Privacy Policy

Last updated: January 2, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to EchoPad, the software program provided by the Company.
  • Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
  • CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Wabi Sabi Solutions LLC, 1968 S. Coast Hwy #107 Laguna Beach CA 92651. For the purpose of the GDPR, the Company is the Data Controller.
  • Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: California, United States.
  • Data Controller, for the purposes of GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept promoted by U.S. regulatory authorities for allowing internet users to control tracking across websites.
  • GDPR refers to EU General Data Protection Regulation.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Application or the Website or both.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. For the purpose of the GDPR, Service Providers are considered Data Processors.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
  • Website refers to EchoPad, accessible from https://echopad.com.
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You may also be referred to as the Data Subject or as the User.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. This may include, but is not limited to:

  • Email address
  • First name and last name

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s IP address, browser type, browser version, pages visited, time and date of visits, time spent on pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including the type of mobile device, unique device ID, IP address, mobile operating system, mobile browser type, unique device identifiers, and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track activity on Our Service and store certain information.

Technologies used may include Cookies, web beacons, tags, and scripts to collect and track information and improve and analyze Our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your device when you go offline, while Session Cookies are deleted when you close your browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

  • Type: Session Cookies
  • Administered by: Us
  • Purpose: Essential for providing services through the Website, authenticating users, and preventing fraud.

Cookies Policy / Notice Acceptance Cookies

  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: Identify if users have accepted cookies on the Website.

Functionality Cookies

  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: Remember choices like login details or language preference.

Tracking and Performance Cookies

  • Type: Persistent Cookies
  • Administered by: Third-Parties
  • Purpose: Track traffic and usage patterns to improve the Website and test features.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including monitoring usage
  • To manage Your Account and registration
  • For the performance of a contract (purchases/subscriptions)
  • To contact You (email, phone, SMS, push notifications) about updates and security
  • To provide news/offers unless You opt out
  • To manage Your requests and support needs
  • To deliver targeted advertising and measure its effectiveness
  • For business transfers (merger, acquisition, asset sale)
  • For other purposes such as analytics, usage trends, campaign effectiveness, and service improvement

Sharing Your Personal Information

We may share Your personal information:

  • With Service Providers (analytics, advertising, payment, support, communication)

Retention of Your Personal Data

We retain Personal Data only as long as necessary for purposes in this Privacy Policy, including legal obligations, dispute resolution, and enforcement of agreements.

Usage Data is generally retained for a shorter period unless needed for security/functionality or required by law.

Transfer of Your Personal Data

Your information may be processed at the Company’s operating offices and other locations where processing parties are located, which may be outside your jurisdiction.

We take steps reasonably necessary to ensure secure treatment of data and that transfers only occur with adequate safeguards.

Delete Your Personal Data

You have the right to delete or request deletion of Personal Data.

Where available, you may delete or manage information from within the Service. You may also contact Us to request access, correction, or deletion.

We may retain certain information where required by law or for lawful purposes.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred with notice.

Law Enforcement

We may disclose Personal Data if required by law or valid requests by public authorities.

Other Legal Requirements

We may disclose Personal Data to comply with legal obligations, protect rights/property, prevent wrongdoing, protect safety, or protect against legal liability.

Security of Your Personal Data

We use commercially acceptable means to protect Personal Data, but no method of transmission or storage is 100% secure.

Detailed Information on the Processing of Your Personal Data

Analytics

We may use third-party Service Providers to monitor and analyze use of our Service.

Google Analytics
Google Analytics tracks and reports website traffic and may share data with other Google services. You can opt out via the Google Analytics opt-out browser add-on and certain settings.
Google Privacy Policy: https://policies.google.com/privacy

PostHog
PostHog Privacy Policy: https://posthog.com/privacy

Email Marketing

We may contact You with newsletters or promotions. You can opt out via unsubscribe links or by contacting Us.

Mailchimp
Mailchimp Privacy Policy: https://mailchimp.com/legal/privacy/

Payments

We may use third-party payment processors. We do not store payment card details; they are handled by processors under their Privacy Policies.

Behavioral Remarketing

We use remarketing to advertise after you visit our Service. Vendors may use cookies and identifiers to understand usage and serve ads.

Opt-out tools may include:

Vendors may include:

  • Google Ads (AdWords) and related settings/opt-outs
  • Facebook remarketing and interest-based advertising opt-outs

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data based on consent, contract performance, legal obligations, vital interests, public interests, or legitimate interests.

Your Rights under the GDPR

You may request access, correction, objection, erasure, portability, or withdraw consent by contacting Us. We may verify identity before responding.

You may also complain to a Data Protection Authority in the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This section supplements the Privacy Policy for California residents.

Categories of Personal Information Collected

We may collect categories including:

  • Identifiers
  • California Customer Records statute categories
  • Commercial information
  • Internet/network activity
  • Sensitive personal information (e.g., account login/password)

Sources of Personal Information

We may collect information directly from You, indirectly, automatically (cookies), or from Service Providers.

Use of Personal Information

We may use personal information to operate the Service, provide support, fulfill purchases, comply with legal requests, audit, detect security incidents, and other internal uses.

Disclosure / Sharing

We may disclose categories such as identifiers, customer records, commercial info, and network activity to Service Providers and business partners for business purposes.

Sale of Personal Information

We do not sell personal information as commonly understood. However, some advertising/analytics practices may be considered a “sale” or “sharing” under CCPA/CPRA.

We do not knowingly sell personal information of consumers under 16 without affirmative authorization.

Your Rights under the CCPA/CPRA

California residents may have rights to notice, access/know, opt out of sale/sharing, correct, limit use of sensitive personal info, delete, and not be discriminated against.

To exercise these rights, contact Us:

We will respond within required timelines after verifying identity.

Do Not Sell My Personal Information

You may opt out of the sale/sharing of personal information by contacting Us. Opt outs may be browser-specific and may require repeating on different browsers/devices.

Limit the Use or Disclosure of My Sensitive Personal Information

California residents may request limits on sensitive personal information use/disclosure by contacting Us.

“Do Not Track” Policy (CalOPPA)

Our Service does not respond to Do Not Track signals. You can configure DNT in your browser settings.

Your California Privacy Rights (“Shine the Light”)

California residents with an established business relationship may request information about sharing personal data for third-party direct marketing once per year.

California Privacy Rights for Minor Users

California residents under 18 may request removal of content they publicly posted, subject to legal limitations.

Children’s Privacy

The Service may contain content appropriate for children under 13. Where applicable, we seek parental notice/consent prior to collecting personal information from a child.

We may collect persistent identifiers from children to support internal operations of the Service. We may also collect other information from children only with parent consent (or from a parent/guardian).

Parents can review, correct, or delete a child’s personal information or discontinue collection by contacting Us.

Links to Other Websites

We are not responsible for third-party sites linked through the Service. Review their policies separately.

Changes to this Privacy Policy

We may update this Privacy Policy. Changes are effective when posted. For material changes, we may notify via email and/or notice within the Service.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: