California Privacy Statement

 

In accordance with AB 375 (California Consumer Protection Act of 2018), you have the right to:

  • Know what personal information is being collected;
  • Know whether your personal information has been sold and to whom—
    including the categories and specific pieces of personal information the
    business has collected;
  • Say no to the sale of your personal information (1798.120(a);
  • Access your personal information;
  • Receive equal service and price even if you exercise your privacy rights.

Your Rights

Deletion Requests Rights

Pursuant to 1798.105(a) you have the right to request that we delete any personal information that we have collected about you.

Pursuant to [1798.105 (d)(1)-(9)] we may deny your deletion request
if retaining the information is necessary for us, or our service
providers to:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive,
    fraudulent, or illegal activity, or prosecute those responsible for such
    activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to
    exercise their free speech rights, or exercise another right provided
    for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Access to Specific Information and Data Portability Rights

Pursuant to 1798.110(a)(1)-(5) you have the right to request that a
business that collects personal information about you disclose to you
the following:

  1. The categories of personal information it has collected about you.
  2. The categories of sources from which the personal information is collected.
  3. The business or commercial purpose for collecting or selling personal information.
  4. The categories of third parties with whom your personal information is shared.
  5. The specific pieces of personal information that have been collected about you.

Pursuant to 1798.115(a)(1)-(3) you have the right to request that a
business that sells your personal information, or that discloses it for a
business purpose, disclose to you the following:

  1. The categories of personal information that the business collected about you.
  2. The categories of personal information that the business sold about
    you and the categories of third parties to whom your personal
    information was sold, by category or categories of personal information
    for each third party to whom your personal information was sold.
  3. The categories of personal information that the we disclosed about you for a business purpose

Pursuant to 1798.120 California residents also have the right, at any
time, to direct a business that sells personal information about the
consumer, to third parties, not to sell the consumer’s personal
information. This right is referred to as the right to opt out. Please
go to our “Do not sell my personal information” page to opt-out of having your personal information sold.

Non-Discrimination Rights

Pursuant to 1798.125(a)(1)(A)-(D) a business shall not discriminate
against you because you exercised any of your rights under this title,
including, but not limited to, by:

  1. Denying you of goods or services.
  2. Charging different prices or rates for goods or services, including
    through the use of discounts or other benefits or imposing penalties.
  3. Providing a different level or quality of goods or services to you, if you exercise your rights under this title.
  4. Suggesting that you will receive a different price or rate for goods
    or services or a different level or quality of goods or services.

Information We Collect

We collect 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 or device
(“personal information”). In particular, we have collected the following
categories of personal information from consumers within the last
twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier,
online identifier, Internet Protocol address, email address, account
name, Social Security number, driver’s license number, passport number,
or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics
or description, address, telephone number, passport number, driver’s
license or state identification card number, insurance policy number,
education, employment, employment history, bank account number, credit
card number, debit card number, or any other financial information,
medical information, or health insurance information. Some personal
information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition,
physical or mental disability, sex (including gender, gender identity,
gender expression, pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming histories or
tendencies.

NO

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 other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act)

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 from other personal information.

Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.

YES

 

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance
      Portability and Accountability Act of 1996 (HIPAA) and the California
      Confidentiality of Medical Information Act (CMIA) or clinical trial
      data;
    • personal information covered by certain sector-specific privacy
      laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-
      Bliley Act (GLBA) or California Financial Information Privacy Act
      (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly and indirectly from activity on our website(s). For
    example, from consumers submitting forms on our websites or 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 provide you with information, products or services that you request from us.
  • To provide you with email alerts, and/or SMS messages that may
    interest you—providing that you opted in to receive those messages while
    using our website(s).
  • To improve our website and present its contents to you.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients, 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 CCPA.
  • 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 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.

Disclosing/Sharing Personal Information

We may share and/or sell information that we collect about you in
many ways and for numerous different purposes—for which we may be
compensated—including the following.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category I: Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • With our vendors that assist us with delivery of email and/or SMS messaging
  • With one or more vendors who provide independent verification of consent, including verification of consent under TCPA;
  • Third parties to whom you or your agents authorize us to disclose
    your personal information in connection with products or services we
    provide to you;
  • Third party vendors that assist us in storing and/or processing of your data;
  • Third party vendors that assist us in identifying site issues, observing user behavior, and tracking page performance.

In the preceding twelve (12) months, we have sold the following categories of consumers’ personal information:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category I: Professional or employment-related information.

We have sold consumers’ personal information for a business purpose to the following categories of third parties:

  • Our affiliates and/or other;
  • Third parties to whom you or your agents authorize us to disclose
    your personal information in connection with products or services we
    provide to you.

Exercising Access, Data Portability, and Deletion Rights

Contact Information

If you have any questions or comments about this notice, our Privacy
Statement, the ways in which we collect and use your personal
information, your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to
contact us. 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 also make a verifiable consumer request on behalf of your minor
child. You can submit a verified request by either:

Response Timing and Format

After receiving a verified request we will deliver the information to
you within 45 days. In certain instances where it is reasonably
necessary, it could take up to 90 days. In those instances you will be
notified within the first 45 days of our intent to use the 45-day
extension as set forth in 1798.130(a)(2)

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 an
    authorized representative.
  • 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 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.

  

In accordance with AB 375 (California Consumer Protection
Act of 2018), you have the right to:

  • Know
    what personal information is being collected;
  • Know
    whether your personal information has been sold and to whom—
    including the categories and specific pieces of personal information the
    business has collected;
  • Say
    no to the sale of your personal information (1798.120(a);
  • Access
    your personal information;
  • Receive
    equal service and price even if you exercise your privacy rights.

Your Rights

Deletion Requests Rights

Pursuant to 1798.105(a) you have the right to request that
we delete any personal information that we have collected about you.

Pursuant to [1798.105 (d)(1)-(9)] we may deny your deletion
request
if retaining the information is necessary for us, or our service
providers to:

  1. 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.
  2. Detect
    security incidents, protect against malicious, deceptive,
    fraudulent, or illegal activity, or prosecute those responsible for such
    activities.
  3. Debug
    products to identify and repair errors that impair existing intended
    functionality.
  4. Exercise
    free speech, ensure the right of another consumer to
    exercise their free speech rights, or exercise another right provided
    for by law.
  5. Comply
    with the California Electronic Communications Privacy Act (Cal. Penal Code
    § seq.).
  6. 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.
  7. Enable
    solely internal uses that are reasonably aligned with consumer
    expectations based on your relationship with us.
  8. Comply
    with a legal obligation.
  9. Make
    other internal and lawful uses of that information that are compatible
    with the context in which you provided it.

Access to Specific Information and Data Portability Rights

Pursuant to 1798.110(a)(1)-(5) you have the right to request
that a
business that collects personal information about you disclose to you
the following:

  1. The
    categories of personal information it has collected about you.
  2. The
    categories of sources from which the personal information is collected.
  3. The
    business or commercial purpose for collecting or selling personal
    information.
  4. The
    categories of third parties with whom your personal information is shared.
  5. The
    specific pieces of personal information that have been collected about
    you.

Pursuant to 1798.115(a)(1)-(3) you have the right to request
that a
business that sells your personal information, or that discloses it for a
business purpose, disclose to you the following:

  1. The
    categories of personal information that the business collected about you.
  2. The
    categories of personal information that the business sold about
    you and the categories of third parties to whom your personal
    information was sold, by category or categories of personal information
    for each third party to whom your personal information was sold.
  3. The
    categories of personal information that the we disclosed about you for a
    business purpose

Pursuant to 1798.120 California residents also have the
right, at any
time, to direct a business that sells personal information about the
consumer, to third parties, not to sell the consumer’s personal
information. This right is referred to as the right to opt out. Please
go to our “Do not sell my personal
information” page to opt-out of having your personal information sold.

Non-Discrimination Rights

Pursuant to 1798.125(a)(1)(A)-(D) a business shall not
discriminate
against you because you exercised any of your rights under this title,
including, but not limited to, by:

  1. Denying
    you of goods or services.
  2. Charging
    different prices or rates for goods or services, including
    through the use of discounts or other benefits or imposing penalties.
  3. Providing
    a different level or quality of goods or services to you, if you exercise
    your rights under this title.
  4. Suggesting
    that you will receive a different price or rate for goods
    or services or a different level or quality of goods or services.

Information We Collect

We collect 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 or device
(“personal information”). In particular, we have collected the following
categories of personal information from consumers within the last
twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal
identifier,
online identifier, Internet Protocol address, email address, account
name, Social Security number, driver’s license number, passport number,
or other similar identifiers.

YES

B. Personal information categories listed in the
California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical
characteristics
or description, address, telephone number, passport number, driver’s
license or state identification card number, insurance policy number,
education, employment, employment history, bank account number, credit
card number, debit card number, or any other financial information,
medical information, or health insurance information. Some personal
information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under
California or federal law.

Age (40 years or older), race, color, ancestry, national
origin,
citizenship, religion or creed, marital status, medical condition,
physical or mental disability, sex (including gender, gender identity,
gender expression, pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services
purchased,
obtained, or considered, or other purchasing or consuming histories or
tendencies.

NO

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 other similar network activity.

Browsing history, search history, information on a
consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar
information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family
Educational Rights and Privacy Act)

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 from other personal information.

Profile reflecting a person’s preferences,
characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.

YES

 

Personal information does not include:

  • Publicly
    available information from government records.
  • De-identified
    or aggregated consumer information.
  • Information
    excluded from the CCPA’s scope, like:
    • health
      or medical information covered by the Health Insurance
      Portability and Accountability Act of 1996 (HIPAA) and the California
      Confidentiality of Medical Information Act (CMIA) or clinical trial
      data;
    • personal
      information covered by certain sector-specific privacy
      laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-
      Bliley Act (GLBA) or California Financial Information Privacy Act
      (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed
above from the following categories of sources:

  • Directly
    and indirectly from activity on our website(s). For
    example, from consumers submitting forms on our websites or 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
    provide you with information, products or services that you request from
    us.
  • To
    provide you with email alerts, and/or SMS messages that may
    interest you—providing that you opted in to receive those messages while
    using our website(s).
  • To
    improve our website and present its contents to you.
  • As
    necessary or appropriate to protect the rights, property or safety of us,
    our clients, 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 CCPA.
  • 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 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.

Disclosing/Sharing Personal Information

We may share and/or sell information that we collect about
you in
many ways and for numerous different purposes—for which we may be
compensated—including the following.

In the preceding twelve (12) months, we have disclosed the
following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information
categories.

Category C: Protected classification characteristics under
California or federal law.

Category I: Professional or employment-related information.

We disclose your personal information for a business purpose
to the following categories of third parties:

  • With
    our vendors that assist us with delivery of email and/or SMS messaging
  • With
    one or more vendors who provide independent verification of consent,
    including verification of consent under TCPA;
  • Third
    parties to whom you or your agents authorize us to disclose
    your personal information in connection with products or services we
    provide to you;
  • Third
    party vendors that assist us in storing and/or processing of your data;
  • Third
    party vendors that assist us in identifying site issues, observing user
    behavior, and tracking page performance.

In the preceding twelve (12) months, we have sold the
following categories of consumers’ personal information:

Category A: Identifiers.

Category B: California Customer Records personal information
categories.

Category C: Protected classification characteristics under
California or federal law.

Category I: Professional or employment-related information.

We have sold consumers’ personal information for a business
purpose to the following categories of third parties:

  • Our
    affiliates and/or other;
  • Third
    parties to whom you or your agents authorize us to disclose
    your personal information in connection with products or services we
    provide to you.

Exercising Access, Data Portability, and Deletion Rights

Contact Information

If you have any questions or comments about this notice, our
Privacy
Statement, the ways in which we collect and use your personal
information, your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to
contact us. 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 also make a verifiable consumer request on behalf of your minor
child. You can submit a verified request by either:

Response Timing and Format

After receiving a verified request we will deliver the
information to
you within 45 days. In certain instances where it is reasonably
necessary, it could take up to 90 days. In those instances you will be
notified within the first 45 days of our intent to use the 45-day
extension as set forth in 1798.130(a)(2)

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 an
    authorized representative.
  • 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
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.