HPLY CALIFORNIA PRIVACY NOTICE

Effective Date: August 10, 2026

TABLE OF CONTENTS

PART 1 — NOTICE AT COLLECTION, CATEGORIES OF PERSONAL INFORMATION, BUSINESS PURPOSES, SOURCES, DISCLOSURES, AND RETENTION

1.Scope and Relationship to the Privacy Policy

2.California Notice at Collection

3.Personal Information Covered by This Notice

4.Categories of California Residents

5.Identifiers

6.Customer Records Information

7.Protected Classification Characteristics

8.Commercial Information

9.Internet or Electronic Network Activity

10.Geolocation Information

11.Audio, Electronic, Visual, and Similar Information

12.Professional or Employment-Related Information

13.Education Information

14.Inferences and Preferences

15.Sensitive Personal Information

16.Sources of Personal Information

17.Business and Commercial Purposes

18.Categories of Recipients

19.Sale and Sharing of Personal Information

20.Retention Criteria

21.Data Minimization

22.Changes to Collection Practices

Schedule A — California Collection and Disclosure Matrix

PART 2 — CALIFORNIA PRIVACY RIGHTS, REQUESTS, VERIFICATION, APPEALS, SENSITIVE PERSONAL INFORMATION, AND NON-DISCRIMINATION

1.California Privacy Rights

2.Right to Know and Access

3.Right to Correct

4.Right to Delete

5.Right to Opt-Out of Sale or Sharing

6.Right to Limit Sensitive Personal Information

7.Exercising Rights

8.Authorized Agents

9.Identity Verification

10.Timing and Responses

11.Appeals and Complaints

12.Non-Discrimination

13.Recordkeeping

14.Accessibility

15.Contact Information

Schedule B — California Rights Matrix

PART 3 — COOKIES, ADVERTISING, CHILDREN, METRICS, AND REGULATORY COMPLIANCE

1.Cookies and Similar Technologies

2.Preference Signals

3.Automated Decisionmaking Technology

4.Children’s Information

5.Metrics and Recordkeeping

6.Regulatory Cooperation

7.Internal Governance

8.Updates to this Notice

9.Compliance and Notice Administration

PART 1 — NOTICE AT COLLECTION, CATEGORIES OF PERSONAL INFORMATION, BUSINESS PURPOSES, SOURCES, DISCLOSURES, AND RETENTION

1. Scope and Relationship to the Privacy Policy

This California Privacy Notice supplements the HPLY Privacy Policy and applies to California residents whose Personal Information HPLY collects or Processes in circumstances governed by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and implementing regulations (collectively, the “CCPA”).

This Notice explains the categories of Personal Information HPLY may collect, the sources from which it may be collected, the business or commercial purposes for collection and use, the categories of third parties to whom it may be disclosed, and the criteria used to determine retention.

Capitalized terms not defined in this Notice have the meanings given in the CCPA or HPLY Privacy Policy.

If the CCPA does not apply to HPLY or to a particular Processing activity, this Notice does not create rights or obligations beyond those required by applicable law or expressly provided by HPLY.

2. California Notice at Collection

At or before the point of collection, HPLY may collect the categories of Personal Information described in this Notice for the purposes identified below.

HPLY does not necessarily collect every category from every individual. The information collected depends on how a person interacts with HPLY, including whether the person visits the website, creates an account, makes a Donation, communicates with support, acts for a Nonprofit Organization, applies for a role, purchases merchandise, or uses another feature.

HPLY may provide additional contextual notices when a specific feature collects information not reasonably described by this general Notice.

HPLY will not collect additional categories of Personal Information or use collected information for materially incompatible purposes without providing any notice required by the CCPA.

3. Personal Information Covered by This Notice

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Personal Information does not include publicly available information as defined by the CCPA, lawfully obtained truthful information that is a matter of public concern, or information that has been de-identified or aggregated in accordance with applicable law.

Some information may be exempt from the CCPA or subject to another legal framework, including information governed by certain financial, health, employment, or other sector-specific laws.

HPLY will apply exemptions and limitations only as permitted by law.

