Effective August 12, 2026

Privacy Policy

At Lighter, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

For individuals in Connecticut, Washington or Nevada, please also refer to our Consumer Health Data Privacy Policy for additional information about the processing of your consumer health data, which controls for that data.

What this Privacy Policy Covers

Lighter is a technology platform dedicated to helping you privately track your GLP-1 and peptide use with simple, personalized tools. We are not a medical provider and do not provide medical advice. The Personal Data that you provide to Lighter through the Services, therefore, is not considered “protected health information” and is not subject to the Health Insurance Portability and Accountability Act (“HIPAA”). “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations.

Lighter provides consumer-facing wellness tools. We are not a “covered entity” or “business associate” under HIPAA. Accordingly, most information we collect through our app and website is not “protected health information” under HIPAA.

Your use of Lighter’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

Health Entries — the data we protect absolutely

Some of what you put into Lighter is the reason the app exists, and we hold it to a stricter rule than everything else in this Policy. We call it your Health Entries, and we mean, specifically:

  • the medications you select, including brand and generic names;
  • the route, dose amount and unit, injection site, and pain level you record for a dose;
  • the side effects you log and their severity;
  • your weight, height, body metrics, starting and goal weight, goal pace, biological sex, and date of birth;
  • your food, nutrition, and water logs, and any food photo you take;
  • your progress photos;
  • your answers to onboarding questions about your health, goals, and journey;
  • any free-text note you write; and
  • any value read from, or written to, Apple Health.

Health Entries are never used for advertising or marketing, are never disclosed for advertising or marketing, and are never transmitted to an advertising platform or to our attribution provider.

What we do share for advertising measurement — and it includes none of the items above — is described in Advertising Measurement and Attribution below.

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal DataBusiness/Commercial PurposeCategories of Third Parties We Disclose To
Profile or Contact Data such as your email address and any name you provide.Providing, customizing and improving the Services; corresponding with you.Service Providers.
Device, Connection and Identifier Data such as your IP address, your device’s vendor identifier (IDFV), your device’s user-agent string, other device identifiers, app version, and diagnostic and crash data.Providing, customizing and improving the Services; security and debugging; advertising measurement and attribution.Service Providers; Advertising Measurement Partners.
Payment Data such as your subscription and purchase status. Purchases are made through Apple in-app purchase; we do not collect or store your payment card numbers.Providing the Services.Service Providers (specifically, Apple and our subscription-management partner).
Conversion Event Data such as the fact that you installed the app, opened it, created an account and by which sign-in method, started a free trial, or started a subscription, and the gross price and currency of a subscription purchase.Advertising measurement and attribution; understanding how the Services are used.Service Providers; Advertising Measurement Partners.
Usage and Analytics Data such as coarse in-app events, tied to your random account identifier, and the way features are used.Providing, customizing and improving the Services.Service Providers.
Consumer Demographic Data such as date of birth, biological sex, and similar information.Providing, customizing and improving the Services.Service Providers.
Health Data such as the medications, doses, routes and injection sites you log, pain levels, side effects and severity, weight and body metrics, food and water logs, goals, onboarding answers, and similar information. (These are your Health Entries.)Providing, customizing and improving the Services.Service Providers.
Sensory Data such as optional progress photos and food photos that you choose to provide. (These are your Health Entries.)Providing, customizing and improving the Services.Service Providers.
Community Data such as Group membership, messages, photos, reactions, display name, logging streak, Group information you choose to provide, and report or block records.Providing and moderating the optional Groups features you choose to use; security and safety.Service Providers; Other Group Members and Parties You Choose to Share With.
Credentialing Data such as your Lighter login credentials or information generated when you sign in with Apple or by email.Providing, customizing and improving the Services.Service Providers; Parties You Authorize, Access or Authenticate.
Consent and Acceptance Records such as the fact that you accepted our Terms and were shown our privacy notices, the version of each document you were shown, and the date, time and screen on which you did so.Keeping a record of your choices; honoring your privacy choices and legal rights.Service Providers.
Other Identifying Information that You Voluntarily Choose to Provide such as emails or other communications you send us.Providing, customizing and improving the Services; corresponding with you.Service Providers.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

  • Creating and managing your account or other user profiles.
  • Processing your subscription and other transactions.
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics, and product development and improvement.
  • Personalizing the Services and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

Measuring Our Advertising

  • Understanding which advertising campaigns and channels lead people to install Lighter, create an account, start a trial, or subscribe, as described in Advertising Measurement and Attribution below.

