Effective: May 21, 2024

This Privacy Policy (“Privacy Policy” or “Policy”) explains how Twaydabae, Inc., a California corporation (Company”, “We”, “Us” or “Our”) may gather, collect, record, hold, distribute, share, disclose or otherwise use any information or data about any user (“User” or “You” or “Your”) of the Company’s website at twaydabae.com (“Company Website”) or through any other site, program, activity, technology platform, technology application, or service offered by Company (the Company Website and these other programs, activities, platform, applications and services are collectively referred to as “Company Program[s]”). Any capitalized terms not defined in this Privacy Policy shall have the meanings set forth in the Terms and Conditions (the “T&C”) which govern the Company Website and the other Company Programs.

BY CONTINUING TO USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM OFFERED BY THE COMPANY, YOU HEREBY AGREE TO BE BOUND BY ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AS IT IS PRESENTED TO YOU AS OF THE DATE OF YOUR FIRST USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. NO CHANGES (ADDITIONS OR DELETIONS) BY YOU TO THIS PRIVACY POLICY WILL BE ACCEPTED BY THE COMPANY. IF YOU DO NOT AGREE TO ALL THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, OR YOU DO NOT WISH YOUR PERSONAL INFORMATION TO BE USED PURSUANT TO THIS PRIVACY POLICY, THEN YOU SHOULD NOT USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM AND YOU SHOULD NOT PROVIDE ANY OF YOUR PERSONAL INFORMATION TO THE COMPANY.

THIS IS A BINDING CONTRACT BETWEEN YOU AND THE COMPANY AND YOU SHOULD DOWNLOAD AND PRINT THIS PRIVACY POLICY FOR YOUR RECORDS.

1.    INFORMATION WE COLLECT.

During a User’s access or use of the Company Website or any other Company Program, the Company may, either directly or by using its service providers, gather, collect, record, hold, distribute, share, disclose or otherwise use personal information or data about You which You provide to Us, as described in Section 1.1 below, or which is automatically collected, as described in Section 1.2 below (hereinafter collectively referred to as the User’s “Personal Information”).

1.1    INFORMATION YOU PROVIDE TO US.

We collect Personal Information that You may provide directly to the Company while using the Company Website, including data a Traveler may provide to the Company related to Trip, or data a Host may provide the Company related to a Trip, or data an Organizer may provide to the Company related to a Trip. Without limiting the generality of the foregoing, You may provide the Company with Your Personal Information in the following instances:

• A Traveler may provide Personal Information while Booking a Trip,  or otherwise by requesting, seeking, purchasing or procuring any other of Our goods or services (collectively referred to as “goods/services”);
• A Host may provide Personal Information while using the Company Website to host a Trip, as such term is defined in the T&C;
• An Operator may provide Personal Information while using the Company Website related to a Trip, as such term is defined in the T&C;
• A User may provide other Personal Information while using the Company Website or any other Company Program, or via telephone;
• You may provide Personal information to create an account with the Company;
• A User may provide other Personal Information while requesting any other information about, or requesting customer support regarding, any Trip or any other goods/services of the Company;
• A User may provide other Personal Information while requesting any information from or about the Company, such as a newsletter, e-alert, or any other information about the Company’s goods/services, events or business partners (collectively referred to as “Newsletters/Alerts”);
• A User may provide other Personal Information while completing any other information through any Company Program;
• A User may provide other Personal Information while communicating with any other representative of our Company;
• A User may provide other Personal Information while using any third party social media sites;
• A User may provide other Personal Information while participating in any contest, promotion or sweepstake sponsored or promoted by the Company (collectively referred to as “Contests/Sweepstakes”;
• Choose to participate in any of the Company’s customer surveys, customer forums or other information gathering activities or events with Our Customers (collectively referred to as “Customer Surveys”);
• A User may provide other Personal Information while applying for a job with the Company; or
• A User may provide other Personal Information while otherwise communicating with the Company in any other way.

In these instances, the following are the types of Personal Information You may provide to the Company and which We may collect:

• Your name;
• Mailing address and/or billing address;
• E-mail address;
• Phone (or mobile) number;
• Date of birth or age;
• Gender;
• Nationality and Passport Information;
• Emergency contact information;
• Food allergies, medical-related ailments or injuries, or food preferences;
• Credit or debit card number and other information about the same (if You make a payment either directly to Us or by using a third party payment provider that handles payments and will receive Your payment card information);
• Gift card information or related gift information;
• Information You provide when You purchase any of Our goods/services, including product or service parameters or preferences You provided when making a purchase;
• Photos, videos, audio or similar content uploaded by You;
• Information You provide or otherwise involved in the return or exchange of a product, such as information about the transaction, product details, purchase price, and the date and location/media of the transaction.
• If You choose to subscribe, receive, or otherwise participate in any Newsletters/Alerts (as defined above in this Section 1.1), We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such as additional demographic information or other information You may provide as part of Your participation in any such Newsletter/Alerts;
• If You choose to participate in any Contest/Sweepstakes (as defined above in this Section 1.1), We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such as additional information necessary to determine if You are eligible to participate in Contest/Sweepstakes or to otherwise facilitate the Contest/Sweepstakes; and
• If You choose to participate in any Customer Surveys (as defined above in this Section 1.1), We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such Your purchase history, habits, and/or preferences or other information You may provide as part of Your response or feedback to the Customer Surveys.

