Privacy Policy

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Version: 1.0

Date of last update: 19 January 2024

The following applies to you only if you are a California resident.

Please note the following:

Users can visit the Sites without providing their Personal Information, but we may collect Personal Information, such as IP addresses, automatically with cookies or other tracking technologies;
We will add a link to this Privacy Notice on our home page, or at a minimum, on the first significant page after entering the Sites;
Our Privacy Policy link includes the word “Privacy” and can easily be found on the page specified above;
Users will be notified of any privacy policy changes on our Privacy Policy page;
Users are able to change their Personal Information by emailing us, by calling us, or updating their Personal Information in their online accounts with us;
Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. Because uniform standards for “Do Not Track” signals have not yet been adopted, we do not process or respond to such signals in users’ web browsers at this time; and
We allow the collection of users’ behavioral tracking by third parties. We do authorize the collection of Personal Information on the Sites by third parties.

Information We Collect From California Consumers

We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal Information does not include:

Publicly available information that is lawfully made from federal, state, or local government records;
Deidentified or aggregated consumer information;
Medical information or protected health information governed by California and federal health information privacy laws;
Clinical trial information subject to the Federal Policy for the Protection of Human Subjects (the Common Rule); or
Personal information regulated by the Fair Credit Reporting Act (FCRA).

Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers. Some of the categories may overlap with each other:

Category of Personal Information	Examples	Collected
A. Identifiers	A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number	YES
B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e))	All of the Identifiers listed above, plus: Signature, social security number, bank account number, credit card number, debit card number, or any other financial information (as through our third-party payment processor, as applicable)	YES
C. Legally Protected Characteristics	Age (40 years or older)	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	YES
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or similar network activity	Browsing history, search history, information regarding a consumer's interaction with a website, mobile application, or online advertisement	YES
G. Geolocation data	Physical location or movements	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
I. Employment information	Professional or employment-related information	NO
J. Education information, defined as non-public personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
K. Inferences drawn of other categories of Personal Information	A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	YES

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from our Users. For example, from information that you provide to us through our online forms, email, or other means
Indirectly from activity on our Sites. For example, from website usage details collected automatically

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to fulfill your product order;
To provide you with information, products or services that you request from us;
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you;
To carry out our obligations and enforce our rights arising from any contracts entered into; between you and us , including for billing and collections;
To improve our Sites and present the contents to you;
For testing, research, analysis and product/service development;
As necessary or appropriate to protect the rights, property or safety of us, our Users, or others
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your Personal Information or as otherwise set forth in the California Consumer Privacy Act (CCPA); or
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We may also use or disclose the Personal Information we collect for the following commercial purpose: to advance our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

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

Sharing Personal Information

We may disclose your Personal Information to a third party for a business and/or commercial purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories

Category C: Legally Protected Characteristics

Category D: Commercial information

Category F: Internet activity

Category G: Geolocation data

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a commercial purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories

Category D: Commercial information

Category F: Internet activity

We disclose your Personal Information for a business purpose to the following categories of third parties:

Our affiliates
Our service providers
Third parties to whom you authorize us to disclose your Personal Information in connection with products or services we provide to you

In the preceding twelve (12) months, we have not sold any Personal Information for monetary consideration. We do, however, disclose information for a commercial purpose by working with companies to deliver advertisements to you across the Internet. If you do not wish to have your Personal Information used for this purpose, please email [email protected].

Your Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides consumers who are California residents with specific rights regarding their Personal Information. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit an email request to the following email address: [email protected] and include the words “CALIFORNIA PRIVACY” in the subject line, and you must put the statement “Your California Privacy Rights” in the body of the request and state the name of our specific website with respect to which you are requesting the information as well as your name, street address, city, state, and zip code.

Right to Know About Personal Information Collected, Disclosed, or Sold

As a California consumer, you have a right to request what Personal Information we collect, use, disclose, and sell.

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request as described below, we will disclose to you:

The categories of Personal Information we collected about you
The categories of the sources for the Personal Information we collected about you
Our business or commercial purpose(s) for collecting or selling that Personal Information.
The categories of third parties with whom we shared that Personal Information.
The specific pieces of Personal information we collected about you

In addition, if we sold or disclosed your Personal Information for a business purpose, we will provide you with two separate lists disclosing:

Disclosures for a business purpose, identifying the Personal Information categories disclosed that each category of recipient obtained; and
Sales and/or disclosures for a commercial purpose, identifying the Personal Information categories that each category of each category of recipient obtained.

Right to Request Deletion of Personal Information

As a California consumer, you have the right to request that we delete any or all of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request to delete your Personal Information if retaining the Personal Information is necessary for us or our service providers to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
Debug products to identify and repair errors that impair existing intended functionality
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
Comply with a legal obligation
Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Right to Opt-Out of the Sale of Personal Information

As a California consumer, you have the right to opt-out of the sale of your Personal Information. If you would like to opt-out of the sale of your Personal Information, please email [email protected] including Opt-Out of the Sale in the subject line.

Right to Non-Discrimination if You Exercise any of Your Rights

As a California consumer, you have the right not to be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your California rights, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights to Know and to Delete

To exercise your rights to know and/or to delete described above, please submit a verifiable consumer request to us by either:

Calling us at +1 (424) 842-2442
Emailing us at [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized representative including
full name
date of birth
address
email address
whether you are a California consumer pursuant to CCPA
(if you would like to know the specific pieces of personal information that we have collected about you, or to delete your personal information) identification that clearly shows your name, date of birth and address (for example, passport or other photo identification)
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with your Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We will confirm receipt of your verifiable consumer request within ten (10) days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding our receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Grievances and Complaints

Under California Civil Code Section 1789.3, residents of California who use this Website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at [email protected].

Contact for More Information

If you have any questions or concerns about our Privacy Policy or this Notice regarding your privacy or Personal Information, please contact us at [email protected].