California CCPA and CPRA Notice

Effective Date: January 1, 2023

This Privacy Notice for California Residents supplements the information contained in our primary privacy policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended and effective January 1, 2023, the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

The following chart identifies the Personal Information categories we collect, the source of the collection, the business purpose for which we collected the information, and with whom we shared or sold the information. In all cases, we treat the information, including Personal Information, as an asset of the company and it may be sold with the sale of all or part of the company.

 

CATEGORY COLLECTED: Identifiers
Exemplar
  • First and Last Name.
  • Postal Address.
  • Unique Personal Identifier.
  • Online Identifier.
  • Internet Protocol Address.
  • Email Address.
Source
  • Directly and indirectly from consumers.
  • Third-party data providers.
  • Ad exchanges.
  • Supply-side platforms.
  • Advertising Clients.
Business Purpose
  • Personalize Website; Respond to Consumer request; targeted advertising through Google.
  • Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Share or Sale
  • Service providers.
  • Contractors.
  • Third-party vendors.
  • Advertising Clients.
  • Affiliated companies.
CATEGORY COLLECTED: Personal Information and Sensitive Personal Information
Exemplar
  • First and Last Name.
  • Address.
  • Telephone Number.
  • Credit Card or Debit Card, when purchases are made.
Source
  • Directly from Consumers.
Business Purpose
  • To process consumer requests.
  • Purchases.
  • Transactions.
  • Payments.
  • Prevent fraud.
Share or Sale
  • Service providers.
  • Contractors.
  • Third-party vendors, including processors and merchant banks.
  • Advertising Clients.
  • Affiliated companies.
CATEGORY COLLECTED: Commercial Information
Exemplar
  • Records of products or services purchased, obtained, or considered.
  • History or tendencies toward products and services or response to advertising.
Source
  • Directly and indirectly from consumers.
  • Third-party data and service providers.
  • Ad exchanges.
  • Supply-side platforms.
  • Advertising Clients.
Business Purpose
  • Personalize Website; Respond to Consumer request; targeted advertising through Google.
  • Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To process consumer requests, purchases, transactions, payments, and prevent fraud.
Share or Sale
  • Service providers.
  • Contractors.
  • Third-party vendors.
  • Advertising Clients.
  • Affiliated companies.
  • Advertising Clients.
CATEGORY COLLECTED: Internet or other Similar Network Activity
Exemplar
  • Browsing history.
  • Search history.
  • Information on a consumer’s interaction with a website.
  • Application.
  • Advertisement.
Source
  • Directly and indirectly from consumers, third-party data providers.
  • Ad exchanges.
  • Tech and analytics third-party platforms.
  • Advertising Clients.
Business Purpose
  • Personalize Website; Respond to Consumer request; targeted advertising through Google. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Share or Sale
  • Service providers.
  • Contractors.
  • Third-party vendors.
  • Advertising Clients.
  • Affiliated companies.
CATEGORY COLLECTED: Geolocation Data
Exemplar
  • Through collection of your IP, we collect your general location, upon requesting services or products, we collect your physical address.
Source
  • Directly and indirectly from consumers.
  • Third-party data providers.
  • Ad exchanges.
  • Tech and analytics third-party platforms.
  • Advertising Clients.
Business Purpose
  • Personalize Website; Respond to Consumer request; targeted advertising through Google.
  • Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Share or Sale
  • Service providers.
  • Contractors.
  • Third-party vendors.
  • Advertising Clients.
  • Affiliated companies.
CATEGORY COLLECTED: Inferences Drawn from other Personal Information
Exemplar
  • From information we collect as set forth herein and information provided by third-parties, we are able to create a general profile of your preferences, characteristics, and personal preferences to determine what ads or products or services you may be interested in receiving.
Source
  • Directly and indirectly from consumers.
  • Third-party data providers.
  • Ad exchanges.
  • Tech and analytics third-party platforms.
  • Advertising Clients.
Business Purpose
  • Personalize Website; Respond to Consumer request; targeted advertising through Google.
  • Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
Share or Sale
  • Service providers.
  • Contractors.
  • Third-party vendors.
  • Advertising Clients.
  • Affiliated companies.
CATEGORY COLLECTED: Highly Sensitive Information
Exemplar
  • Name, address, credit or debit card or financial information for purposes of a payment transaction involving our products or services.
Source
  • Consumers.
Business Purpose
  • To respond to request of consumer for purchase of products or services.
Share or Sale
  • We do not share or sell Highly Sensitive Information with third-parties unless they are necessary to assist us in performing the services or provide the products or otherwise as requested by you. We do share with merchant bank and processors to process your payments and refunds.
  • We do not sell Highly Sensitive Information to any other third-parties.

