to provide you with the most relevant ads.
    • Location Information: We access geo-location information from your mobile device. This helps us connect you with other users and relevant content, and display local activities and content based on your current location. It also helps us to send you relevant messages based on where you live. You can control the collection of geo-location information through your device.
    • Cookies and Other Similar Technologies: We use cookies, which deposit small data files stored on your computer or mobile device, and other similar technologies like software development kits ("SDKs") or third party libraries. We use cookies to distinguish you, identify your interests and your account and its status and settings, to collect usage data, keep track of your preferences and deliver content specific to your interests. For example, we use cookies to remember your likes of content, your followers and who you follow, search history, account type and the last time you checked or updated your feed. Our advertising partners may use cookies and similar technologies to identify and deliver content and advertising specific to your interests, to track the effectiveness of such advertising and to provide and analyse their services. You can configure your browser to reject cookies. By using our Services you consent to our, and our advertising partners’, use of cookies and related technologies, and the sharing of data with our advertising partners. You can withdraw your consent to our use of cookies using your browser settings or your device’s limit ad tracking settings. You may also be able to control the use of cookies via industry websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/ or through other functionality which we may have available from time to time.

How We Use Your Information

We use the information we have to help us provide, operate, improve, understand, customize, support, and market our Services. How exactly we use your Information will depend on the nature of your interaction with the Services and with us. We need to have valid grounds to process your information. Most times, we would seek your consent, like when you register for an account or subscribe to our mailing list. Other times, when you reasonably expect us to use your information, we will not ask for your consent, but only when it is legally permissible for us to do so (e.g. it is necessary for our performance of a contract, or for us to comply with a legal obligation etc.) We use your information in the follow ways:

  • In order to register for a Rapchat account, we need certain information. We may use your email address and/or phone number to send you information about the Services, provide customer support or to notify you of additional products and services, where permitted by applicable law. You may use your account settings to unsubscribe from notifications from us.
  • We collect information to learn about your use of the Service and to enhance your social experience when using the Services, such as friend-to-friend interaction and notifications, chat, or messaging functionality, public leaderboards, and other similar features. We try to show you content that we think will be of most interest to you.
  • To optimize your experience, we use information: To allow you, and those whom you have given permissions to, to access content and information which you have uploaded. To identify you with content which you have uploaded. To test, improve and monitor the Services, including diagnosing and fixing technology problems, and including use as part of our API.
  • We try to continuously improve our Services and your experience. As part of this, we use the data we have to identify ways to make our Services better and more engaging for our users. We use your interactions on the Services, along with the other data described in this policy, to infer your interests. We do this to identify and suggest content that you may like and to tailor advertising, including off-site advertising.
  • We use data to identify and respond to potential risks to our users and Services (e.g., spammers, phishing attempts, screen scraping, bullying and other violations of our Terms of Service).
  • If you provide us with your list of friends on a third party social network or a mobile device, your friends on such network can automatically follow you when you use the Services and your account can be automatically configured to follow your friends. You can, however, unfollow any other user at any time.
  • We promote our Services via customised advertising on third party sites. We may use your information to target advertising; including to design advertising campaigns designed to reach individuals with similar profiles to existing users.
  • We use your information for customer relationship management purposes, including for targeting email and other engagement campaigns such as push notifications.
  • We sometimes conduct or sponsor challenges and contests. Participation in challenges and contests is completely voluntary. If you decide to participate, we may ask you for additional contact, demographic, and other information and may ask you to agree to additional terms and conditions.

Information We Share

You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our Services. We may share your information with third parties as described below:

  • Affiliates: We may share your information with any related entities of Rapchat ("Affiliates") that use and disclose your information for their purposes in ways consistent with this Policy.
  • Third Party Service Providers: We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. When we share your information with third party service providers, we require them to use your information on our behalf in accordance with our instructions and terms.
  • Business Partners: We may engage in activities that include sharing your information with business partners who provide products and services that we think may be of interest to you. In such instances, we will restrict our business partners' use of any information that personally identifies you to our joint marketing and business activities.
  • Challenges and Contests: In the event that you participate in a challenge, contest, or other promotion that is sponsored by Rapchat and a third party, such participation serves as your consent for Rapchat to share your information collected in conjunction with the challenge, contest, or promotion, with that co-sponsoring third party. After the information is provided to such third parties, the subsequent use or disclosure of such information is subject to those third parties' privacy policies and practices.
  • Our Advertisers and Third Party Advertising Partners: We may share information about you or your use of the Services with our advertisers and third party advertising partners. This means that we may give our advertisers information about the characteristics of our users, along with sharing certain identifiers and/or location information, but we do not specifically identify you by name or share your contact information. Third parties can use this data to deliver targeted advertisements that they believe will be of most interest to you or to assess the effectiveness and reach of advertising campaigns.
  • Google Analytics: Google Analytics collects information such as how often users visit our website, what pages they visit when they do so, and what other sites they used prior to coming to the website. You may opt-out of Google Analytics tracking with the Google Analytics opt-out browser add-on.
  • Statistics: We may publicly disclose aggregated statistics (like what types of content or users are popular in a certain city).
  • Content: We may use any recording, video and/or other content you create and post in the Services in order to promote Rapchat, our Business Partners, or our Services.
  • Legal Disclosures: We may disclose information, including information that personally identifies you, to: (i) protect or defend the legal rights, interests or property of Rapchat and our Affiliates; (ii) protect the safety and security of our customers or members of the public; (iii) protect against fraud or for risk management purposes; or (iv) comply with applicable law or legal process.
  • Business Transaction: We may share some or all of your information in connection with, or during negotiation of, any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, information may also be transferred as a business asset.
  • Additional Partners: Notwithstanding any other provision, we partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business. Our partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share personal information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners may link the hashed or obfuscated personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Our partners use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, over time for advertising (including addressable TV), analytics, attribution, and reporting purposes. For example, our partners may deliver an ad to you in your web browser based on a purchase you made in a physical retail store, or they may send a personalized marketing email to you based on the fact that you visited a particular website. Your data may be transferred outside of the country from which it was originally collected. To learn more about interest-based advertising in general and to opt out, please visit http://www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

Our Legitimate Interest For Collecting, Sharing, Processing, And Using Your Information

We use and process your information in furtherance of the following legitimate interests:

  • Keeping The Services Safe And Secure: We use your information to try and keep our Services safe and secure. We do so as it is necessary to pursue our legitimate interests, the interests of our community and yours, in ensuring Rapchat is secure, and to protect against fraud, spam, misuse and abuse. For example, we process your information to protect you and Rapchat from malicious scraping of our website by those seeking to download music and recordings. We also want to protect against hackers who try to access content.
  • Providing Our Services: We use your information to provide the Services, including any personalized services. We do so as it is necessary to pursue our legitimate interests in providing an innovative and tailored offering to our users on a sustained basis and to provide stable connectivity. For example, where there is poor connectivity in an area or neighbourhood, users can experience difficulty in downloading/uploading content. In that case, we need to process log data, including your IP address, to troubleshoot the issue. Without your IP address and location info, it can be hard to fix connectivity issues.
  • Improving Your Experience On Our Services: We work hard to develop, enhance and improve our Services, such as by providing better content feeds. We also may share data with researchers to contribute to academic research. Where we contribute to academic research, we take into account your rights and ensure that protections are in place with respect to your information.

Storing and Managing Your Information

We offer the ability to correct or update the information collected during registration via your account settings on our website or the mobile application or by contacting support via email support form and we rely on the accuracy of the information you provide us (such as your age). You may request deletion of your account by contacting support via email at suport@rapchat.me or our privacy team at privacyinquiry@rapchat.me.

We retain your information in our server logs, our databases and our records only for as long as necessary in light of the purposes set out in this Policy, subject to any legal obligations to further retain such information. We may use third party service providers to store and maintain such data. We retain your verification-related information for a reasonable period of time, even if you do not complete all verification steps, to assist with future verifications and to prevent abuse of our verification processes.

If you create content with other users such collaboration songs, this content will remain after you delete your account.

Your Rights and Choices

You may contact us in writing via email to privacyinquiry@rapchat.me if you wish to do any of the following:

  • update or correct your Information;
  • request for information from us on what Information of yours we have and how we have used and shared your Information during the last one year before the date of your request;
  • restrict or withdraw your consent to our processing of your Information;
  • delete your Information; or
  • have any questions, concerns or feedback on this Privacy Policy.

If you are a resident of the European Union using the Services, you have the following rights under the General Data Protection Regulations:

  • Access And Porting: You can access much of your information by logging into your account. Where legally required, we can provide your information upon your request. However, in accordance with applicable law, information will not be provided where doing so would adversely affect the rights (including the intellectual property rights) of others.
  • Change, Limite, Restrict, Or Delete: You can also change, limit, restrict, or delete much of your information by logging into your account. If you cannot do this, or you do not have a Rapchat account, contact privacy support via email at privacyinquiry@rapchat.me. We may retain certain information as required by applicable law.
  • Object: If we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. If you are a resident of the European Union, you also have a general right to object to the use of your information for direct marketing purposes.
  • Revoke Consent: Where you have previously provided your consent, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent to email marketing by following the link provided in a marketing email. You can also revoke any consent you have provided to our use of your geo-location information by changing the setting on your mobile device. If you withdraw your consent to the use of your information for purposes set out in this Policy, you may not have access to all (or any) of our Services and we might not be able to provide you all (or any) of the Services. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
  • Complain: If you are a resident of the European Union, should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority.