4. Categories of California Residents

This Notice may apply to website visitors, registered users, Donors, prospective Donors, Nonprofit Organization representatives, Nonprofit Organization contacts, customer-support contacts, merchandise purchasers, vendors, contractors, job applicants, employees, beneficiaries, and other individuals who interact with HPLY.

The categories of information and purposes differ according to the relationship and feature used.

5. Identifiers

HPLY may collect identifiers such as name, email address, telephone number, mailing address, account username, internal account identifier, IP address, device identifier, transaction identifier, support identifier, and identifiers associated with a Nonprofit Organization representative.

HPLY may use identifiers to create and administer accounts, authenticate users, process transactions, communicate with users, provide support, detect fraud, maintain security, administer Nonprofit Organization participation, comply with law, and maintain business records.

Identifiers may be disclosed to cloud infrastructure, communications, payment, security, fraud-prevention, support, legal, accounting, and other service providers where reasonably necessary for the relevant purpose.

HPLY does not provide Donor names, email addresses, telephone numbers, mailing addresses, or other Donor contact information to participating Nonprofit Organizations for their independent fundraising, marketing, advertising, donor acquisition, or unrelated solicitation.

6. Customer Records Information

HPLY may collect information described in California customer-records statutes, including contact information, payment-related information, transaction information, account records, signatures where applicable, and other information provided in connection with a commercial, charitable, employment, or business relationship.

Payment card and bank information may be collected directly by a Payment Processor rather than stored by HPLY.

Customer records information may be used for account administration, transaction processing, Donation administration, Nonprofit Organization onboarding, support, compliance, fraud prevention, accounting, tax, and dispute-resolution purposes.

7. Protected Classification Characteristics

HPLY may receive information concerning characteristics protected under California or federal law where a person voluntarily provides the information or where collection is reasonably necessary for employment, accessibility, legal compliance, or another permitted purpose.

HPLY does not require users to disclose protected characteristics merely to browse participating Nonprofit Organizations or make ordinary use of the Services unless the information is reasonably necessary for the applicable feature or required by law.

HPLY will not use protected classification information for unlawful discrimination.

8. Commercial Information

HPLY may collect commercial information such as Donation history, transaction history, merchandise orders, refunds, chargebacks, loyalty activity where applicable, saved or favorited Nonprofit Organizations, support interactions, and related transaction records.

HPLY may use commercial information to facilitate Donations, administer transactions, provide requested Services, maintain records, provide support, prevent fraud, comply with law, and administer available account features.

Donation information provided to participating Nonprofit Organizations is limited to information reasonably necessary for payment processing, reconciliation, legal compliance, Donation administration, or another expressly authorized purpose.

HPLY does not provide Donor contact information to participating Nonprofit Organizations for their independent fundraising, marketing, advertising, donor acquisition, or unrelated solicitation.

9. Internet or Electronic Network Activity

HPLY may collect Internet or electronic network activity information such as IP address, browser type, device type, operating system, pages or screens accessed, searches, session information, authentication events, security events, referring information, error information, and interactions with the Services.

HPLY may use this information to operate and secure the Services, authenticate users, maintain sessions, diagnose technical errors, prevent fraud and abuse, maintain platform reliability, support requested functionality, and understand or respond to specific user interactions with the Services.

HPLY does not currently use third-party analytics services to analyze user activity for general behavioral analytics.

Internet or electronic network activity may be disclosed to cloud infrastructure, hosting, monitoring, security, fraud-prevention, communications, and other technical service providers where reasonably necessary to operate and protect the Services.

10. Geolocation Information

HPLY may derive approximate location from an IP address or other network information for security, fraud prevention, localization, legal compliance, and operation of the Services.

If a feature requires more precise location information, HPLY will request any permission or provide any notice required by applicable law before collecting that information.

HPLY does not collect precise geolocation merely because approximate location can be derived from an IP address.

11. Audio, Electronic, Visual, and Similar Information

HPLY may collect photographs, images, videos, audio recordings, documents, support attachments, profile materials, or similar information when voluntarily submitted or when reasonably necessary for a requested feature.

