PRIVACY POLICY

Effective date: March 31, 2021

Prawn Holding, LLC (“Prawn”, ”us”, “we”, or “our”) operates the http://prawncoastal.com website (the “Service”).

This page informs you of our policies regarding the collection, use, and
disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from http://prawncoastal.com

Definitions
———–

* Service

Service is the http://prawncoastal.com website operated by Prawn

* Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

* Usage Data

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

* Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

* Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

* Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

* Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use
——————————

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected
~~~~~~~~~~~~~~~~~~~~~~~

Personal Data
*************

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not
limited to:

* Email address
* First name and last name
* Phone number
* Address, State, Province, ZIP/Postal code, City
* Cookies and Usage Data

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.

Usage Data
**********

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’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.

Location Data
*************

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any
time, through your device settings.

Tracking & Cookies Data
************

We use cookies and similar tracking technologies to track the activity on our
Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored
on your device. Tracking technologies also used are beacons, tags, and scripts
to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be
able to use some portions of our Service.

Examples of Cookies we use:

* Session Cookies. We use Session Cookies to operate our Service.
* Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
* Security Cookies. We use Security Cookies for security purposes.
* Advertising Cookies. Advertising Cookies are used to serve you with
advertisements that may be relevant to you and your interests.

Use of Data
———–

Prawn uses the collected data for various purposes:

* To provide and maintain our Service
* To notify you about changes to our Service
* To allow you to participate in interactive features of our Service when
you choose to do so
* To provide customer support
* To gather analysis or valuable information so that we can improve our
Service
* To monitor the usage of our Service
* To detect, prevent and address technical issues
* To provide you with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless you have opted
not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection
Regulation (GDPR)
—————————————————————————————-

If you are from the European Economic Area (EEA), Prawn legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Prawn may process your Personal Data because:

* We need to perform a contract with you
* You have given us permission to do so
* The processing is in our legitimate interests and it’s not overridden by
your rights
* For payment processing purposes
* To comply with the law

Retention of Data
—————–

Prawn will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. 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.

Prawn 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 Data
—————-

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to
us, please note that we transfer the data, including Personal Data, to United
States and process it there.

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

Prawn 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 including the security of
your data and other personal information.

Disclosure of Data
——————

Business Transaction
~~~~~~~~~~~~~~~~~~~~

If Prawn 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.

Disclosure for Law Enforcement
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Under certain circumstances, Prawn 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).

Legal Requirements
~~~~~~~~~~~~~~~~~~

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

* To comply with a legal obligation
* To protect and defend the rights or property of Prawn,
Inc.
* To prevent or investigate possible wrongdoing in connection with the
Service
* To protect the personal safety of users of the Service or the public
* To protect against legal liability

Security of Data
—————-

The security of your 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.

“Do Not Track” Signals
———————-

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can
set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings
page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)
—————————————————————————

If you are a resident of the European Economic Area (EEA), you have certain
data protection rights. Prawn aims to take reasonable
steps to allow you to correct, amend, delete, or limit the use of your
Personal Data.

If you wish to be informed what Personal Data we hold about you and if you
want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

* The right to access, update or to 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.

* The right of rectification. You have the right to have your information
rectified if that information is inaccurate or incomplete.

* The right to object. You have the right to object to our processing of
your Personal Data.

* The right of restriction. You have the right to request that we restrict
the processing of your personal information.

* The right to data portability. You have the right to be provided with a
copy of the information we have on you in a structured, machine-readable
and commonly used format.

* The right to withdraw consent. You also have the right to withdraw your
consent at any time where Prawn relied on your
consent to process your personal information.

Please note that we may ask you to verify your identity before responding to
such requests.

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

Service Providers
—————–

We may employ third party companies and individuals to facilitate our Service
(“Service Providers”), to provide the Service on our behalf, to perform
Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for any other
purpose.

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 can opt-out of having made your activity on the Service available to
Google Analytics by installing the Google Analytics opt-out browser add-
on. The add-on prevents the Google Analytics JavaScript (ga.js,
analytics.js, and dc.js) from sharing information with Google Analytics
about visits activity.

For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
<http://policies.google.com/privacy?hl=en>

Advertising
~~~~~~~~~~~

We may use third-party Service Providers to show advertisements to you to help
support and maintain our Service.

* Google AdSense & DoubleClick Cookie

Google, as a third party vendor, uses cookies to serve ads on our Service.
Google’s use of the DoubleClick cookie enables it and its partners to
serve ads to our users based on their visit to our Service or other
websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based
advertising by visiting the Google Ads Settings web page:
<http://www.google.com/ads/preferences/>

Behavioral Remarketing
~~~~~~~~~~~~~~~~~~~~~~

Prawn uses remarketing services to advertise on third
party websites to you after you visited our Service. We and our third-party
vendors use cookies to inform, optimize and serve ads based on your past
visits to our Service.

* Google AdWords

Google 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 – <http://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:
<http://policies.google.com/privacy?hl=en>

* Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by
visiting this page: <http://www.facebook.com/help/164968693837950>

To opt-out from Facebook’s interest-based ads follow these instructions
from Facebook: <http://www.facebook.com/help/568137493302217>

Facebook adheres to the Self-Regulatory Principles for Online Behavioral
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: <http://www.facebook.com/privacy/explanation>

Payments
~~~~~~~~

We may provide paid products and/or services within the Service. In that case,
we use third-party services for payment processing (e.g. payment processors).

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.

Links to Other Sites
——————–

Our Service may contain links to other sites 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.

Children’s Privacy
——————

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone
under the age of 18. 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 children without verification
of parental consent, we take steps to remove that information from our
servers.

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 “effective 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, please contact us:

* By email: info@prawncoastal.com​

 

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Prawn Holding, LLC (“Company”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit the Company website or subscribe to receive the Company services (collectively, our “Services”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

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 (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category A – Identifiers

Examples: Name, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.

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

Examples: Name, signature, Social Security number, address, telephone number, fax number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, bank account number, credit card number, debit card number, or any other financial information, physical illness, mental illness or disabilities.

Category C – Protected classification characteristics under California or federal law

Examples: Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.

Category D – Commercial information

Examples: Records of personal property.

Category F – Internet or other similar network activity

Examples: Access history and information on your interaction with our application.

Category I – Professional or employment-related information

Examples: Occupation, employer information.

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 level, school attended.

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

Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.

Directly from you. For example, through information we ask from you when our clients or their agents subscribe and engage our Services.

Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website.

Use of Personal Information

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

To fulfill or meet the reason for which the information is provided. For example, to submit this information to our clients or their agents in the form of insurance application forms or request for information.

To provide you with email alerts and other notices concerning our Services, or updates to your insurance application process.

To improve our Services to you.

For testing, research, analysis and product development.

As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

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

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

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

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

Category J: Non-public education information.

We disclose your personal information for a business purpose to the following categories of third parties:

Our clients or their agents for which you have engaged in a business contract.

Service providers.

Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your

verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.

Our business or commercial purpose for collecting that personal information.

The categories of third parties with whom we share that personal information.

The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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

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.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at CCPA@useindio.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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

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

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

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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

Non-Discrimination

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

Deny you use of our Services.

Provide you a different level or quality of Services.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting the Company website and this Privacy Notice to check for any changes.

Contact Information

If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at: info@prawncoastal.com.