 

Supplemental Information Automatically Collected. When you visit or interact with the Websites, we may use a variety of technologies such as pixels, cookies, clear GIFs, pixel tags, log files, JavaScript, web beacons, and other technologies or third-party services which automatically or passively collect Personal Information about you and your interactions with Websites. We may also automatically collect the following information about you:

  • Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third-parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
  • Cookies. Cookies are small text files placed in device browsers to store your preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. We may use session, persistent, or permanent cookies. These can be identified and blocked through your privacy settings in your browser.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.
  • Analytics. We may also use Google Analytics and other service providers to collect and process analytics information on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and processing of data generated by your use of the Site by going to https://tools.google.com/dlpage/gaoptout.
  • Computer or Device Information. We automatically collect your Internet Protocol (“IP”) address or other unique identifier or information from the computer, mobile device, tablet you use to access the Websites, including but not limited to your browser type, device type, system type, and the domain name from which you accessed the Websites.
  • Usage Information. We may collect information about your use of the Websites, including the date and time you visit the Websites, the content, areas or pages of the Websites that you visit, the website or app from which you navigated to the Websites, the page or app you visit after leaving the Websites, the amount of time you spend viewing or using the Websites, the number of times you return to the Websites, as well as other click-stream or usage data, and whether you open, forward, or click-through an email or display ad to the Websites. For legal compliance purposes, we may also capture or record your interactions with the Website to confirm that your information was submitted to us.
  • Third-party Providers. We use third-party service providers to support our Websites. Some of these service providers may use technology such as pixels, cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information on your computer for later access and usage.
  • Use of Third-Party Analytics and Technologies. We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (a) Remarketing with Google Analytics; (b) Google Display Network Impression Reporting; (c) Google controlled Campaign Manager integration; and (d) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/.
  • Information from Third-Party Websites or Services. If you link to us through a third-party website, email, or service, such as a social media account, we may automatically receive certain information about you based on your registration and privacy settings on those third-party websites or services. This may include, but may not be limited to, your name, username, demographic information, updated address or contact information, location, interests, and online activity.

California Privacy Choices. If you are a resident of California, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

  • RIGHT TO KNOW. The right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we collected about you, including:
    • The categories of Personal Information collected;
    • The categories of sources of the Personal Information;
    • The purposes for which we collected the Personal Information;
    • The categories of Personal Information disclosed to third-parties, and the categories of recipients to whom we disclosed the Personal Information;
    • The categories of Personal Information shared for cross-context behavioral or targeted advertising purposes, and the categories of recipients to whom we disclosed the Personal Information for those purposes; and
    • The categories of Personal Information sold, and the categories of third-parties to whom we sold the Personal Information.
  • RIGHT TO CORRECT. The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and the purposes of processing the Personal Information.
  • RIGHT TO DELETE. The right to have us delete the Personal Information we maintain about you, subject to additional exemptions.
  • RIGHT TO CONTROL SENSITIVE PERSONAL INFORMATION. The right to exercise control over our collection and processing of Sensitive Personal Information.
  • RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION. The right to direct us not to “sell” your Personal Information to third-parties for monetary or other valuable consideration. You also have the right to direct us not to use your Personal Information for automated decision-making or profiling for certain purposes. The exception to this Right is our ability to disclose, share, and sell your Personal Information to the third-parties who provide to you the services and products you requested at registration.
  • RIGHT TO PORTABILITY. The right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • RIGHT AGAINST DISCRIMINATION OR RETALIATION. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.
  • HOW TO EXERCISE YOUR RIGHTS. Submit your request to exercise one of the privacy rights identified above, as follows:

Verification Required. Before processing your request, we will need to verify your identity and confirm you are a resident of a California. In order to verify your identity, we will generally either require the successful authentication of your email, or the matching of sufficient information you provide us to the information we maintain about you in our system. As a result, we require requests to include first and last name, phone number, email, street address, city, state, and zip code. We may at times need to request additional Personal Information from you, taking into consideration our relationship with you, and the sensitivity of your request.

We will process requests to opt-out of sales within 10 business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within 45 days, subject to any applicable exceptions and extensions permitted by law.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of California, or where we are unable to verify your identity.

Submitting Authorized Agent Requests. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either: (a) a valid power of attorney; or (b) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you or the California Resident to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Opt-Out Preference Signal (Global Privacy Control).

You may use an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request.

If you would like us to make the connection between your browser and your account within our database, please email us or submit the requested form through our website portal below.

Retention Notice. We retain Personal Information as long as is necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation, or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. As such, we retain Personal Information for as long as you continue to use our Websites and/or services for the purposes explained in our Privacy Notice. When you discontinue the use of our Websites or services, we will retain your Personal Information for as long as necessary to comply with our legal obligations, to resolve disputes, and defend claims, as well as, for any additional purpose based on the choices you have made, such as to receive marketing communications. In particular, we will retain Personal Information provided, including complaints, claims, and any other Personal Information provided during the duration of your agreement with us for the services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims.

Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or de-identification is possible.