1.2    INFORMATION AUTOMATICALLY COLLECTED.

When a User accesses or otherwise uses the Company Website or any other Company Program, We automatically collect certain Personal Information about You, including:

• Device Information: We (or our Service providers/Contractors as defined below) may collect information about the computer, tablet, phone or other device You use to access any of the Company Programs, including the Internet Protocol address, hardware models, operating system and version, mobile network information and other unique device identifiers.
• Cookies and other Web-based Tracking Technologies: We (or Our Service Providers/Contractors as defined in Section 3 herein) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by Your web browser on Your computer or mobile device (hard drive) that helps Us to improve the way We deliver Our Company Website or other Company Programs to You, helps Us improve Your overall experience using Our Company Website or other Company Programs, and/or helps Us analyze the areas and features of Our Company Programs that are most popular or to detect fraud. Web beacons are electronic images that may be used in Our Company Programs or emails and help deliver cookies, count visits, and understand usage. Like many other websites, cookies and these other web-based tracking technologies may be used by Us (or Our Service Providers/Contractors) during Your visit to the Company Website or other Company Program in order to improve Your individual experience as a User of the Company Website or other Company Program or to generally improve or enhance the overall functionality of the Company Website or other Company Program. While most websites automatically accept cookies for these purposes, You may be able to instruct Your browser to stop accepting cookies or prompt You before accepting a cookie from the sites You visit, including the Company Website. SEE SECTION 8 OF THIS PRIVACY POLICY WHICH PROVIDES FURTHER NOTICE ABOUT HOW THESE COOKIES ARE USED AND PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES.
• Geo-location Data: Subject to any of Your device permissions, We (or our Service Providers/Contractors as defined below) may be able to collect information about the precise location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”).
• Social Media Information:  If any social media activities, offerings, or features, such as the Facebook “Like” button or similar social media interactive programs (collectively, “Social Media Activities”), are made available to You through any of the Company’s Programs, and in addition to the collection of other Personal Information noted above, the following may apply:
  • We may obtain and collect certain information from Your social media account consistent with Your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, and friends list. We may also allow You to enter into contests to provide photos, such as of products/services You have purchased, which You may share with Your connections on social media for votes, shared offers, or other promotions. 
  • A third party that is hosting the Social Media Activities may also collect Your Internet Protocol address, which page You are visiting on Our Company Program, Your Geo-location Data, and other Personal Information about You, and may also set a cookie to enable the feature to function properly.
  • These Social Media Activities may be hosted by a third party or hosted directly on Our Company Program. Thus, Your interactions with these Social Media Activities may be governed by the privacy policies of the third party that is hosting the Social Media Activities (see Section 8 regarding Third Party Sites).

1.3    ADDITIONAL SOURCES FROM WHOM OR WHERE WE MAY RECEIVE OR COLLECT INFORMATION ABOUT YOU.

In addition to the Personal Information provided by You as described in Section 1.1 and in addition to the collection of Personal Information as described in Section 1.2, the following are additional ways We may collect Personal Information about You or additional sources from which We may receive Personal Information about You:

• From Our Service Providers/Contractors: From Our Service Providers/Contractors, as such term is defined in Section 3 herein, including without limitation from Our Data Analytics Providers or from Our Third Party Application Providers, as such terms are defined in Section 3 herein.
• From Our Advertising Network: From Our Advertising Network, as such term is defined in Section 3 herein.
• From Hosts or Operators of Trips:  From a Host of a Trip or an Operators of a Trip, as such terms are defined in the T&C  (as defined in Section 1.1 above).
• Security:  Our offices and/or facilities may use security cameras to monitor the activity of Our staff or any other parties. The information We collect includes audio-video recordings. The camera images are not monitored in real time. The recordings are viewed only if there is a reason to believe that there has been a breach of security. We use this information to detect security incidents and to report to law enforcement agencies.
• Employees: We may collect Personal Information in the context of Your role as an applicant to, an employee of, director of, or officer of, Our business. The Personal Information We collect in these cases may include name, Social Security number, address, date of birth, gender, race, ethnicity, bank account and routing number, tax filing status, emergency contact information, telephone number, family member names, educational background, criminal background, employment history, medical provider information, dependent name(s), date of birth, gender and address, medical insurance provider, compensation and benefits data, workplace, and title. We only use this information for purposes of evaluating qualifications related to Your job application or Your job duties; evaluating Your performance; or for providing compensation, benefits, and services in the context of the employment relationship. The Personal Information described in this paragraph is the “Employee Data”.
• Individuals Representing Businesses: We may collect Personal Information in the context of Your role as a representative of a business. The Personal Information We collect in these cases may include name, address, email address, telephone, date of birth, gender, Social Security number, and personal financial information. We use this information for communicating with You in Your role as a representative of a business or if You are an owner of a business to evaluate Your creditworthiness. The Personal Information described in this paragraph is the “Biz Rep Data”.
• Other Sources From Which We Collect Personal Information: We may collect Personal Information about You from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to Your use of Our Company Website or other Company Programs. For example, We may collect Personal Information from publicly accessible sources (e.g., property records); directly from a third party (e.g., credit reporting agencies or customer due diligence providers); or from a third party with Your consent (e.g., Your bank). We may merge or co-mingle that Personal Information with the Personal Information We maintain about You and other data collected on or through Our Company Website. Categories of sources from which We may collect Personal Information include: advertising networks; internet service providers; Data Analytics Providers; government entities; operating systems and platforms; and social networks.

1.4    EXCLUSIONS FROM PERSONAL INFORMATION.

Personal Information does not include: (i) Publicly available information from government records; or (ii) De-identified or aggregated consumer information.

2.    HOW WE USE YOUR INFORMATION.

2.1    PRIMARY WAYS WE USE YOUR INFORMATION.

In addition to Section 1, a User’s Personal Information may be gathered, collected, recorded, held, processed, or otherwise used by or on behalf of the Company (including by Our Service Providers/Contractors as defined in Section 3 herein) to provide, maintain, and improve Our Services to You, including for the following purposes:

