🌴 California Privacy Choices

Effective Date: February 18, 2026 | Last Updated: February 18, 2026

✅ Good News: HotSpot Does NOT Sell Your Personal Information

HotSpot does not and will not sell your personal information to third parties.

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), you have the right to opt-out of the "sale" of personal information. Because we don't sell your data, there is nothing to opt-out of.

Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right	Description	How to Exercise
Right to Know	Request disclosure of personal data we collect, use, and disclose	Email: privacy@hotspot-us.com
Right to Delete	Request deletion of your personal data (subject to exceptions)	Settings > Account > Delete Account
Right to Opt-Out of Sale	Opt-out of "sale" of personal information	NOT APPLICABLE - We don't sell your data
Right to Correct	Request correction of inaccurate personal data	Settings > Profile > Edit Information
Right to Limit Use of Sensitive Data	Limit use of sensitive personal information (CPRA)	Email: privacy@hotspot-us.com
Right to Non-Discrimination	We will not discriminate for exercising your rights	Automatic - no action needed

Categories of Personal Information We Collect

Identifiers: Email, username, device ID
Demographic Information: Age, gender, relationship status (self-reported)
Commercial Information: Check-in history, promotion redemptions
Geolocation Data: Venue check-in locations (NOT continuous GPS tracking)
Internet Activity: App usage, features accessed, check-in patterns
Inferences: Preferences derived from your check-in behavior

How We Use Your Personal Information

Provide Services: Enable check-ins, Hot Sync, promotions
Analytics: Generate aggregated, anonymized venue statistics
Personalization: Show relevant venues and promotions
Safety & Security: Fraud prevention, account security
Communications: Send transactional and promotional notifications

How We Share Your Personal Information

⚠️ Data Sharing with Venues (Anonymized)

When you check in at a venue, your data is shared as follows:

Aggregated Demographics: Venues see anonymized statistics (e.g., "45% Female, Average age 26") - NOT linked to your identity
First Name Only: When redeeming promotions, venues see your first name and redemption timestamp
We NEVER share: Email, phone, last name, exact GPS coordinates, or full profile

With Venues: Anonymized demographics and promotion redemption data
With Friends (Hot Sync): Real-time check-ins (ONLY if you accept connection request)
Service Providers: Cloud hosting (AWS), push notifications (Apple/Firebase), analytics (anonymized)
Legal Requirements: When required by law or to protect rights

We Do NOT Sell or Share for Cross-Context Behavioral Advertising

✅ We do NOT sell personal information for money or other valuable consideration
✅ We do NOT share personal information for cross-context behavioral advertising
✅ We do NOT share sensitive personal information for purposes other than providing services

Sensitive Personal Information

We collect the following sensitive personal information (as defined by CPRA):

Precise Geolocation: Venue check-in locations (NOT continuous tracking)
Demographic Data: Gender, relationship status (self-reported, optional)

We USE sensitive information ONLY to:

Provide check-in services and verify you're at the venue
Generate anonymized, aggregated venue statistics
Personalize your experience

We do NOT use sensitive information for:

Cross-context behavioral advertising
Profiling for decisions with legal/significant effects

How to Exercise Your Rights

1. Right to Know

Email: privacy@hotspot-us.com with subject line: "CCPA Right to Know Request"

Include: Your name, email, username, and description of information requested

2. Right to Delete

Option A: In-app: Settings > Account > Delete Account

Option B: Email: privacy@hotspot-us.com with subject line: "CCPA Deletion Request"

3. Right to Correct

Option A: In-app: Settings > Profile > Edit Information

Option B: Email: privacy@hotspot-us.com with details of incorrect information

4. Right to Limit Use of Sensitive Data

Email: privacy@hotspot-us.com with subject line: "CPRA Limit Sensitive Data Request"

Note: Limiting location data may prevent core check-in functionality

Verification Process

To protect your privacy, we will verify your identity before processing requests:

We will match your request to email address on file
We may ask for additional verification (e.g., account password, security questions)
For deletion requests, we may require additional verification to prevent fraud

Response Timeline

45 days: We will respond within 45 days of receiving your request
Extension: May extend by an additional 45 days if reasonably necessary (we will notify you)
Free: Responding to requests is FREE (first 2 requests per 12 months)

Authorized Agents

You may designate an authorized agent to make requests on your behalf. The agent must:

Provide written authorization signed by you
Verify their own identity
You may still need to verify your identity directly with us

Non-Discrimination

We will NOT discriminate against you for exercising your CCPA/CPRA rights.

We will not:

Deny you goods or services
Charge different prices or rates
Provide different quality of services
Suggest you will receive different prices or quality

Shine the Light Law (Cal. Civ. Code §1798.83)

California residents may request information about disclosure of personal information to third parties for direct marketing purposes.

Request: Email privacy@hotspot-us.com with subject line: "Shine the Light Request"

Frequency: Once per calendar year

California Minors (Under 18)

HotSpot requires users to be 17+. California minors have additional rights:

Right to request removal of content you posted
Right to request deletion of account
Email: privacy@hotspot-us.com with subject line: "Minor Content Removal Request"

Contact Information

For California Privacy Questions or Requests:

Email: privacy@hotspot-us.com
Subject Line: Include "CCPA" or "CPRA" for fastest processing
Mailing Address: HotSpot, Inc., [Address TBD]

Updates to This Notice

We may update this California Privacy Choices page from time to time. We will notify you of material changes via email or in-app notification.