This Notice is for residents of U.S. states with comprehensive privacy laws — including California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah, Oregon, Montana, Texas and others. It supplements our Privacy Policy and, for those residents, controls where it conflicts. noobtopro (noobto.pro) is operated by noobtopro, a sole proprietorship (Einzelunternehmen) under German law.
We are a small, single-person, pre-revenue business. We do not meet the size or revenue thresholds that make most of these laws apply to us (for example, California's CCPA applies only above roughly $26.6 million in revenue, 100,000 California consumers, or 50% of revenue from selling data; other states use 100,000-resident or 25,000-plus-data-sale thresholds), and where a law has no threshold we fall within its small-business exemption. We nonetheless make the good-faith disclosures below and honor these rights voluntarily, even where the law does not strictly require it of an operator of our size.
1. Categories of personal information we collect
We collect the following categories of personal information, from you, from your device, and from our service providers, and use them for the purposes described:
- Identifiers — such as your name, email, account ID, IP address, and device/cookie identifiers. Used to provide and secure the Service and manage your account.
- Commercial information — such as your subscription tier, payment status, and history. Used for billing and to deliver Pro features.
- Internet or network activity — such as pages viewed, usage, and referrers. Used for analytics and to improve the Service.
- Geolocation (approximate) — coarse location derived from your IP address. Used for security and analytics.
- User content — the answers you type and photos of your work that you upload for AI grading.
- Sensitive personal information — your submissions may incidentally reveal sensitive information (for example, health, beliefs, message contents, or precise geolocation contained in a photo). We use sensitive personal information only to provide and secure the grading service and for other legally permitted purposes — not to infer characteristics about you and not for advertising.
- Inferences — performance and usage inferences derived from the above. Used to improve the Service.
For how long we keep this information, see the retention section of our Privacy Policy.
2. We do not sell or share your personal information
We do not sell or share your personal information, including sensitivepersonal information, and we will not do so without your consent. We do not sell personal information for money, and we do not share it for cross-context behavioral advertising or targeted advertising. (This consent commitment also satisfies the sensitive-data consent rule that applies to us under the Texas Data Privacy and Security Act, § 541.107, even though that Act's broader obligations exempt a small business of our size.)
The service providers we use — such as our hosting provider, analytics, and the AI model provider that grades uploaded work (Groq, in the United States, on Google Cloud / GCP) — process data only on our instructions to operate the Service. That is a service-provider disclosure, not a sale or a share. Before any photo is sent to the AI provider, we strip EXIF metadata server-side, which removes any precise geolocation embedded in the image.
3. Your rights
Depending on your state of residence, you may have the right to:
- Know and access the personal information we have collected about you.
- Delete personal information we have collected from you.
- Correct inaccurate personal information.
- Opt outof any "sale" or "sharing" of your personal information and of targeted advertising and certain profiling. We do none of these, so there is nothing to opt out of; we still honor opt-out signals as a courtesy (see Section 5).
- Limit the use of your sensitive personal information — we already use it only for permitted purposes, so this right is not separately actionable here (see Section 4).
- Non-discrimination for exercising your rights (see Section 6).
- In Virginia, Colorado, Connecticut, Oregon, Montana, Texas and certain other states, the right to appeal a denial of your request. To appeal, email [email protected]with "Appeal" in the subject line. If we deny your appeal, you may contact your state Attorney General.
4. Right to limit the use of sensitive personal information
Some submissions could reveal sensitive personal information — such as health, beliefs, racial or ethnic origin, message contents, or precise geolocation contained in a photo. We use sensitive personal information only to provide and secure the grading service and for other legally permitted purposes — not to infer characteristics about you and not for advertising.
Because we already confine this use to permitted purposes (and strip EXIF geolocation from photos before grading), the "limit" right does not give you anything separate to exercise. There is no additional secondary use to restrict.
5. Opt-out preference signals (Global Privacy Control)
We do notsell or share your personal information for cross-context behavioral advertising, so there is no "Do Not Sell or Share My Personal Information" activity to switch off. Our hosting/analytics setup is consistent with this: our hosting provider acts only as a service provider, and our site analytics are not used for ad targeting.
Even so, we honor the Global Privacy Control (GPC)as a courtesy. If your browser sends a GPC signal, we treat it as a valid opt-out for that browser or device — and for your account when you are logged in — and, consistent with the California rules in effect from 1 January 2026 (§ 7025), we indicate that your opt-out request was honored. You do not need to be a Pro subscriber to exercise this, and we will not ask you to opt back in for at least 12 months.
6. How to exercise your rights
To make a request, email [email protected]. Because we operate online and interact with you primarily through your account, we provide this online method rather than a toll-free number, as permitted by California law. We verify your identity (typically via your account email). Authorized agents may submit requests on your behalf with your written permission, or via GPC for opt-outs. We confirm receipt and respond within the timeframes required by applicable law (generally up to 45 days, extendable as the law allows); most requests are free.
7. Non-discrimination
We will not discriminate or retaliate against you for exercising your privacy rights. Our free and Pro tiers differ by the value of the services they provide, not by your exercise of privacy rights, and both tiers receive the same privacy rights and opt-outs.
8. Contact
Questions about this Notice, or to exercise your rights: [email protected] — noobtopro, Cologne (Köln), Germany. California residents may also contact the California Privacy Protection Agency (CPPA) or the California Attorney General.