HPLY may use this information for Nonprofit Organization Profiles, verification, support, moderation, security, fraud prevention, accessibility, dispute resolution, and other purposes reasonably related to the context in which it was provided.

HPLY may disclose such information to storage, communications, security, legal, and other approved providers where reasonably necessary for the applicable purpose.

12. Professional or Employment-Related Information

HPLY may collect professional information such as job title, employer, professional affiliation, Nonprofit Organization affiliation, work history, professional contact information, and information submitted in connection with employment, contracting, vendor, or business relationships.

HPLY may use this information for Nonprofit Organization representative verification, hiring, employment administration, contracting, vendor administration, business communications, security, and legal compliance.

13. Education Information

HPLY may collect education-related information such as degrees, certifications, training, credentials, and educational history where voluntarily submitted in connection with employment, contracting, verification, or another relevant relationship.

HPLY may use this information for employment, professional evaluation, verification, or other purposes reasonably related to the context in which it was provided.

14. Inferences and Preferences

HPLY may derive or maintain limited inferences concerning communication preferences, risk, fraud, security, and other interactions with the Services where reasonably necessary to operate, protect, and improve the Services.

HPLY may independently select, organize, feature, or promote participating Nonprofit Organizations based on charitable categories, themes, campaigns, seasons, causes, editorial considerations, or promotional priorities. These selections may appear in Featured sections of the Services, newsletters, or other HPLY communications.

HPLY’s editorial selection or promotion of a Nonprofit Organization is not necessarily based on an individual user’s behavior, Donation history, interests, favorites, or other Personal Information and should not be understood as individualized behavioral profiling merely because HPLY organizes or features particular Nonprofit Organizations.

HPLY will not use charitable interests to infer sensitive characteristics in a manner that creates unlawful discrimination, unexpected profiling, or material harm.

Users may be able to manage favorites, communication settings, or other available account preferences.

15. Sensitive Personal Information

HPLY may collect Sensitive Personal Information as defined by the CCPA where reasonably necessary for a permitted purpose, including account security, authentication, fraud prevention, payment processing, employment administration, legal compliance, or another purpose permitted by applicable law.

Sensitive Personal Information may include account credentials, precise geolocation if an applicable feature is enabled, government identifiers where legally required, payment information handled through applicable providers, and other information treated as sensitive under California law.

HPLY intends to use and disclose Sensitive Personal Information for purposes that do not trigger the CCPA right to limit use and disclosure.

If HPLY later uses or discloses Sensitive Personal Information in a manner that triggers the right to limit under the CCPA, HPLY will provide the notice and limitation mechanism required by applicable law.

16. Sources of Personal Information

HPLY may collect Personal Information from:

(a) individuals directly;

(b) devices, browsers, and applications used to access the Services;

(c) participating Nonprofit Organizations and their authorized representatives;

(d) Payment Processors and financial-service providers;

(e) service providers, contractors, and vendors;

(f) publicly available sources;

(g) fraud-prevention, security, identity-verification, and compliance providers;

(h) employers, references, or professional contacts where applicable;

(i) communications and interactions with HPLY; and

(j) other sources permitted by applicable law.

HPLY does not necessarily obtain information from every source listed above for every individual.

17. Business and Commercial Purposes

HPLY may collect, use, and disclose Personal Information for business and commercial purposes including:

(a) providing, operating, maintaining, and supporting the Services;

(b) creating and administering accounts;

(c) authenticating users and securing accounts;

(d) facilitating and administering Donations and other transactions;

(e) processing payments through Payment Processors;

(f) administering participating Nonprofit Organizations and Nonprofit Organization Profiles;

(g) responding to inquiries and providing customer support;

(h) detecting, preventing, investigating, and responding to fraud, abuse, security incidents, and unlawful activity;

(i) maintaining platform reliability and diagnosing technical problems;

(j) selecting, organizing, featuring, or promoting participating Nonprofit Organizations based on charitable categories, themes, campaigns, seasons, causes, editorial considerations, or promotional priorities;

(k) administering available favorites, communication settings, and other user-selected preferences;

(l) maintaining business, accounting, tax, transaction, and compliance records;

(m) enforcing HPLY agreements and policies;

(n) protecting HPLY, Users, Nonprofit Organizations, and others;

(o) complying with legal and regulatory obligations;

(p) responding to lawful requests and legal process;

(q) conducting corporate transactions, audits, and business administration; and

(r) other purposes disclosed at collection or otherwise permitted by applicable law.