• When you purchase something from our Company Website or any other Company Program (including without limitation a Trip as defined in the T&C or any other goods/services), as part of the buying and selling process, We collect the Personal Information that You give Us (such as, but not limited to, your name, address, email address, date of birth, phone number, gender and (optionally) your social media handle). We use this Personal Information to process your buying and selling transactions, fulfill your orders, and/or process any other aspects of your transactions.
• When You browse Our Company Website, We also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps Us learn about Your browser and operating system.
• Email marketing: We may send You emails or otherwise communicate with You about the Company Website, the Company’s products and services, other offers and events, or other updates or promotional information. If You prefer not to receive promotional communications from Us, You may “Opt Out” at any time by following the “Opt Out” instructions in Section 5.1 herein.
• Text message marketing: We may send You SMS Text messages or otherwise communicate with You about the Company Website, the Company’s products and services, other offers and events, or other updates or promotional information. If You prefer not to receive promotional communications from Us, you may “Opt Out” at any time by following the “Opt Out” instructions in Section 5.1 herein or reply “STOP” to any Text message You may receive.
• To allow You to sign up and participate in any other Company communication resources, including without limitation any Newsletters/Alerts, as defined in Section 1.1 herein.  If You prefer not to continue to receive these other Company communications, You may “Opt Out” at any time by following the “Opt Out” instructions in Section 5.1 herein;
• When You provide Us with Personal Information to complete a transaction (including without limitation a Trip as defined in the T&C), We verify your credit card, place an order, connect with our online customer service through online chat or email, we imply that you consent to our collecting it and using it for that specific reason only.
• We may also collect Personal Information, including contact information, if you elect to enter or participation in any Contests/Sweepstakes (as defined in Section 1.1 herein), which we will use to facilitate the Contests/Sweepstakes.
• We may also collect Personal Information if You elect to sign up and/or participate in any other Company communication resources, including without limitation any Newsletters/Alerts, as defined in Section 1.1 herein If You prefer not to continue to receive these other Company communications, You may “Opt Out” at any time by following the “Opt Out” instructions in Section 5.1 herein.
• To carry out or facilitate any Personal Information You provide if You participate in any Customer Surveys (as defined in Section 1.1 herein). 
• The Company collects Personal Information from those individuals applying for employment or similar positions at the Company to the extent necessary to: (i) identify the individual; and (ii) evaluate their suitability for the position applied for. This Personal Information may include name, contact information, educational and employment background, criminal record information, residency and/or citizenship information, and other information necessary for Us to screen potential employees and staff.
• As may otherwise be needed to Book a Trip (as defined in the T&C).
• Without limiting the foregoing, We may also use Your Personal Information for the following purposes:
  • Send support and administrative messages, and respond to your comments, questions, and customer service requests;
  • Monitor and analyze trends, usage, and activities in connection with Our goods/services;
  • To conduct credit card screenings or to otherwise protect against fraud or unauthorized transactions, including by identifying potential unauthorized users or hackers;
  • Personalize Your experience and the advertisements and content You see when You use any Company Program based on Your preferences, interests, and browsing and purchasing behavior;
  • For compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested under any subpoena;
  • To facilitate Your use of various social media sharing features or other integrated tools (such as the Facebook “Like” button) which You may use as part of social media pages; and
  • To carry out any other purpose described to You at the time the Personal Information is collected.

2.2    OTHER WAYS WE MAY USE YOUR INFORMATION.

In addition to the above, Your Personal Information may be gathered, collected, recorded, held or otherwise used for the following additional purposes:

• Outside Professionals: To use with, or otherwise distribute, share or disclose to, any of the Company’s professional advisors such as attorneys, accountants, financial advisors, investment plan administrators, or insurance providers (“Outside Professionals”) in order to facilitate the professional advice from those Outside Professionals (See Section 3); 
• Government Entities: To use with, or otherwise distribute, share, or disclose to, any court, tax authorities, law enforcement authorities, other administrative agencies, other governmental agencies, or any other government entities (collectively, “Government Entities”) in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law, or regulation, or in order to respond to any request of any Government Entities, including without limitation tax reporting (See Section 3);
• Auditing: Auditing related to a current interaction with You, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Security: Helping to ensure security and integrity to the extent the use of Your Personal Information is reasonably necessary and proportionate for these purposes;
• Debugging: Debugging to identify and repair errors that impair existing intended functionality;
• Transient Use: Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with Us provided that Your Personal Information is not disclosed to a third party and is not used to build a profile about You or otherwise alter Your experience outside the current interaction with Us;
• Services: Performing services on Our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on Our behalf;
• Advertising: Providing advertising and marketing services to You;
• Research: Undertaking internal research for technological development and demonstration;
• Quality and Safety: Undertaking activities to verify or maintain the quality or safety of Our products and services and to improve, upgrade, or enhance Our products and services; and
• Commercial Interests: Advancing Our commercial or economic interests, such as by inducing a 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.

2.3    OTHER TERMS REGARDING THE USE OF YOUR INFORMATION.

2.3.1    We will use or share Your Personal Information only for the purposes as described in this Section 2 and in Section 3 herein, unless We reasonably determine We need to use it for another reason and that reason is compatible with the original purpose(s) described herein. For example, We consider de-identification, aggregation, and other forms of anonymization of Personal Information to be compatible with the purposes listed herein and in Your interest because the anonymization of such information reduces the likelihood of improper disclosure of that information. If We need to use Your Personal Information for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so. If You wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact Us via the information specified in the Contact section below.

2.3.2    PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR ADDITIONAL CONSENT IN COMPLIANCE WITH THIS PRIVACY POLICY AND WHERE DOING SO IS REQUIRED OR PERMITTED BY LAW INCLUDING WITHOUT LIMITATION ANY SUBPOENA OR OTHER TYPES OF COURT ORDERS.

3.    SHARING OF INFORMATION.

We may distribute, share or disclose Personal Information about You as follows or as otherwise described herein:

• Affiliates and Subsidiaries: We may disclose Your Personal Information with our affiliates or subsidiaries for any of the purposes described herein (collectively, “Affiliates”).
• Service Providers/Contractors:  We may share or disclose Your Personal Information with Our service providers or other third-party vendors or contractors that We engage or retain in connection with the provision of the Company Programs or otherwise to help Us carry out and fulfill a business or commercial purpose for the Company, including without limitation the following types of service providers that We may engage (all are hereinafter collectively referred to as “Service Providers/Contractors”):
  • Email, internet or other telecommunication Service Providers/Contractors;
  • Cloud, other data storage, or other hosting Service Providers/Contractors;
  • Third-party payment Service Providers/Contractors, including without limitation third-party credit card processors (see Third Party Application Providers below in this Section 3);
  • Data analytics companies who assist Us with various types of data analytics, web analytics, and app analytics (see Data Analytics Providers and Data Analytics Tools or Services below in this Section 3);
  • Host and Operators, as such terms are defined in the Terms and Conditions;
  • Third party advertising or marketing companies that We engage (see Advertising Networks below in this Section 3; or
  • Other third-party contractors, we engage to assist Us in providing Our goods/services and services.
• Third-Party Application Providers: If a third-party application is used to support Our Company Programs, We may share or disclose Your Personal Information to such third-party application providers, including without limitation third-party credit card processors, other third-party payment service providers, or intermediary services that assist in processing Your payments service provider (collectively ”Third Party Application Providers“).
• Data Analytics Providers and Data Analytics Tools or Services: We may use analytics tools or services provided by a third party data analytics service provider (”Data Analytics Providers“) or by using one of their tools, such as, but not limited to Google Analytics, to collect and process certain analytics data (“Data Analytics Tools or Services”). These Data Analytics Tools or Services may also collect data about Your use of other websites, apps, and online resources. SEE SECTION 8.5 OF THIS PRIVACY POLICY THAT PROVIDES FURTHER NOTICE ABOUT HOW SOME OF THESE DATA ANALYTICS PROVIDERS AND DATA ANALYTICS TOOLS OR SERVICES MAY USE COOKIES AND PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES. 
• Aggregated Form: We may make certain automatically collected, aggregated, or otherwise de-identified Personal Information available to third parties for various other purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding Our Users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Company Programs.
• Advertising Network: We may work with advertising companies or marketing companies (collectively, “Advertising Network”) in order to provide You with advertisements, marketing or other information that We think may interest You or to others. These Advertising Networks may set or access their own cookies, pixel tags or similar technologies on our Company Programs or they may otherwise collect or have access to data about You which they may collect over time and across different online services. These Advertising Networks may also provide Us with their own independent data about potential customers and such data could include data about You previously collected by the Advertising Network.
• Social Media Activities: The Company Programs may, now or in the future, offer certain Social Media Activities (as defined in Section 1.2 above), including without limitation certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let You share actions that You take on Our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings You establish with the entity that provides the social sharing feature.
• Merger, Sale, or Other Asset Transfers: We may share or disclose or otherwise transfer Your Personal Information to the Company’s Outside Professionals (as defined in Section 2.2 herein), other advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which We are acquired by or merged with another company or We sell, liquidate, or transfer all or a portion of Our assets.
• Government Entities or as Otherwise Required By Law, Subpoena, or Similar Government Order: We may use, distribute, share, disclose, access, or preserve Your Personal Information if We believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any tax reporting requirements of the Company; (ii) comply with any other law enforcement requests or legal process or requirements of any Government Entities (as defined in Section 2.2 above), such as a court order or subpoena; (iv) comply with any other form of request from any Government Entities; (v) respond to Your requests; or (vi) protect Your, Our, or others’ rights, property, or safety. FOR THE AVOIDANCE OF DOUBT, WE MAY BE REQUIRED TO DISCLOSURE YOUR PERSONAL INFORMATION TO: (I) TAXING AUTHORITIES AS PART OF OUR TAX REPORTING REQUIREMENTS; OR (II) LAW ENFORCEMENT AUTHORITIES OR OTHER GOVERNMENTAL ENTITIES OR VIA SUBPOENA ARISING OUT OF YOUR USE OF ANY UNLAWFUL OR INFRINGING CONTENT WHILE USING ANY COMPANY PROGRAM.
• Company’s Outside Professionals: We may share or disclose Your Personal Information with any of the Company’s Outside Professionals (as defined in Section 2.2 herein) in order to facilitate the professional advice such Outside Professionals provide to the Company.
• Consent: We may also share or disclose Your Personal Information with your permission.

4.    DATA RETENTION.

We will retain Your Personal Information for as long as necessary to fulfill the purposes for which We collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Your Personal Information, the purposes for which We process Your Personal Information, whether We can achieve those purposes through other means, and the applicable legal requirements.

5.    CERTAIN ADDITIONAL CHOICES YOU MAY HAVE ABOUT YOUR INFORMATION.

5.1    OPT-OUT FROM RECEIVING COMMUNICATIONS FROM THE COMPANY.

5.1.1    YOU CAN OPT-OUT FROM RECEIVING COMMUNICATIONS FROM THE COMPANY.

In the event a User has provided the Company with Personal Information such as that discussed above, and thereafter a User does not want to continue to directly receive further notices. information  or communications from the Company such as emails or newsletters relate to the Company’s goods/services, the User must send an email message to the Company at this email address [email protected] stating that the User no longer wants to receive these communications or other communications directly from the Company (“Communication Opt Out”). Once the Company has received the User’s request for the Communication Opt Out, the Company will use commercially reasonable efforts, in a commercially reasonable time period, to try to carry out such User’s request for the Communication Opt Out; provided, however, the Company will not have any obligation to retrieve, and cannot prevent the further use by others of, such User’s Personal Information which may have been shared up to that time with other parties as permitted by the provisions of this Privacy Policy.

5.1.2    EFFECT OF COMMUNICATION OPT-OUT.

If a User elects to send the Company a Communication Opt Out (as defined in Section 5.1.1), and provided such User has properly delivered its Communication Opt Out request to the Company in accordance with Section 5.1 herein, such User will no longer receive emails directly from the Company after a commercially reasonable time from the date such User sent its Communication Opt Out notice to the Company. However, the Company does not have any obligations under, or liability arising out of, this Privacy Policy with regard to a User’s decision to share its Personal Information with, Our use of, any other internet websites, forums, or programs that the User may have linked to via the Company Website which are not under the Company’s direct control or ownership. Accordingly, after sending Your Communication Opt-Out notice to the Company, You may need to contact these other entities directly regarding their use of Your Personal Information.