Corresponding with You

  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Lighter or the Services.
  • Sending emails and other communications according to your preferences.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Lighter or another party; enforcing any agreements with you; responding to claims that any content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

  • When you provide such information directly to us.
  • When you create an account or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to onboarding questions or questionnaires.
  • When you join or create a Group, post or react to Community content, upload a Community photo, or use report or block tools.
  • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically, such as through diagnostic and usage signals.

Third Parties

  • We use an analytics provider to analyze how you interact and engage with the Services. Those events are tied to your random account identifier — not your name or email — and carry coarse categories rather than exact values.
  • Our attribution provider tells us which advertising campaign a new install can be attributed to.

Parties You Authorize, Access or Authenticate

  • Sources you choose to integrate, such as Apple Health. With your permission, Lighter can read profile facts, activity, nutrition, water, and weight from Apple Health, and can write nutrition, water, and weight that you log in Lighter to Apple Health. Lighter does not write medications, doses, side effects, or photos to Apple Health.
  • If you sign in to the Services through a third party, such as Sign in with Apple, limited information from that account (such as an identifier and, if you choose to share it, an email address) may be transmitted into your account with us.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. For more information, please refer to the state-specific sections below.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They are permitted to use the data only to provide those services to us, under contracts that limit them to our instructions. They include:

  • Supabase, for our hosted database, authentication, and file storage.
  • Cloudflare, for private storage of optional progress and Community photos (R2) and cookieless website analytics.
  • PostHog, for product analytics. Events are tied to your random account identifier — not your name or email — and carry coarse categories (for example a BMI band, an age range, or whether you use a branded or compounded medication), never exact values, medication names, doses, side effects, notes or photos.
  • RevenueCat, for subscription management.
  • Superwall, for paywall presentation.
  • Brevo, for transactional and lifecycle email.
  • Apple, for app distribution, in-app purchases, and Sign in with Apple.
  • Google, for website analytics (Google Analytics through Google Tag Manager) — limited cookieless measurement may run before opt-in; analytics cookies and persistent measurement require opt-in, and advertising features stay off.
  • Google (Gemini API), for the AI analysis of food photos you choose to scan. When you scan a meal, that photo is sent to Google’s Gemini API so it can be identified and estimated. It is processed to return that result to you and for no other purpose; it is not used for advertising, and it does not go to our attribution provider or to any advertising platform.
  • AppsFlyer, our mobile measurement and attribution provider, which helps us understand which marketing channels lead to app installs and subscriptions. It receives standard install and session attribution data (which includes your IP address, your device’s vendor identifier, and your device’s user-agent string), an internal Lighter account identifier, and four non-health conversion events: the app was opened, an account was created (with the sign-in method you used — Apple, Google, or email), a free trial was started, and a subscription was started (with the gross price and currency of the purchase). AppsFlyer processes this data on our behalf under a contract that limits it to that purpose. At our instruction, AppsFlyer forwards some of that data onward to the advertising platform described immediately below.

Advertising Measurement Partners. These are not our service providers, and the “only on our instructions” sentence above does not apply to them. They receive measurement data as independent advertising businesses and use it for their own advertising purposes, under their own terms and privacy policies.

  • Meta Platforms (Facebook and Instagram), where we buy advertising. Meta receives, through AppsFlyer, the four conversion events described in Advertising Measurement and Attribution below, with the gross price and currency attached to the subscription event, together with device and connection information that includes your IP address, your device’s vendor identifier (IDFV), and your device’s user-agent string. Meta’s privacy policy is at facebook.com/privacy/policy; its ad-preference controls are at accountscenter.facebook.com/ads.

Meta is currently the only advertising platform that receives this data. If we advertise on additional platforms in the future, they will receive the same limited measurement data described here, and we will update this Policy.

Parties You Authorize, Access or Authenticate. With your permission and consent, Lighter is configured to share data about you with parties you authorize, access, or authenticate, such as Apple Health.

Other Group Members and Parties You Choose to Share With. If you choose to use Groups, we disclose the Community Submissions you post, together with your display name and logging streak, to the other members of the relevant Group. Your private tracking entries are never posted to a Group unless you choose to include them in a Community Submission.