HPLY does not currently use third-party analytics services for general behavioral analytics of Users.

18. Categories of Recipients

Depending on the information and purpose involved, HPLY may disclose Personal Information to:

(a) cloud infrastructure, hosting, and technical service providers;

(b) Payment Processors and financial-service providers;

(c) communications and customer-support providers;

(d) security, fraud-prevention, identity-verification, and compliance providers;

(e) participating Nonprofit Organizations, but only to the extent reasonably necessary for payment processing, reconciliation, legal compliance, Donation administration, or another expressly authorized purpose;

(f) fulfillment, shipping, and commerce providers where applicable;

(g) professional advisers, including lawyers, accountants, auditors, and insurers;

(h) governmental, regulatory, judicial, or law-enforcement authorities where required or permitted by law;

(i) parties to an actual or proposed merger, financing, acquisition, restructuring, sale of assets, or similar corporate transaction; and

(j) other recipients authorized by the individual or permitted by applicable law.

HPLY does not provide Donor names, email addresses, telephone numbers, mailing addresses, or other Donor contact information to participating Nonprofit Organizations for their independent fundraising, marketing, advertising, donor acquisition, or unrelated solicitation.

HPLY does not currently disclose Personal Information to third-party analytics providers for general behavioral analytics.

19. Sale and Sharing of Personal Information

HPLY does not sell Personal Information for monetary consideration.

HPLY does not currently use advertising or cross-context behavioral advertising technologies in a manner that HPLY represents in this Notice as constituting a “sale” or “sharing” of Personal Information under the CCPA.

If HPLY implements cookies, SDKs, social integrations, advertising technologies, analytics technologies, or similar technologies and the resulting disclosure or other activity constitutes a “sale” or “sharing” of Personal Information under the CCPA, HPLY will provide any notice and right to opt out required by applicable law, including a clear and conspicuous opt-out mechanism and recognition of legally valid opt-out preference signals where required.

HPLY does not knowingly sell or share the Personal Information of consumers under sixteen years of age without the affirmative authorization required by law.

Disclosures to Service Providers and Contractors under contracts satisfying applicable CCPA requirements are not treated as sales or sharing to the extent provided by the CCPA.

20. Retention Criteria

HPLY retains Personal Information only for as long as reasonably necessary and proportionate for the purposes for which it was collected or Processed, subject to applicable legal, security, fraud-prevention, accounting, tax, recordkeeping, contractual, and dispute-resolution requirements.

Retention depends on the nature and sensitivity of the information, account status, transaction history, legal obligations, risk, applicable limitation periods, backup lifecycle, and whether a dispute, investigation, security matter, or legal hold exists.

Account information may be retained for the life of the account and an appropriate period afterward. Donation and payment records may be retained for tax, accounting, dispute, compliance, and fraud-prevention periods. Security logs may be retained according to risk and operational needs. Nonprofit Organization verification and authorization records may be retained as reasonably necessary to document participation, profile, payment, and compliance decisions.

HPLY may retain de-identified information for a longer period where HPLY maintains the information in de-identified form and does not attempt to re-identify it except as permitted by applicable law.

21. Data Minimization

HPLY seeks to collect only Personal Information reasonably necessary and proportionate for the relevant purpose.

Optional fields may be identified where practicable, and complete financial or identity credentials may be collected directly by regulated or specialized providers where appropriate.

HPLY may reject, redact, quarantine, delete, or restrict information submitted through an inappropriate or insecure channel.

Users should not submit highly sensitive information through general support messages, profile fields, email, or feedback tools unless HPLY expressly requests it through an appropriate process.