5.2    OPT-OUTING OF BEHAVIORAL ADVERTISING OR USE OF ANALYTICS TOOLS.

5.2.1    BEHAVIORAL ADVERTISING.

Our Company Website or other Company Programs may use behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about Your use of the Company Website or other Company Programs so that they can provide advertising about products and services tailored to Your interests. That advertising may appear either on the Company Website or other Company Program(s), or on other websites not operated by Us. If You do not want third parties to collect information about Your use of the Company Website or other Company Program(s), You can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING OUR COMPANY WEBSITE OR OTHER COMPANY PROGRAM(S). IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

5.2.2    OPTING OUT OF USE OF ANALYTICS.

Many analytics providers allow end-users to opt out of the retention of their information, including Our third-party Data Analytics Providers (as defined in Section 3 herein). Please note that, typically, unless You create an account with the analytics provider, Your choice to opt out applies only to the device from which You make the request, because the providers use cookies on that device to recognize Your choice. If You get a new device, install a new web browser, update Your browser, or otherwise erase/alter Your browser cookie files You may clear the opt-out cookie

5.3.    DO NOT TRACK NOTICE. 

Some browsers have a “DO NOT TRACK” feature that lets website users inform websites or other applications that they do not want to have their online activities tracked. These “do not track” features may also give website users other choices regarding the collection of their personal identifiable information. However, these “do not track” features and “do not track’ signals are not yet uniform. ACCORDINGLY, EACH USER OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM IS HEREBY NOTIFIED THAT THE COMPANY WEBSITE AND THE OTHER COMPANY PROGRAMS ARE NOT CURRENTLY SET UP TO RESPOND TO ANY OF THE USER’S “DO NOT TRACK” FEATURES OR “DO NOT TRACK” SIGNALS. This “DO NOT TRACK” notice is provided to Users at the recommendation of the U.S. Federal Trade Commission and to residents of the State of California as required pursuant to the California Online Privacy Protection Act (CalOPPA). 

5.4.    GEO-LOCATION DATA.

You may be able to prevent Your device from sharing precise location information, including without limitation some or all of the Geo-Location Data described in Section 1.2 above, at any time through Your device’s operating system settings.

6.    LINKS TO, AND USE OF, THIRD-PARTY SERVICES OR THIRD-PARTY SITES.

6.1    THIRD-PARTY SERVICES. 

In general, the third-party providers used by Us will only collect, use and disclose Your information to the extent necessary to allow them to perform the services they provide to Us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information We are required to provide to them for Your purchase-related transactions. For these providers, We recommend that You read their privacy policies so You can understand the manner in which Your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either You or Us. So if You elect to proceed with a transaction that involves the services of a third-party service provider, then Your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if You are located in Canada and Your transaction is processed by a payment gateway located in the United States, then Your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once You leave Our Company Website or any other Company Program, or are redirected to a third-party website or application, You are no longer governed by this Privacy Policy or Our T&C .

6.2    LINKS. 

When You click on links on Company’s Website, they may direct You away from our site. We are not responsible for the privacy practices of other sites and encourage You to read their privacy statements.

6.3    COOKIES BY THIRD PARTIES. 

Third parties vendors (e.g., Google, Facebook, etc.) may use cookies and similar technologies to collect or receive information regarding Your device and elsewhere on the internet and use that information to provide measurement services and target ads. You can choose to opt out of Google’s use of cookies by visiting the Google ad and content network privacy policy.

7.    INFORMATION SECURITY.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, We cannot guarantee its absolute security. We make efforts to protect Your Personal Information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If You have questions about the security of Your Personal Information, contact the Company at the email or regular mailing address specified in the Contact Use section below.

7.1    COPPA NOTICE. 

This Company Website and other Company Programs are not directed to children under the age of 13. We adhere to the U.S. federal Children’s Online Privacy Protection Act (“COPPA“) and will not knowingly register or otherwise collect Personal Information from any child under the age of 13. We ask that minors under the age of 13 not submit any Personal Information to Us. If You have reason to believe a child under the age of 13 has provided Us with Personal Information, please contact the Company and request that such information be deleted from Our records.

7.2    USER AGE CONFIRMATION.

By using the Company Website or any other Company Program, You represent that You are at least the age of majority in Your state or province of residence, or that You are the age of majority in Your state or province of residence and You have given Us your consent to allow any of Your minor dependents to use Our Company Website or other Company Program.

8.    COOKIES POLICY; HOW YOU CAN DISABLE COOKIES.

8.1    WHAT ARE COOKIES? 

As is common practice with almost all professional websites this Company Website or other Company Program use cookies, which are tiny files that are downloaded to your computer, to improve your experience. This section describes what information they gather, how We use it and why We sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of a website’s functionality.

8.2    HOW WE USE COOKIES.   

• WE USE COOKIES FOR A VARIETY OF REASONS AS INDICATED IN SECTION 1.2, SECTION 3, AND THIS SECTION 8 OF THIS PRIVACY POLICY.
• In addition to the description of cookies as set forth in Section 1.2 and Section 3 of this Privacy Policy, We may use analytics tools, services or similar tools provided by third parties Data Analytics Providers (as defined in Section 3 herein) to help analyze how You and other Users utilize the Company’s products/services. These analytics tools use cookies and other tracking technologies to collect information such as how often Users visit the Company Website or other Company Programs, what pages they visit, and what other websites they have used prior to visiting the Company Website. We use the information We get from these analytics tools to improve Our products/services. Analytics tools collect the IP address or other unique identifier assigned to You and/or Your devices on the date You visited them. Analytics tools provided by third parties plant a persistent cookie on Your web browser to identify You as a unique User the next time You visit the Company Website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy.
• Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that You leave on all cookies if You are not sure whether You need them or not in case they are used to provide a service that You use.
• BY USING OUR COMPANY WEBSITE, YOU GIVE CONSENT FOR US TO SHARE YOUR PERSONAL INFORMATION WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU THE PRODUCTS/SERVICES.

8.3    DISABLING COOKIES. 

You can prevent the setting of cookies by adjusting the settings on Your browser (see Your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that You visit. Disabling cookies will usually result in also disabling certain functionality and features of this Company Website or any other Company Programs. Therefore, it is recommended that You do not disable cookies.

8.4    THE COOKIES WE SET.

In addition to the disclosures We have provided in Section 1.2 and Section 3 of this Policy regarding cookies or other web-based tracking technologies or analytics tools, the following section details certain ways that We may set or use cookies or other web-based tracking technologies on the Company Website or any other Company Program:

• Email newsletters related cookies: The Company Website or other Company Programs  may offer newsletters or email subscription services and cookies may be used to remember if You are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
• Orders processing related cookies: The Company Website or other Company Programs This site offer e-commerce or payment facilities and some cookies are essential to ensure that Your order is remembered between pages so that We can process it properly.
• Forms related cookies: When You submit data to or through a form such as those found on contact pages or comment forms, cookies may be set to remember Your user details for future correspondence.

