Effective Date: 30th January 2026
This California Privacy Policy describes how PACTM LLC (the "Company," "we," or "us") collects and processes personal information about our consumers who reside in California.
The California Consumer Privacy Act ("CCPA") requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information.
This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.
This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy notice at Privacy Policy.
We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information").
Personal information does not include:
publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience;
lawfully obtained, truthful information that is a matter of public concern;
deidentified or aggregated consumer information; or
information excluded from the CCPA's scope, such as:
health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act.
The chart below identifies which categories of personal information we collected from our consumers within the last 12 months and the expected retention period.
| Category | Examples | Collected | Retention Period |
|---|---|---|---|
| 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 | For as long as the user maintains an account, or as otherwise required by law. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records"). | A name, signature, Social Security number, physical characteristics or description, photograph, 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 | For as long as the user maintains an account, or as otherwise required by law. |
| C. Protected classification characteristics under California or federal law ("Protected Classes"). | 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, reproductive health decisionmaking, military and veteran status, or genetic information (including familial genetic information). | Yes | For as long as the user maintains an account, or as otherwise required by law. |
| D. Commercial information. | Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes | Up to 7 years for financial and accounting compliance. |
| 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. | Yes | Stored only as long as necessary to complete age verification (or, where applicable, age estimation), and in no event retained longer than 30 days after completion of that purpose, unless a longer retention period is required by law or expressly authorized by the user |
| F. Internet or other similar network activity. | Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites. | Yes | Up to 24 months, unless retained longer for security, compliance, or fraud-prevention purposes. |
| G. Geolocation data. | Approximate location data inferred from your IP address when you use our website or services. We do not collect precise GPS or device-based location information. | Yes | Retained for as long as reasonably necessary for functionality, fraud prevention, and analytics, typically not longer than 12 months, unless a longer period is required by law |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes | Retained for as long as necessary to provide the Services and enforce our policies, or until the user deletes the content or closes their account, whichever is earlier, unless a longer retention period is required or permitted by law (e.g., for legal compliance, fraud prevention, or safety concerns). |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | No | N/A |
| 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)) ("FERPA Information"). | 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 | N/A |
| K. Inferences drawn from other personal information. | Profiles reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. | Yes | For as long as the user maintains an account, or as otherwise required by law. |
| L. Sensitive personal information. | Further identified in the chart below. | No | N/A |
Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. The California Consumer Privacy Act (CCPA) only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.
The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.
| Sensitive Personal Information Category | Collected to Infer Characteristics? | Retention Period |
|---|---|---|
| L.1. Government identifiers, such as Social Security number (SSN), driver's license, state identification card, or passport number. | No | N/A |
| L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password. | No | N/A |
| L.3. Precise geolocation, such as physical store visits or physical locations when visiting websites or using mobile apps. | No | N/A |
| L.4. Racial or ethnic origin. | No | N/A |
| L.5. Citizenship or immigration status. | No | N/A |
| L.6. Religious or philosophical beliefs. | No | N/A |
| L.7. Union membership. | No | N/A |
| L.8. Mail, email, or text messages not directed to the Company. | No | N/A |
| L.9. Genetic data. | No | N/A |
| L.10. Neural Data, such as information generated by measuring a consumer’s central or peripheral nervous system’s activity that is not inferred from nonneural information. | No | N/A |
| L.11. Unique identifying biometric information. | No | N/A |
| L.12. Health information. | No | N/A |
| L.13. Sex life or sexual orientation information. | No | N/A |
We obtain the categories of personal information listed above from the following categories of sources:
We may use and disclose the personal information we collect to advance the Company’s business and commercial purposes, specifically to:
We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):
We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.
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. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.
We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.
We may disclose the personal information we collect to third parties for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the table below, such as to engage third parties to support our business functions. For example, we may disclose IP address and device information to analytics providers to help us understand user engagement, or age verification data to a compliance vendor to confirm user eligibility.
We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA's other contract requirements for engaging service providers or contractors.
The chart below identifies the categories of entities to whom we have disclosed our consumers' personal information for a business purpose over the preceding 12 months, along with the personal information categories disclosed and the disclosure's business purposes.
| Category of Business Purpose Disclosure Recipients | Personal Information Categories Disclosed | Sensitive Personal Information Categories Disclosed | Business Purpose Disclosures |
|---|---|---|---|
| Customer Service Support Providers |
| None | To support customers with using our products and services, including online account management and troubleshooting. |
| Hosting and Infrastructure Providers |
| None | To host our websites and services and ensure performance, uptime, and data storage capabilities. |
| Age Verification Providers |
| None | To verify user age and identity and ensure compliance with legal obligations and platform eligibility requirements. |
| Security and Fraud Prevention Providers |
| None | To detect, prevent, and mitigate security incidents and malicious or fraudulent activity affecting the platform. |
| Analytics Providers |
| None | To analyze traffic and usage patterns to improve functionality and user experience. |
| Payment Processors |
| None | To process and fulfill payments for subscriptions and related purchases. |
| Sellers |
| None | To enable Sellers to fulfill orders for physical goods, including shipping and customer communications related to the transaction. |
We do not sell your personal information to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.
Our personal information sales or sharing does not include information about consumers we know are under age 16.
If you are a California resident, the CCPA grants you the following rights regarding your personal information:
You have the right to request that we disclose certain information about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request").
Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involve disproportionate effort. You may exercise your right to know twice within any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:
For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers to take appropriate action.
You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers to take appropriate action.
For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.
You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes (the "right to limit"). As we do not use or disclose sensitive personal information beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right.
For more on the Permitted SPI Purposes, see Sensitive Personal Information Use and Disclosure Purposes
You have the right to request that businesses stop selling or sharing your personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in").
As we do not sell or share consumers' personal data, we do not currently provide these consumer rights.
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.
To exercise the right to know, data portability, delete, or correct described above, please submit a verifiable request to us by:Emailing us at: [email protected].
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice within a 12-month period.
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. To designate an authorized agent, you must provide written authorization signed by you and your agent, or a valid power of attorney. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.
We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make the request.
We consider requests made through your password-protected account with our company sufficiently verified when the request relates to personal information associated with that specific account. You do not need to create an account with us to submit a request to know, correct, or delete.
For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer's name, email address, or account username.
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact [email protected].
We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.
Any disclosures we provide will cover information for the 12-month period preceding the request's receipt date. We will consider requests to provide a longer disclosure period that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort.
For data portability requests, we will select a format to provide your personal information that is readily usable 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 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.
We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.
The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.
We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website. We encourage you to check our website to review the current Privacy Policy in effect.
If you have any questions or comments about this policy, the ways in which we collect and use your information described here, your choices and rights regarding that use, or wish to exercise your rights under California law, please do not hesitate to contact us at: [email protected].
If you need to access this Privacy Policy in an alternative format due to a disability, please contact [email protected].