Children

Our Services are intended for general audiences, and are not intended for anyone under 13, or anyone under the minimum age to use the Services in the jurisdiction where they reside ("Minimum Age"). Users under the Minimum age are prohibited from using our Services and we do not knowingly collect information from such individuals. If we become aware that a child under the Minimum Age has provided us with their information, we take steps to remove such information and terminate the child's account, unless proper parental consent is delivered to Rapchat.

Consent To Processing And Transfer Of Information

When you use our Services your personal information is transferred to the United States, where the laws protecting privacy may be less stringent than those in your home country. We’re a US company, based in Columbus, Ohio, so this transfer is necessary for the performance of our Terms of Service.

Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located outside of the United States, please be aware that information we collect may be transferred to and processed by servers located in the United States. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States.

In certain cases, your data may be transferred to other countries or made available to users in other countries as part of the Services.

Data Security

We employ certain administrative, technical, and physical security measures to help reduce the risks of loss, theft and unauthorized access associated with the information that is in our possession. We cannot, however, guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Changes To Privacy Policy

We may, at our sole and absolute discretion, change or update portions of this Privacy Policy at any time and without prior notice to you. We may attempt to notify you when changes are made via the email address associated with your account. We also recommend that you review this Privacy Policy from time to time so you are aware of any changes or updates. We will indicate the effective date of the notice. Your continued use of the Services after any modification to this Privacy Policy constitutes your acceptance of such modification and your consent to our processing of Information in accordance with the modified Privacy Policy. If you do not wish to continue using the Services under the modified Privacy Policy, you should terminate your account.

Contact Us

If you have any questions or comments or if you would like to exercise any statutory rights, please contact us via email at privacyinquiry@rapchat.me.

RAPCHAT PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: December 12, 2019.

Last reviewed on: February 27, 2020.

The California Consumer Privacy Act ("CCPA") provides new rights to California residents ("consumers"). This section ("CCPA Notice") explains how Rapchat collects and uses the personal information of California consumers and how those consumers can exercise their rights under CCPA. This CCPA Notice will be updated every 12 months, or as needed to address changes in the law or our practices.

This CCPA Notice supplements our other privacy notices and policies and shall govern in the event of a conflict.

Note for non-members or prospective members. Please note that this CCPA Notice does not apply to human resources data or business-to-business communications data. If you would like information about human resources data or business-to-business communications data, please reach out to your contact at Rapchat.

Collected Personal Information.

  • Categories Of Personal Information: Rapchat may collect personal information about members and other users of our services who are California consumers including personal information within the following categories: identifiers (e.g. your name and other contact information, IP address and device ID); characteristics of protected classifications under California or federal law; commercial information (e.g. your order information, payment information and feedback information); internet or other electronic network activity information (e.g. your browsing history); geolocation data; audio, electronic, visual, or similar information (e.g. pictures and videos that you send to us, or recordings of your calls to our customer service centers); professional or employment-related information; inferences information (e.g. your interests, demographics and shopping preferences); and individual records (e.g. any other information that may identify or relates to you).
  • Non-Personal Information. Rapchat may also collect, generate or share deidentified or aggregate information. This is not personal information under CCPA and we reserve the right to convert, or permit others to convert, personal information into deidentified data or aggregate consumer information.

Sources Of Personal Information: Rapchat collects personal information from different sources.

  • Personal Information We Collect From You: Rapchat collects some personal information that you provide directly to us. This can include contact information,, communication information, feedback information, preferences information, pictures and videos that you send to us, content you upload and other information you provide to us. In addition, you may provide us with the personal information of other people if you invite others to become Rapchat users.
  • Personal Information We Collect From Cookies And Other Similar Technologies: Rapchat or its vendors collect some personal information automatically from cookies, pixels and similar technologies when you use our services. This can include your browsing activities when you are on our Services; information about devices that you use to access Rapchat’s services; and other information collected through cookies, pixels, and similar technologies.
  • Personal Information We Create: Rapchat creates some personal information when you use our services. This can include analytics and inferences about your interests, demographics and content preferences.
  • Personal Information We Collect From Third Parties: Rapchat collects personal information from other companies. This can include updated address and shipping instructions information; credit information; information from advertisers; information from Facebook, Twitter and other similar platforms; personal information from third parties that supplements the personal information we already have.

Uses Of Personal Information: Rapchat uses personal information for the following business or commercial purposes:

  • Account provision and maintenance, including creating and managing your account with Rapchat; providing customer service; verifying member information; and providing other services in the course of Rapchat’s business operations
  • Customer service and communications, including responding to requests, comments, or questions through emails, Facebook messenger messages, text messages, push notifications, telephone calls, postal mail, chat functions; providing interest-based advertising and other advertising, marketing and promotional content and messaging, managing and communicating through Rapchat presences on social media platforms and other platforms; maintaining product review capabilities; reviewing recorded calls or content of other communications for quality or customer service purposes; responding to requests for information and taking action that may be requested under CCPA.
  • Improving services and user experience, including creating and updating applications, websites, and other features or functionality used by Rapchat; debugging to identify and repair errors that may affect how the services function; engaging in analytics related to improving services or user experience
  • Personalizing user experience and marketing, including targeted product display; targeted marketing and advertising through the services; marketing through emails, Facebook messenger messages, text messages, push notifications and other communications methods; re-targeted marketing and advertising across other websites, devices, and platforms; auditing related to the performance of Rapchat’s advertising and marketing efforts; engaging in analytics to personalize user experience.
  • Fraud prevention and information security, including when the account is otherwise accessed; detecting and responding to fraud or security incidents; protecting against other malicious, deceptive, or illegal activity.
  • Legal obligations, including prosecuting people responsible for fraudulent, malicious, deceptive or illegal activities; defending claims; notifying of product recalls or other issues related to products; enforcing and notifying of Rapchat’s terms of service, privacy policy and other policies and changes to such terms of service, privacy policy and other policies.
  • Payment-related activities, including processing payments, evaluating payment options, managing Smart-pay and similar payment programs, and managing private label credit card programs.
  • Conducting research, analytics, surveys, and focus groups to improve member experiences, develop services and products, provide better marketing and advertising.
  • Product safety or quality activities.
  • Any other legal purpose consistent with our applicable notice of privacy practices.

Disclosures Of Personal Information:

  • Sales of Personal Information: The concept of a "sale" under CCPA is different from what has traditionally been considered a "sale", e.g., selling a customer list for money. Under CCPA, a "sale" potentially includes other uses or disclosures of personal information to third parties outside Rapchat in a commercial context (unless an exception to "sale" as provided by CCPA exists). Because the concept of "sale" is so broad under CCPA, Rapchat may be deemed to "sell" the following personal information even though we may not disclose your personal information in exchange for money: identifiers; characteristics of protected classifications under California or federal law; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; professional or employment-related information; inferences information; and individual records.
  • Disclosures For Business Purposes. Please note that Rapchat may share your personal information with vendors that help us fulfill your transactions and provide other services to us. Examples of these vendors include payment processors, fraud prevention services, and shippers. We do not treat these disclosures as sales. Rapchat may disclose the following personal information to our vendors: identifiers; characteristics of protected classifications under California or federal law; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; professional or employment-related information; inferences information; and individual records.

CCPA Rights:

  • Right To Delete Personal Information: If you are a California consumer, you have the right to request that Rapchat delete any personal information about you that Rapchat has collected from you. Note that Rapchat may retain some personal information, as permitted under CCPA.
    • How to exercise right of deletion: If you are a California consumer, you may exercise your right to request deletion of your personal information by clicking here or by emailing ccpa-deletion-request@rapchat.me. In order to verify your identity, you must enter the email address and password associated with your Rapchat account. There is no reasonable method by which Rapchat can verify the identity of a consumer who does not have a Rapchat account.
  • Right To Opt-Out Of Sales: Rapchat may sell certain personal information that Rapchat has collected about you as described in the "Sales of personal information" section above. If you are a California consumer, you have the right to opt-out of some sales of your personal information.
  • Right To Receive A Copy Of Your Personal Information And Other Information: If you are a California consumer, you have the right to request that Rapchat disclose to you the following information:
    • The categories of personal information Rapchat has collected about you.
    • The categories of sources from which the personal information about you is collected.
    • The business or commercial purpose for collecting or selling personal information about you.
    • The categories of third parties with whom Rapchat shares personal information about you.
    • The categories of personal information Rapchat sold about you and the categories of third parties to whom the personal information about you was sold.
    • The categories of personal information Rapchat disclosed about you for a business purpose.
    • The specific pieces of personal information Rapchat has collected about you.
  • How to exercise right to receive a copy of personal information and other information: If you are a California consumer, you may exercise your right to request a copy of the information described under this "Right to receive a copy of personal information and other information" section by clicking here or by emailing ccpa-access-request@rapchat.me. In order to verify your identity, you must enter the email address and password associated with your Rapchat account. There is no reasonable method by which Rapchat can verify the identity of a consumer who does not have a Rapchat account.
  • Right To Non-Discrimination: If you are a California consumer, you have the right that a business shall not discriminate against you because you exercised rights under CCPA. However, we reserve the right to provide loyalty programs and other differential pricing and services as permitted by CCPA, which will be subject to applicable terms and conditions of such programs.

Limitation Of Rights; Compliance With Applicable Law:

Notwithstanding anything to the contrary in this CCPA Notice, we may collect, use and disclose personal information as required or permitted by applicable law and this may override CCPA rights. In addition, we need not honor any requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.