# Privacy Policy

Your privacy is very important to us. This Site is hosted by DOORTOKEN.org or one of its affiliates (collectively, "Company").This Privacy Policy has been prepared to explain how we collect, use, protect, and share information and data when you use this Web site (the "Site"), including information and data that we share with service providers who are Authorized Users of doortoken.org.&#x20;

By visiting or using all or any part of this Site, you consent to this Privacy Policy.&#x20;

**Visitors**

This Site links to this Privacy Policy because the Company collects, uses, and retains all information, including Personal Information and Usage Data, that users share with or otherwise make available via the Site. For example, when you provide your contact information, this information is collected and stored by the Company under the terms of service agreement. &#x20;

**Information We Collect**&#x20;

Personal Information. Company collects information that personally 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 ("Personal Information").In particular, the Site has collected the following categories of Personal Information from its consumers within the past twelve (12) months:

| Category                                                                                                                              | Examples                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Collected |
| ------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------- |
| A. Identifiers.                                                                                                                       | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.                                                                                                                                                                                                                                                               | YES       |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code Â§ 1798.80(e)).                  | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. (Some personal information included in this category may overlap with other categories.) | YES       |
| C. Protected classification characteristics under California or federal law.                                                          | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).                                                                                                     | NO        |
| D. Commercial information.                                                                                                            | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.                                                                                                                                                                                                                                                                                                                                                         | YES       |
| E. Biometric information.                                                                                                             | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.                                                                                                                                                                          | NO        |
| F. Internet or other similar network activity.                                                                                        | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.                                                                                                                                                                                                                                                                                                                                                                                 | YES       |
| G. Geolocation data.                                                                                                                  | Physical location or movements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | YES       |
| H. Sensory data.                                                                                                                      | Audio, electronic, visual, thermal, olfactory, or similar information.                                                                                                                                                                                                                                                                                                                                                                                                                                   | NO        |
| I. Professional or employment-related information.                                                                                    | Current or past job history or performance evaluations.                                                                                                                                                                                                                                                                                                                                                                                                                                                  | NO        |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.                                                                                                                                                                                                                       | NO        |
| K. Inferences drawn from other personal information.                                                                                  | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.                                                                                                                                                                                                                                                                                                                                          | YES       |

**For purposes of this Privacy Policy, "Personal Information" does not include:**

* Publicly available information from government records.
* Deidentified or aggregated consumer information.
* Information excluded from "Personal Information," like:
  * health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  * personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Company collects Personal Information only if you choose to share it (for example, by inserting your information into forms you complete when registering or updating in the app). The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to use certain features of the Sites.

Anonymous Usage Data. The site automatically collects anonymous usage information that does not identify an individual user ("Usage Data"). For example, each time you use the Site, it automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits. Company uses this information to help understand how people use the Sites, and to enhance the services Company offers.

Cookies and Web Beacons. The site may use cookies (a small text file placed on your computer to identify your computer and browser) and Web beacons (an electronic file placed on a Web site that monitors usage). These technologies may be used in connection with the Sites. Company uses cookies and Web beacons to improve the quality of the Sites. Company does not use cookies or Web beacons to collect Personal Information. Most Web browsers are initially set up to accept cookies. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies, though either of those actions may affect your use of the Site.

**How We Use Information and When We May Share and Disclose Information**

Generally. Company uses Personal Information only at the direction and for the benefit of the User for internal purposes, such as to provide you with the Sites, to enable Company or the User to notify you of new products or services, and to otherwise communicate with you about your use of the Site or the User. Company will disclose your Personal Information to the User in accordance with this Privacy Policy. Company will not disclose Personal Information to third parties without your consent, including for their direct marketing purposes, except as explained in this Privacy Policy.

Service Providers. From time to time, Company or the User may establish a business relationship with other businesses whom Company or the User believes is trustworthy and who we have asked to confirm that their privacy practices are consistent with ours ("Service Providers"). For example, Company may contract with Service Providers to provide certain services. Company only provide our Service Providers with the information necessary or helpful for them to perform these services on Company's behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than for the purpose for which such information was provided or as authorized by you.

Advertising. We may work with third-party advertisers, search providers and ad networks ("Advertisers"). These companies may collect and use information about your use of the Sites in order to provide advertisements about goods and services that may be of interest to you. These companies may place or recognize a unique cookie on your computer or use other technologies such as Web beacons. This Privacy Policy does not cover any use of information that an Ad Network may collect from you.

Standard Analytics Information. Company may use, and disclose to third parties, certain Usage Data regarding the Sites. However, in such cases, your Usage Data is aggregated with the Usage Data of others and does not identify you individually.

Other Transfers. Company may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with it. If Company is merged, acquired, or sold, or in the event of a transfer of some or all of Company's assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

Compliance with Laws and Law Enforcement. Company cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Company may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in its discretion, it believes it is necessary or appropriate for any of the following reasons: (a) to respond to legal requests (including court orders and subpoenas); (b) to protect the safety, property, or rights of Company, or any third party; (c) to prevent or stop any illegal, unethical, or legally actionable activity; or (d) to comply with the law.

**Be Careful When You Share Information with Others**

Please be aware that whenever you send messages, make postings, or otherwise post or transmit any information or content on this Site or any other of the Sites or any public forum available on or through the Sites, that information or content may be accessed by others. In addition, when you share information or any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

**Security**

Company is very concerned about safeguarding the confidentiality of your Personal Information. Company employs reasonable physical and electronic measures designed to protect your information from unauthorized access. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while Company strives to protect information transmitted on or through the Sites, Company cannot and does not guarantee the security of any information you upload, store, share, transmit, or provide on or through any Site and you do so at your own risk.

**Links to Other Web sites**

The Sites may contain links to other Web sites, or allow others to send you such links. A link to a third party's Web site does not mean that Company or the User endorses it or that we are affiliated with it. Company dos not exercise control over third-party Web sites. You access such third-party Web sites or content at your own risk. You should always read the privacy policy of a third-party Web site before providing any information to the Web site.

**Children's Privacy**

Company does not knowingly collect Personal Information from children under the age of 13. If Company becomes aware that a user is under the age of 13, Company will terminate any account that user may have with it. If Company becomes aware that it has inadvertently received Personal Information from a child under the age of 13, Company will delete such information from its records.

**Processing in the United States**

Please be aware that your Personal Information may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Sites, you agree that the collection, use, transfer, and disclosure of your Personal Information will be governed by the applicable laws in the United States.

**Privacy Policy Changes**

From time to time, this Privacy Policy may be changed. If this Privacy Policy is changed, you will be informed by posting of the revised Privacy Policy on the Site. Those changes will go into effect on the Revision Date shown in the revised Privacy Policy. Your continued use of the Sites constitutes your consent to the revised Privacy Policy.

**FOR CALIFORNIA CONSUMERS ONLY:**

The California Consumer Privacy Act of 2018 ("CCPA"), as amended from time to time, applies solely to visitors, users, and others who reside in the State of California.The CCPA provides California residents with specific rights regarding their personal information.If you are a California resident, this section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights.You have the right to request that Company disclose certain information to you about its collection and use of your Personal Information over the past 12 months.Once Company receives and confirms your verifiable consumer request, it will disclose to you:

* The categories of Personal Information it collected about you.
* The categories of sources for the Personal Information it collected about you.
* Its business or commercial purpose for collecting or selling that Personal Information.
* The categories of third parties with whom it shares that Personal Information.
* The specific pieces of Personal Information it collected about you (also called a data portability request).
* If Company sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
* Sales, identifying the Personal Information categories that each category of recipient purchased; and
* Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights. You have the right to request that Company delete any of your Personal Information that it has collected from you and retained, subject to certain exemptions.Once Company receives and confirms your verifiable consumer request, Company will delete (and direct its service provider(s) to delete) your Personal Information from our records, unless an exemption applies.&#x20;

Company may deny your deletion request if retaining the information is necessary for Company or its service provider(s) to:

* Complete the transaction for which the Personal Information was collected, provide a good or service that you requested, take actions reasonably anticipated within the context of its 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 Â§ 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 Company.
* 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.

Exercising Access, Data Portability, and Deletion Rights.To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Company by emailing [r@doortoken.org](mailto:info@doortoken.org) directly.\
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Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.\
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You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows Company to reasonably verify you are the person about whom Company collected personal information or an authorized representative.

Describe your request with sufficient detail that allows the Company to properly understand, evaluate, and respond to it.

Company cannot respond to your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with Company.Company will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format.Company endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If more time is required (up to 90 days), you will be informed of the reason and extension period in writing by mail or electronically, at your option.

Any disclosures Company provides will only cover the 12-month period preceding the verifiable consumer request's receipt. The response Company provide will also explain the reasons it cannot comply with a request, if applicable. For data portability requests, Company will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Company does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Company determines that the request warrants a fee, it will tell you why that decision was made and provide you with a cost estimate before completing your request.

Other California Privacy Rights.California's "Shine the Light" law (Civil Code Â§ 1798.83) permits users of the Site that are California residents to request certain information regarding Company's disclosure of personal information to third parties for their direct marketing purposes.To make such a request, please send an email to info@doortoken.org.\
