NIWERS CALIFORNIA PRIVACY NOTICE

Effective Date: pending — company being formed Version: 2026-05-v1.0


Introduction

This California Privacy Notice supplements our Privacy Policy and applies solely to California residents. It is provided pursuant to:

This Notice describes how Niwers (Fitcheck LLC d/b/a Niwers, "we", "us") collects, uses, and discloses personal information of California residents and your rights under California law.


1. Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information from California residents (CCPA categories):

CCPA Category Examples Source Purpose Disclosed to
A. Identifiers Name, username, email, phone, IP address, device ID Direct from you, automatic Account, communication, services Service providers
B. Customer records Name, address, payment information Direct from you Order fulfillment Sellers, Stripe
C. Protected classifications Age, gender (optional) Direct from you Age verification, personalization Service providers
D. Commercial information Purchase history, browsing, products viewed Automatic Recommendations, analytics Service providers
E. Internet activity Browsing history, app usage, interactions Automatic Analytics, personalization Service providers
F. Geolocation data IP-derived city/state, precise (with consent) Automatic, your consent Localization, fraud detection Service providers
G. Sensory data Photos and videos you upload Direct from you Service display, moderation Service providers, public
H. Professional information Business name, EIN (Sellers only) Direct from you INFORM Act compliance Stripe, government
I. Education information Not collected — — —
J. Inferences Style preferences, recommendations Derived Personalization Service providers
K. Sensitive personal information SSN, ITIN, gov ID (Sellers), precise location, login credentials Direct from you, automatic INFORM Act, KYC, security Stripe, KYC providers

2. Sources of Personal Information

We collect personal information from:


3. Purposes for Collection

We use personal information for the following business purposes (CCPA-defined):


4. Sale and Sharing of Personal Information

4.1. Niwers Does Not Sell Personal Information for Money

Niwers does not sell your personal information for monetary consideration.

4.2. Possible "Sharing" Under CPRA

The CPRA defines "sharing" broadly to include disclosures for cross-context behavioral advertising, even without monetary exchange.

Currently, Niwers does NOT engage in cross-context behavioral advertising sharing. If we begin in the future, we will:

4.3. Past 12 Months — No Sale or Sharing

In the past 12 months, Niwers has NOT sold or shared personal information of California residents within the meaning of CCPA/CPRA.

4.4. Service Provider Disclosures (Not Sales)

Disclosures to our service providers (Stripe, Cloudflare, Supabase, etc.) for business purposes are not considered sales or sharing under CCPA/CPRA, as they are bound by contract to use information only for our specified purposes.

4.5. Minors

We do not sell or share the personal information of consumers we know to be under 16 without affirmative authorization.


5. Sensitive Personal Information (SPI)

5.1. SPI We Collect

SPI Type Purpose
Government identifiers (SSN, ITIN, EIN, ID) INFORM Act compliance, KYC (Sellers only)
Account login credentials Authentication
Precise geolocation Optional features (with consent)
Mail/email/text contents Service provision (your messages)

5.2. Use of SPI

We use SPI only as necessary to:

5.3. Right to Limit SPI Use

California residents have the right to limit the use and disclosure of SPI to those purposes set out in CCPA/CPRA § 1798.121.

To exercise this right, contact privacy@niwers.com or use Settings → Privacy Rights → Limit SPI Use.


6. California Consumer Rights

As a California resident, you have the following rights:

6.1. Right to Know (Access)

You may request that we disclose:

You can request information for the past 12 months (or longer for certain Sellers' tax records).

6.2. Right to Delete

You may request deletion of personal information.

Exceptions (we may retain information to):

6.3. Right to Correct

You may request correction of inaccurate personal information.

6.4. Right to Opt-Out of Sale or Sharing

You may opt out of any future sale or sharing of personal information.

Currently, Niwers does not sell or share personal information. When/if we do:

6.5. Right to Limit SPI Use

See Section 5.3.

6.6. Right to Data Portability

You may request a copy of your personal information in a portable, machine-readable format (e.g., JSON or CSV).

6.7. Right to Non-Discrimination

We will not:

based on your exercise of CCPA rights.

6.8. Right to Limit Retention

We retain information only as long as reasonably necessary, as detailed in our Privacy Policy.


7. How to Exercise Your California Rights

7.1. Two Designated Methods

Method 1: In-App Privacy Portal

Method 2: Email

7.2. Verification

We will verify your identity by:

7.3. Authorized Agents

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

7.4. Response Times

We will:

7.5. No Fees

Verifying and responding to your requests is free, except in cases of manifestly unfounded or excessive requests.


8. Notice at Collection

Pursuant to California Civil Code § 1798.100(b):

At or before the point of collection, we provide notice of:

This Privacy Notice serves as our Notice at Collection.


9. Financial Incentive Programs

Niwers does not currently offer financial incentives or price/service differences in exchange for personal information.


10. Children Under 16

We do not knowingly:

For users 13–16, we obtain affirmative authorization before any sale or sharing (currently not applicable).


11. Annual CCPA Metrics

In compliance with CCPA's metrics disclosure requirement (for businesses processing 10M+ Californians' data), Niwers will publish annual privacy metrics if/when we meet the threshold.


12. Categories of Recipients (Past 12 Months)

We have disclosed personal information to the following categories of third parties for business purposes:


13. Updates to This Notice

We update this Notice as required by law and operations. Last Updated date reflects most recent revision. Material changes will be communicated.


14. Contact Us

Topic Contact
California Privacy Rights Officer privacy@niwers.com
Subject Line "California Privacy Rights Request"
Mail pending — company being formed
pending — company being formed
Attn: Privacy Officer

15. California Resident Verification

To exercise rights, you may need to confirm:


Version: 2026-05-v1.0 Effective Date: pending — company being formed