We never sell your Health Entries, and we never share your medications, doses, weight, body metrics, side effects, food logs, notes, photos, or Apple Health data with advertisers or for advertising. Your private health entries stay in your account and are used only to provide the Services you request; content you voluntarily post to a Group is disclosed only as described above and in the Community Features section below. Your full-fidelity health data is never sent to analytics or advertising services; only coarse categories, tied to your random account identifier, are used to understand how the Services are used.

Separately, we share a limited set of non-health measurement signals — device and connection identifiers and conversion events — with our attribution provider and with the advertising platform we advertise on, so we can measure how our marketing performs. That sharing is described in full in Advertising Measurement and Attribution below.

Community Features (Optional)

Lighter includes optional community features ("Groups") that you can choose to use. When you join a Group and post a message, photo, or reaction, that content — together with your display name and logging streak — is visible to the other members of that Group. It is shared content, not private data, so you should not post anything you want to keep confidential, including sensitive health details. Your logs, dose data, weight, and other personal entries are never posted to a Group unless you type them into a message or otherwise choose to share them yourself.

Because Groups are visible to other people, we cannot guarantee your anonymity in them. Other members may be able to infer who you are from what you post, from your display name, or from other context.

To keep Groups safe and supportive, we provide tools to report messages and block members, and we may remove content or restrict accounts that violate our Community Guidelines. When content is reported, we retain a copy of the reported message — and, for a reported photo, the image for up to 30 days — so we can review and act on the report even if the underlying message is later deleted, after which we delete it. If you delete your account, your Group memberships, messages, reactions, and Community photos are removed. A private Group you created may continue under another member's leadership, so its name and description may remain, but its link to you is removed. A report record and its content snapshot may also be retained as described above, on a legitimate-interest basis, for safety and to comply with law.

Advertising Measurement and Attribution

Like most apps, we run ads to help people discover Lighter, and we want to understand which ads and channels actually work so we do not waste money on ones that do not. Measuring this is called “attribution.” This section describes what leaves your device and who receives it.

The identifiers involved, in plain English

  • IP address — the numeric address your device uses on the internet. It changes as you move between networks and it indicates your approximate location, typically at the level of a city or region.
  • Vendor identifier (IDFV) — an identifier Apple gives your device that is the same across all apps published by us, and different for every other developer. It is not the advertising identifier, and it is not shared across companies. It resets when you delete all of our apps from the device.
  • User-agent string — a short line of text your device sends that describes your operating system and its version.
  • Advertising identifier (IDFA) — Apple’s cross-company advertising identifier. Lighter never accesses or shares it. See Apple’s tracking prompt below.
  • Internal Lighter account identifier — a random identifier we generate for your account. It is not your name or email.

What our attribution provider receives

AppsFlyer assembles this measurement for us, as our service provider. It receives standard install and session attribution data — which includes your IP address, your device’s vendor identifier, and your device’s user-agent string — the internal Lighter account identifier we use to keep one person’s events together, and four non-health conversion events:

  1. The app was opened — no other information attached.
  2. An account was created — with the sign-in method you used, which is one of “apple”, “google”, or “email”. Never your email address itself.
  3. A free trial was started — no other information attached.
  4. A subscription was started — with the gross price and currency of the purchase (for example, 39.99 and USD).

The price is attached only to real App Store purchases, and we do not send the name of the product or plan.

What our advertising partners receive

We advertise on third-party advertising platforms — currently Meta (Facebook and Instagram). So that the platform we advertise on can measure which of its ads led to installs and subscriptions, we have instructed AppsFlyer to forward to it the four conversion events listed above, with the gross price and currency attached to the subscription event, together with device and connection information that includes your IP address, your device’s vendor identifier (IDFV), and your device’s user-agent string.

We have configured this to apply to people who installed Lighter after seeing one of our ads on that platform, rather than to everyone who uses the app. These advertising platforms are not our service providers for this data. They receive it as independent advertising businesses, use it for their own advertising purposes under their own terms, and may combine it with information they already hold about you. We do not control that.

What is never included

None of your Health Entries — as defined near the top of this Policy — is ever included: not your medications, doses, routes, injection sites, pain levels, weight, body metrics, side effects, food or water logs, onboarding answers, free-text notes, or photos. We do not use your health information to target ads, and we do not build advertising audiences from it.

For the avoidance of doubt, the foregoing excludes data that originates from Apple Health. Data obtained from Apple Health is used only to provide health and fitness features in the app, is never used for advertising or data mining, is never sold, and never reaches our attribution provider or any advertising platform.