22. Changes to Collection Practices

HPLY may update the categories of Personal Information, sources, purposes, recipients, or retention practices as the Services, law, technologies, or business operations change.

When the CCPA requires notice before a new category is collected or Personal Information is used for a materially different purpose, HPLY will provide the required notice at or before collection.

The Effective Date will be revised as appropriate when this Notice changes.

SCHEDULE A — CALIFORNIA COLLECTION AND DISCLOSURE MATRIX

HPLY does not necessarily collect every category identified in this Schedule from every California resident.

The categories and practices applicable to a particular individual depend on the person’s relationship with HPLY and the Services used.

HPLY’s editorial selection, organization, featuring, or promotion of participating Nonprofit Organizations based on charitable categories, themes, campaigns, seasons, causes, or promotional priorities is not necessarily based on individualized Personal Information or behavioral profiling.

PART 2 — CALIFORNIA PRIVACY RIGHTS, REQUESTS, VERIFICATION, APPEALS, SENSITIVE PERSONAL INFORMATION, AND NON-DISCRIMINATION

1. California Privacy Rights

Subject to the CCPA’s applicability, definitions, exemptions, exceptions, verification requirements, and limitations, California residents may have rights concerning Personal Information HPLY maintains about them.

These rights may include the right to know or access Personal Information, correct inaccurate Personal Information, delete Personal Information, opt out of sale or sharing, limit certain uses and disclosures of Sensitive Personal Information where applicable, and receive information concerning HPLY’s collection, use, disclosure, sale, and sharing practices.

HPLY will not discriminate against a California resident for exercising a right provided by the CCPA.

2. Right to Know and Access

A California resident may have the right to request that HPLY disclose the categories and specific pieces of Personal Information HPLY has collected about the resident, subject to applicable law.

A resident may also have the right to request information concerning:

(a) categories of Personal Information collected;

(b) categories of sources;

(c) business or commercial purposes for collection, use, sale, or sharing;

(d) categories of third parties to whom Personal Information is disclosed;

(e) categories of Personal Information sold or shared, if applicable; and

(f) categories of Personal Information disclosed for a business purpose.

HPLY may withhold information where disclosure is prohibited or limited by law, would create an unreasonable security risk, would reveal another person’s Personal Information, or is otherwise subject to an applicable exception.

3. Right to Correct

A California resident may request correction of inaccurate Personal Information maintained by HPLY.

HPLY may consider the nature of the Personal Information, the purpose for which it is maintained, and the totality of the circumstances when determining the accuracy of disputed information as permitted by law.

HPLY may request documentation reasonably necessary to evaluate a correction request.

4. Right to Delete

A California resident may request deletion of Personal Information collected from the resident, subject to applicable exceptions.

HPLY may retain Personal Information where permitted by law, including where reasonably necessary to complete a transaction, provide a requested Service, maintain security, detect fraud, comply with legal obligations, exercise legal rights, maintain required records, or satisfy another applicable exception.

Where HPLY grants a deletion request, HPLY will take the actions required by applicable law with respect to applicable Service Providers, Contractors, or other recipients.

5. Right to Opt-Out of Sale or Sharing

If HPLY sells or shares Personal Information as those terms are defined by the CCPA, California residents have the right to direct HPLY not to sell or share their Personal Information.

HPLY does not sell Personal Information for monetary consideration.

As described in Part 1, Section 19, HPLY does not currently represent that it uses advertising or cross-context behavioral advertising technologies in a manner constituting sale or sharing under the CCPA.

If HPLY engages in activity constituting sale or sharing, HPLY will provide the opt-out mechanisms required by applicable law and will recognize legally valid opt-out preference signals as required by the CCPA and applicable regulations.

6. Right to Limit Sensitive Personal Information

HPLY intends to use and disclose Sensitive Personal Information for purposes that do not trigger the CCPA right to limit use and disclosure.

If HPLY uses or discloses Sensitive Personal Information for purposes that trigger the limitation right, HPLY will provide California residents with the notice and mechanism required by applicable law.