8.5    THIRD-PARTY COOKIES. 

In certain instances, cookies provided by third parties may also be used. In addition to the disclosures We have provided in Section 1.2 and Section 3 of this Policy regarding use of cookies or other web-based tracking technologies or analytics tools by third parties, the following section details certain third party cookies You might encounter through the Company Website or any other Company Program:

• As noted in Section 3, this Company Website or any other Company Program may engage Data Analytics Providers and/or use Data Analytics Tools or Services (as such terms are defined in Section 3), such as Google Analytics) which are some of the most widespread and trusted analytics solution on the web for helping Us to understand how You use the Company Website and ways that We can improve Your experience. These cookies may track things such as how long You spend on the Company Website and the pages that You visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
• Data Analytics Providers and/or use Data Analytics Tools or Services are used to track and measure usage of this Company Website or any other Company Program so that We can continue to produce engaging content. These cookies may track things such as how long You spend on the site or pages You visit which helps us to understand how we can improve the site for You.
• From time to time, We test new features and make subtle changes to the way that the Company Website or other Company Programs are delivered. When We are still testing new features these cookies may be used to ensure that You receive a consistent experience whilst on the Company Website or other Company Programs whilst ensuring We understand which optimizations Our users appreciate the most.
• As We sell Our goods/services, it’s important for Us to understand statistics about how many of the visitors to Our Company Website or any other Company Program actually make a purchase and as such this is the kind of data that these cookies will track. This is important to You as it means that We can accurately make business predictions that allow Us to monitor our advertising and product/service costs to ensure the best possible price.
• Certain of Our Advertising Partners (as defined in Section 3 of this Policy) advertise on Our behalf and affiliate tracking cookies allow Us to see if Our customers have come to the have come to the Company Website or other Company Programs through one of these Advertising Partner sites or sources. to determine a number of factors, including so that We can credit them appropriately and where applicable allow Our Advertising Partners to provide any bonus that they may provide You for making a purchase.
• We also use social media buttons and/or plugins on this Company Website or any other Company Program that allow You to connect with Your social network in various ways. For these to work, many social media sites including (such as Facebook, Instagram and LinkedIn) may set cookies through Our Company Website or any other Company Program which may be used to enhance Your profile on their social media site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

9.    YOUR CONSENT TO THIS PRIVACY POLICY; ENFORCEMENT OF THIS PRIVACY POLICY BY THE COMPANY.

EACH USER CONFIRMS AND AGREES THAT BY THE USER’S ACT OF USING THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAMS, INCLUDING WITHOUT LIMITATION UPLOADING ANY OF THE USER’S PERSONAL INFORMATION OR ANY OTHER CONTENT VIA THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM OR BY PARTICIPATING IN ANY TRIP (AS SUCH TERM IS DEFINED IN THE T&C), THE USER:

• (A) UNCONDITIONALLY CONSENTS TO AND AGREES TO ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, INCLUDING WITHOUT LIMITATION AUTOMATICALLY CONSENTING TO THE COLLECTION, USE AND SHARING OF THE USER’S PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY POLICY; AND
• (B) FURTHER AGREES THAT NO PROVISION OF THIS PRIVACY POLICY SHALL LIMIT, CONDITION, ALTER, OR AMEND, IN ANY WAY WHATSOEVER, ANY RIGHTS THAT USER MAY HAVE SEPARATELY GRANTED TO THE COMPANY PURSUANT TO ANY OTHER AGREEMENT THAT THE USER MAY HAVE SEPARATELY ENTERED INTO WITH THE COMPANY.

10.    CHANGES TO THIS PRIVACY POLICY.

We reserve the right to change, modify or clarify this Privacy Policy at any time (“Changes”), so please review it frequently. All such Changes to this Privacy Policy will take effect immediately upon their posting on the Company Website or any other Company Program. The Company reserves the right to make any and all Changes to the Privacy Policy without providing individualized notice to a User. YOU HEREBY AGREE THAT YOU ARE BOUND BY ALL CHANGES TO, AND ANY UPDATED VERSION OF, THIS PRIVACY POLICY THAT ARE IN EFFECT EACH TIME YOU USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. THUS, THE TERMS OF THIS PRIVACY POLICY MAY BE DIFFERENT THE NEXT TIME YOU USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. ANY USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM BY YOU AFTER SUCH CHANGES SHALL BE DEEMED TO CONSTITUTE ACCEPTANCE BY THE USER OF ALL SUCH CHANGES WITH REGARD TO THE COMPANY WEBSITE AND ALL COMPANY PROGRAMS. EACH USER SHOULD REGULARLY REVIEW AND PRINT THIS PRIVACY POLICY FOR THE USER’S RECORD. If the Company is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products or services to You.

11.    ADDITIONAL NOTICES AND DISCLOSURES UNDER SPECIFIC LAWS.

• NOTICE TO CALIFORNIA RESIDENTS:  Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), residents of the State of California (“California Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all California Residents as set forth in Appendix 1 of this Privacy Policy.
• NOTICE TO COLORADO RESIDENTS:  Under the Colorado Privacy Act (the “CPA”), residents of the State of Colorado (“Colorado Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all such Colorado Residents as set forth in Appendix 2 of this Privacy Policy.
• NOTICE TO CONNECTICUT RESIDENTS:  Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”), residents of the State of Connecticut (“Connecticut Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all such Connecticut Residents as set forth in Appendix 3 of this Privacy Policy.
• NOTICE TO NEVADA RESIDENTS:  Under Nevada Revised Statues Section 603A., et. seq., residents of the State of Nevada (“Nevada Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Nevada Residents as set forth in Appendix 4 of this Privacy Policy.
• NOTICE TO UTAH RESIDENTS:  Under the Utah Consumer Privacy Act (the “UCPA”), residents of the State of Utah (“Utah Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Utah Residents as set forth in Appendix 5 of this Privacy Policy.
• NOTICE TO VIRGINIA RESIDENTS:  Under the Virginia Consumer Data Protection Act, as amended (the “VCDPA”), residents of the State of Virginia (“Virginia Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Virginia Residents as set forth in Appendix 6 of this Privacy Policy.

12.    CONTACT INFORMATION:

If You have questions or comments about this Privacy Policy or the Company Websites, Company Programs or Services, please email Us via the contact information below:

• By emailing the Company at the following email address: [email protected]

APPENDIX 1

CALIFORNIA PRIVACY RIGHTS NOTICE

Effective Date: May 21, 2024

1.    YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA.

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if You are a resident of California You have the following rights with respect to Your Personal Information.

1.1    RIGHT TO KNOW ABOUT OUR COLLECTION, DISCLOSURE, SHARING AND SALE OF PERSONAL INFORMATION ABOUT YOU.

Personal Information as defined in the CCPA is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to You, including the following categories of information: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of Personal Information We have collected about You; the categories of sources from which We collect Personal Information; Our business or commercial purpose for collecting, disclosing, sharing, or selling Personal Information; the categories of third parties to whom We disclose, share, or sell Personal Information, if any; and the specific pieces of Personal Information We have collected about You. Personal Information includes “sensitive” Personal Information as described below.

1.2    RIGHT TO KNOW ABOUT OUR COLLECTION, DISCLOSURE, SHARING AND SALE OF “SENSITIVE” PERSONAL INFORMATION ABOUT YOU.

“Sensitive” Personal Information as defined in the CCPA is Personal Information that reveals: (a) Your Social Security, driver’s license, state identification card, or passport number; (b) Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) Your precise geolocation; (d) Your racial or ethnic origin, religious, or philosophical beliefs, or union membership; (e) the contents of Your mail, email, and text messages unless We are the intended recipient of the communication; and (f) Your genetic data. “Sensitive” Personal Information also includes biometric information that is processed for the purpose of identifying You, information that is collected and analyzed concerning Your health; or Your sex life or sexual orientation.

You have the right to know the categories of “sensitive” Personal Information We have collected about You, the categories of sources from which We collect Personal Information, Our business or commercial purpose for collecting, selling, or sharing “sensitive” Personal Information, the categories of third parties with whom We sell or share “sensitive” Personal Information, if any, and the specific pieces of “sensitive” Personal Information We have collected about You.

1.3    RIGHT TO DELETE YOUR PERSONAL INFORMATION.

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to deletion of Your Personal Information from Our records, and to have Us direct Our Service Providers/Contractors and third parties to delete Your Personal Information from their records.

We are not required to, and reserve Our right to not delete Your Personal Information if it is necessary to: (i) complete the transaction for which the Personal Information was collected, provide a good or service requested by You, or reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform a contract between You and Us; (ii) help to ensure security and integrity to the extent the use of Your Personal Information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) 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 Our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided We have obtained Your informed consent; (vii) enable solely internal uses that are reasonably aligned with Your expectations based on Your relationship with Us and compatible with the context in which You provided the information; and (viii) comply with a legal obligation.

1.4    RIGHT TO CORRECT INACCURATE PERSONAL INFORMATION.

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to correct any inaccurate Personal Information in Our records, and to have Us direct Our Service Providers/Contractors and third parties to correct any inaccurate Personal Information from their records.

If We cannot verify Your identity pursuant to the CCPA and its regulations, We may deny a request to correct. In such event, We shall inform You that Your identity cannot be verified.

In determining the accuracy of the Personal Information that is the subject of Your request to correct, We shall consider the totality of the circumstances relating to the contested Personal Information. We may deny Your request to correct if We determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances.

1.5    RIGHT TO BE FREE FROM DISCRIMINATION.

You have the right to not be discriminated against by Us because You exercised any of Your rights under the CCPA. This means We cannot, on the basis of the exercise of Your rights thereunder, among other things, deny goods or services to You, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to You; or suggest that You will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against You as an employee, applicant for employment, or independent contractor.

1.6     RIGHT TO OPT-OUT OF THE SHARING OF PERSONAL INFORMATION.

We may disclose Your Personal Information to third parties for cross-context behavioral advertising purposes (“Share” or “Sharing”). This means the targeting of advertising to You based on Your Personal Information that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may Share Personal Information with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the Sharing of Your Personal Information and You may exercise Your right by emailing us at [email protected] with the subject “CA Do Not Sell”. If You exercise Your right to opt-out of the Sharing of Your personal information, We will refrain from Sharing Your Personal Information, unless You subsequently provide express authorization for the sharing of Your Personal Information.

1.7    RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION.

We may disclose Your Personal Information to third parties in exchange for monetary or other consideration. Such disclosures are considered to be “Sales” under the CCPA. We may Sell Personal Information to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or any other Company Programs and/or to recommend Our goods/services to You based on Your activity on other websites or apps. You have the right to opt-out of the Sale of Your Personal Information and You may exercise Your right by emailing us at [email protected] with the subject “CA Do Not Sell”. If You exercise Your right to opt-out of the Sale of Your Personal Information, We will refrain from Selling Your Personal Information, unless You subsequently provide express authorization for the Sale of Your Personal Information.

1.8    RIGHT TO LIMIT THE USE OF “SENSITIVE” PERSONAL INFORMATION.

We may use Your “sensitive” Personal Information for purposes other than is necessary to provide Our goods/services as reasonably expected by You. For example, We may share Your “sensitive” Personal Information with Advertising Networks that may use such information to target advertising to You.  You have the right to limit Our use of Your “sensitive” Personal Information to that which is necessary to provide Our goods and services to You by emailing us at [email protected] with the subject “CA Do Not Share”.

1.9    RIGHT OF CHILDREN TO OPT-IN TO THE SALE OF PERSONAL INFORMATION.

We do not knowingly collect or sell the Personal Information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their Personal Information, We have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, We require the consumer to affirmatively authorize the sale of the consumer’s Personal Information. In order to opt-in minors in this age range, as part of the account registration process for Our products which may be targeted toward minors, We require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which We have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, We require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for Our goods/services which may be targeted toward minors, We require that the consumer’s parent or guardian verify the consumer’s identity, which We have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete Your request if We cannot verify Your identity. If You are a parent or guardian seeking to opt-out on behalf of their child, please contact Us at the email address [email protected] with the subject “Minor Opt-Out”.