Some state privacy laws give information related to health special protection. Our Consumer Health Data Privacy Policy explains how we handle that question.

Apple’s tracking prompt

Lighter does not show Apple’s App Tracking Transparency prompt, and Lighter never accesses your device’s advertising identifier (IDFA).

That means no cross-company advertising identifier ever leaves the app. It does not mean the sharing described above is switched off: Apple’s tracking prompt governs the advertising identifier, and your IP address, your device’s vendor identifier, and your user-agent string are not governed by it. Because we show no prompt, there is nothing there for you to decline.

Your choices, and their limits

We do not currently offer a control inside the app that turns this measurement sharing off while you keep using Lighter. What you can do today:

  • Delete your account in the app (Settings → Delete Account). This deletes your account and its data, and also sends a request to our attribution provider to erase the data it holds about you.
  • Email us at [email protected]. You do not need an account to contact us. We will treat your message as a request under the Exercising Your Rights under U.S. State Privacy Laws section below.
  • On this website, use the “Cookie preferences” link in the footer to give or withdraw consent for analytics cookies at any time. That control governs the website only; it has no effect on the app measurement described above.

Two limits apply to any of those routes:

  1. Our service providers keep processing data to run the app itself.
  2. We cannot recall data that has already been delivered. Once a conversion event and the identifiers above have reached an advertising platform, we cannot compel that platform to delete copies it may have made, and we may not be able to locate or delete data already transmitted.

Your Privacy Choices (Do Not Sell or Share; Limit Sensitive Data)

Some state privacy laws define “sell,” “share,” and “targeted advertising” very broadly. We treat the advertising measurement described above as a “share” under the California Consumer Privacy Act, and we honor opt-out requests accordingly. It may also qualify as a “sale” under some states’ definitions.

We disclose to our attribution provider and to the advertising platform we advertise on: device and connection information — including your IP address, your device’s vendor identifier (IDFV), and your device’s user-agent string — and four conversion events: the app was opened, an account was created (with the sign-in method), a free trial was started, and a subscription was started (with the gross price and currency). We do not sell or share any other category of personal information, and no Health Entry is any part of it.

We do not use your Sensitive Personal Data — including your Health Entries — for advertising, to target ads, to build advertising audiences, or to infer characteristics about you. We use it only to provide the Services you request and for the other permitted purposes described in this Privacy Policy.

You can exercise your choices in these ways:

  • Email us at [email protected] to ask a question or exercise any of the rights described in this Policy. You do not need an account to contact us.
  • Delete your account and its data from inside the app (Settings → Delete Account). Deleting your account also triggers a request to our attribution provider to erase the data it holds about you.
  • On this website, use the “Cookie preferences” link in the footer to give or withdraw consent for analytics cookies at any time.

Two limits apply to any such request: our service providers continue processing personal data in order to run the app itself; and opting out does not undo sharing that already happened — we cannot recall events already delivered to an advertising platform, or compel that platform to delete copies it holds.

We will not discriminate against you for exercising these choices.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Cookies, Website Tools and Opt-Out

Our website uses cookies and similar technologies (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our website, analyze trends, learn about our user base and operate and improve our website. Cookies are small pieces of data — usually text files — placed on your computer, tablet, phone or similar device when you use that device to access our website.

Please note that because of our use of Cookies, the website does not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings, maintain your preferences over time and recognize you when you return.
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our website by collecting information such as the number of visitors and the pages they view.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies. You can also delete all Cookies that are already on your device. If you do this, however, some of the website’s functionality may not work.

Website analytics. We use two analytics tools on our website. Cloudflare Web Analytics is a privacy-first, cookieless tool that sets no cookies and uses no cross-site identifiers or fingerprinting; it reports only aggregate, non-identifying metrics such as page views, referrers, and general location and device type. We also use Google Analytics through Google Tag Manager. Google Consent Mode starts with analytics storage denied, so limited cookieless requests may be used for aggregate measurement and modeling before you opt in, but analytics cookies and persistent measurement stay off. If you accept through the consent banner, Google Analytics may store analytics cookies for fuller session and conversion measurement. We keep Google’s advertising features turned off, do not use website analytics for advertising, and do not intentionally add health entries, account or user IDs, or free-text values to analytics events. You can change or withdraw your choice at any time using the “Cookie preferences” link in the website footer.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. This includes row-level access controls for private account data, membership-based access controls for non-public Group content, encryption in transit and at rest, and private (non-public) storage for progress and Community photos. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

  • We retain your profile information and credentials for as long as you have an account with us.
  • We retain your subscription and purchase status for as long as we need it to process your subscription.
  • We retain your device/diagnostic data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
  • We retain your Community content while it remains posted or while your account exists. When content is reported, we retain the reported message snapshot and any reported photo for up to 30 days so we can review and act on the report, then delete that retained content.