Nothing in this Section limits rights that apply under another privacy or consumer-protection law.

7. Exercising Rights

California residents may submit privacy-rights requests by contacting HPLY at:

Email: support@hply.org

Requests should identify the right being exercised and provide sufficient information for HPLY to understand, evaluate, and respond to the request.

HPLY may provide additional request methods where required by applicable law.

A resident is not required to create an account solely to submit a request unless applicable law permits or requires account-based processing for the particular request.

8. Authorized Agents

A California resident may use an authorized agent to submit a request where permitted by the CCPA.

HPLY may require proof that the resident authorized the agent to act on the resident’s behalf and may require the resident to verify the resident’s own identity directly with HPLY, except where applicable law provides otherwise.

HPLY may require an authorized agent to provide information reasonably necessary to verify the agent’s identity and authority.

9. Identity Verification

HPLY will use reasonable methods to verify the identity of a person submitting a privacy request as required by applicable law.

Verification requirements may vary based on the nature of the request, sensitivity of the Personal Information, risk of harm from unauthorized disclosure or deletion, and information already maintained by HPLY.

HPLY may request additional information where reasonably necessary for verification.

HPLY will not disclose sensitive or account-protected information to a requester unless the applicable verification standard is satisfied.

10. Timing and Responses

HPLY will acknowledge and respond to verified California privacy requests within the periods required by applicable law.

Where permitted by law, HPLY may extend the response period and will provide any notice of extension required by law.

If HPLY denies a request in whole or in part, HPLY will provide the explanation required by applicable law.

HPLY generally does not charge a fee for processing a privacy request unless applicable law permits a reasonable fee because a request is manifestly unfounded, excessive, or repetitive.

11. Appeals and Complaints

Where applicable law provides a right to appeal a privacy-request decision, HPLY will provide the applicable appeal process.

California residents may also contact the California Privacy Protection Agency or California Attorney General regarding privacy concerns where permitted by law.

Nothing in this Notice limits a resident’s right to communicate with a governmental or regulatory authority.

12. Non-Discrimination

HPLY will not unlawfully discriminate against a California resident because the resident exercised a right under the CCPA.

Subject to applicable law, HPLY will not deny goods or services, charge a different price, provide a different level or quality of service, or retaliate against an individual merely because the individual exercised a CCPA right.

Differences reasonably related to the value of Personal Information or otherwise permitted by the CCPA are not prohibited by this Section.

13. Recordkeeping

HPLY may maintain records concerning California privacy requests, including request type, date, verification, response, outcome, appeal, and related communications, as reasonably necessary to comply with applicable law, demonstrate compliance, prevent fraud, maintain security, and resolve disputes.

These records are retained in accordance with the HPLY Privacy Policy and applicable law.

14. Accessibility

HPLY intends to make this Notice and legally required privacy mechanisms reasonably accessible in accordance with applicable law.

Individuals who require assistance accessing this Notice or submitting a privacy request may contact HPLY using the information below.

15. Contact Information

Questions or requests concerning this California Privacy Notice may be directed to:

HPLY Inc. 3517 Camino del Río South Suite 215, Mailbox #83 San Diego, CA 92108 United States

Email: support@hply.org

SCHEDULE B — CALIFORNIA RIGHTS MATRIX

The availability and scope of each right depend on applicable law and the circumstances of the relevant Processing.

PART 3 — COOKIES, ADVERTISING, CHILDREN, METRICS, AND REGULATORY COMPLIANCE

1. Cookies and Similar Technologies

HPLY may use cookies, local storage, authentication technologies, security technologies, and similar tools to provide requested functionality, authenticate users, maintain sessions, remember available preferences, detect fraud, protect the Services, and maintain platform reliability.

HPLY does not currently use third-party analytics services for general behavioral analytics and does not represent that advertising or cross-context behavioral advertising technologies are currently deployed.

If HPLY later uses analytics, advertising, pixels, SDKs, social integrations, or similar technologies, HPLY will provide any notices, consent mechanisms, opt-out rights, or other choices required by applicable law.

If any such technology or disclosure constitutes a “sale” or “sharing” of Personal Information under the CCPA, HPLY will provide the legally required opt-out mechanism and honor qualifying opt-out preference signals.

Additional information concerning cookies and similar technologies is provided in the HPLY Cookie Policy.

2. Preference Signals

HPLY will recognize and process legally valid opt-out preference signals as required by the CCPA and applicable regulations.

Where an opt-out preference signal applies to a browser, device, consumer, or other recognized context, HPLY will treat the signal in accordance with applicable California law and any legally required technical specifications.

3. Automated Decisionmaking Technology

HPLY may use automated systems, algorithms, machine learning, artificial intelligence, rules-based tools, or similar technologies in connection with functions such as security, fraud prevention, recommendations, personalization, moderation, support, and operation of the Services where those functions are made available.

HPLY’s manual or editorial selection, organization, featuring, or promotion of participating Nonprofit Organizations based on charitable categories, themes, campaigns, seasons, causes, or promotional priorities is not, merely by reason of that selection, represented by HPLY as Automated Decisionmaking Technology or individualized behavioral profiling.

To the extent HPLY uses Automated Decisionmaking Technology in circumstances that are subject to notice, access, opt-out, or other requirements under the CCPA or applicable regulations, HPLY will provide the notices, information, choices, and rights required by applicable law.

HPLY will not describe ordinary automated processing as legally regulated Automated Decisionmaking Technology unless that characterization applies under California law.

4. Children’s Information

HPLY does not knowingly sell or share the Personal Information of consumers under sixteen years of age without the affirmative authorization required by applicable law.

HPLY does not knowingly use cookies, similar technologies, or Personal Information in violation of laws governing children or minors.

Additional protections may apply where HPLY knowingly collects Personal Information from minors.

5. Metrics and Recordkeeping

HPLY may maintain records regarding California privacy requests, response times, outcomes, verification, appeals, and compliance-related metrics as required or permitted by applicable law.

Such records are maintained in accordance with the HPLY Privacy Policy, applicable law, and HPLY’s legitimate compliance, security, fraud-prevention, and recordkeeping needs.

This Section does not mean that HPLY currently uses third-party behavioral analytics services.

6. Regulatory Cooperation

HPLY may cooperate with the California Privacy Protection Agency, California Attorney General, courts, law-enforcement authorities, and other governmental or regulatory authorities where required or permitted by applicable law.

HPLY may preserve, disclose, or otherwise Process information as reasonably necessary to respond to lawful process, regulatory inquiries, investigations, or other legal obligations.

7. Internal Governance

HPLY may maintain privacy governance, data-protection, security, vendor-management, retention, and compliance processes reasonably designed to support compliance with applicable privacy law.

Nothing in this Section creates a contractual right to inspect HPLY’s internal policies, security systems, privileged materials, compliance records, or confidential business information except where applicable law expressly provides otherwise.

8. Updates to this Notice

HPLY may revise this California Privacy Notice to reflect changes in applicable law, business operations, technologies, Services, or data practices.

Where required by applicable law, HPLY will provide notice before collecting a new category of Personal Information or using Personal Information for a materially different purpose.

Material updates will be communicated where required by applicable law.

The Effective Date at the beginning of this Notice identifies the date applicable to the current version.

9. Compliance and Notice Administration

This Notice is intended to provide the disclosures required by applicable California privacy law concerning HPLY’s collection, use, disclosure, retention, sale, and sharing of Personal Information.

The HPLY Privacy Policy provides additional information concerning HPLY’s broader privacy practices.

If a more specific notice applies to a particular collection or Processing activity, that more specific notice controls with respect to the subject it expressly addresses to the extent of a conflict.

Nothing in this Notice waives, restricts, or limits a privacy or consumer right that applicable law does not permit HPLY to waive, restrict, or limit.

Questions concerning this Notice may be directed to:

HPLY Inc. 3517 Camino del Río South Suite 215, Mailbox #83 San Diego, CA 92108 United States

Email: support@hply.org