If you delete your account, your Group memberships, messages, reactions, and Community photos are removed. A private Group you created may continue under another member's leadership, so its name and description may remain after its link to you is removed. A report record and its content snapshot may also be retained for the limited safety, legal, and moderation purposes described above; user pointers are removed from the surviving report record.

Advertising measurement data we have already sent is a specific exception. Deleting your account sends our attribution provider a request to erase the data it holds about you. But conversion events and identifiers already delivered to an advertising platform cannot be recalled: we cannot compel that platform to delete copies it may have made, and we may not be able to locate or delete data already transmitted.

You can delete your entire account and its data from inside the app (Settings → Delete Account), or by emailing [email protected].

Personal Data of Children

We do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at [email protected].

U.S. State Privacy Rights

If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the “Exercising Your Rights under U.S. State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that your rights may be subject to certain conditions or exceptions in accordance with applicable U.S. State Privacy Laws.

If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected].

  • Access: You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data. If you are an Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to which we have disclosed your Personal Data.
  • Deletion: You may have the right to request that we delete the Personal Data that we have collected about you.
  • Correction: You may have the right to request that we correct any inaccurate Personal Data we have collected about you.
  • Portability: You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
  • Opt out of sale, sharing, or targeted advertising: You may have the right to direct us to stop selling or sharing personal data about you, or processing it for targeted advertising. See Your Privacy Choices above for what that covers and for its two limits.

Processing of Sensitive Personal Data

As needed, we may collect Personal Data that may be deemed “sensitive” under certain U.S. State Privacy Laws (“Sensitive Personal Data”), including health information. The categories of Sensitive Personal Data we collect and our purposes for collecting such Sensitive Personal Data are described in the “Categories of Personal Data We Collect” section above. We use and disclose your Sensitive Personal Data only to provide the Services you request and for the other permitted purposes described in this Privacy Policy; we do not use it for advertising and we do not use it to infer characteristics about you. Depending on your state of residence, you may have the right to opt in, the right to opt out, or, if you are a California resident, the right to limit our use of your Sensitive Personal Data to permitted purposes. You can exercise these choices as described in the “Your Privacy Choices” section above, or by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section.

Automated Decision Making and Profiling

Depending on the state of your residence, you may have the right to opt-out of the use of automated decision making technology or the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable. However, we do not process your Personal Data in this manner.

Anti-Discrimination

We will not discriminate against you for exercising your rights under applicable privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other State-Specific Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to prevent the disclosure of their personal data to third parties for such third parties’ direct marketing purposes. We do not, however, disclose your Personal Data for such purposes.

Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Washington, Nevada and Connecticut residents: please see our Consumer Health Data Privacy Policy, which is a separate document and which controls as to consumer health data.

Exercising Your Rights under U.S. State Privacy Laws

To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below), must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

Because a Lighter account can be created without a name or email address, we may not be able to connect a request to a specific account. If that happens we will tell you what we would need in order to do so, rather than simply refusing.

We may decline a request, in whole or in part, where applicable law permits — for example where complying is prohibited by law, where it would harm another person’s rights, where it would reveal a trade secret, where we are unable to authenticate you as the person to whom the data relates, or where the request is unreasonable or excessive. We will tell you which ground applies.

We will work to respond to your Valid Request within the time period required by applicable privacy laws. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Access, Delete, Correct. As applicable, you may submit a Valid Request for your right to access, delete, correct, or obtain a copy of your Personal Data described in this Privacy Policy by emailing us at [email protected]. If you are a California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, or Texas resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Appealing a Denial

If you are a Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. We will respond to your appeal within the time period required under the applicable law. You can submit a request to appeal by emailing us at [email protected]. If we deny your appeal, you have the right to contact the Attorney General of your State.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at [email protected].

Flame Industries Inc., 7901 4th St N, STE 300, St. Petersburg, FL 33702.