2.    HOW TO EXERCISE YOUR CCPA RIGHTS.

Unless otherwise specified, to exercise any of Your rights described in this Appendix 1, please submit Your request to Us at the email address [email protected] with the subject “CCPA Consumer Request”.

In order to verify Your request, We will need You to provide Us with enough information to identify You (e.g., Your full name, address, and customer or matter reference number), proof of Your identity and address (e.g., a copy of Your driver’s license or passport and a recent utility or credit card bill), and a description of what right You wish to exercise along with any information to which Your requests relates. If feasible, We will match the identifying information provided by You with the personal information that We already maintain about You.

You may designate an authorized agent to make a request under the CCPA on Your behalf. In order to fulfill Your request to know or delete submitted by an authorized agent, You must provide the authorized agent written permission to do so, and We may require that You verify Your own identity with Us directly.

We reserve Our right not to grant a consumer request if We cannot verify that the person making the request is the person about whom We have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of Personal Information twice within a 12-month period. Any Personal Information We collect from You to verify Your identity in connection with Your request will be used solely for the purposes of verification.

3.    OUR PERSONAL INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES.

A description of the Personal Information that We collect online and off-line is provided in Section 1 of the main Policy.

The purposes for which We collect and use Personal Information are described in Sections 1, 2, 3 and 8 of the main Policy.

Sources from which We receive Personal Information are described in Section 1 of the main Policy.

Our Personal Information disclosure practices are described in Section 1, 2, 3, and 8 of the main Policy.

Our Personal Information retention practices are described in Section 4 of the main Policy.

3.1    CATEGORIES OF PERSONAL INFORMATION COLLECTED; SOLD OR SHARED FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING; AND DISCLOSED FOR A BUSINESS PURPOSE WITHIN THE PAST 12 MONTHS.

Category of Personal Information	Collected	Sold or Shared in the Past 12 Months?	Categories of Third Parties to Whom Sold or Shared	Disclosed for a Business Purpose in Past 12 Months?	Categories of Third Parties to Whom Disclosed
Individual Identifiers	Yes	Yes	Advertising Networks; Data Analytics Providers	Yes	Service Providers/ Contractors; Government Entities; Affiliates
Categories Described in California Consumer Records Act, Civil Code §1798.81.5	Yes	Yes	Advertising Networks; Data Analytics Providers	Yes	Service Providers/ Contractors; Government Entities; Affiliates
Characteristics of protected classifications under California or federal law.	Yes	No	Not Applicable	Yes	Service Providers/ Contractors; Government Entities; Affiliates
Commercial information.	Yes	Yes	Advertising Networks; Data Analytics Providers	Yes	Service Providers/ Contractors; Government Entities; Affiliates
Biometric information.	Yes	No	Not Applicable	Yes	Not Applicable
Internet or other electronic network activity.	Yes	Yes	Advertising Networks; Data Analytics Providers	Yes	Service Providers/ Contractors
Geolocation data.	No	No	Not Applicable	No	Service Providers/ Contractors
Audio, electronic, visual, thermal, olfactory, or similar information.	Yes	No	Not Applicable	Yes	Governmental Entities; Contractors
Professional or employment-related information.	Yes	No	Not Applicable	Yes	Service Providers/ Contractors Affiliates
Education information.	Yes	No	Not Applicable	Yes	Service Providers/ Contractors Affiliates
Inferences drawn from any of the information identified above.	None	No	Not Applicable	No	None

 

3.2    CATEGORIES OF “SENSITIVE” PERSONAL INFORMATION COLLECTED; SOLD OR SHARED FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING; AND DISCLOSED FOR A BUSINESS PURPOSE WITHIN THE PAST 12 MONTHS.

Category of Sensitive Personal Information	Collected	Shared or Sold in the Past 12 Months?	Categories of Third Parties to Whom Shared or Sold	Disclosed for a Business Purpose in Past 12 Months?	Categories of Third Parties to Whom Disclosed
Social Security, Driver’s License, State ID, Passport Number.	Yes	No	Not Applicable	Yes	Government Entities
Account Log-in and Password	Yes	No	Not Applicable	No	Not Applicable
Financial Account, Debit Card, Credit Card Number and account access information.	Yes	No	Not Applicable	Yes	Service Providers/ Contractors
Precise Geolocation.	No	No	Not Applicable	No	Service Providers/ Contractors
Racial or ethnic origin, religious or philosophical beliefs or union membership.	No	No	Not Applicable	No	Not Applicable
Contents of e-mail, text messages unless We are intended recipient.	Yes	No	Not Applicable	No	Not Applicable
Genetic Data	No	No	Not Applicable	No	Not Applicable
Biometric Information for purpose of identification.	No	No	Not Applicable	No	Not Applicable
Health information collected and analyzed.	No	No	Not Applicable	No	Not Applicable
Sex life or sexual orientation collected and analyzed.	No	No	Not Applicable	No	Not applicable

4.    OTHER CALIFORNIA PRIVACY RIGHTS.

4.1    SHINE THE LIGHT REQUEST.

Individual consumers who reside in California and have provided Us with their Personal Information may request information about Our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must include Your name, street address, city, state, and zip code, and be submitted to Us at the email address [email protected] with the subject “California Shine The Light Request”.  Within thirty (30) days of receiving such a request, We will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve Our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

4.2    MINOR’S RIGHT TO REMOVE POSTED CONTENT.

If You are a California resident under the age of 18, and a registered User of any website where this Policy is posted, California Business and Professions Code Section 22581 permits You to request and obtain removal of content or information that You have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to the email address [email protected] with the subject “Privacy Rights for Minors”. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information You have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

APPENDIX 2

COLORADO PRIVACY RIGHTS NOTICE

Effective Date: May 21, 2024

1.    YOUR COLORADO PRIVACY RIGHTS.

Under the Colorado Privacy Act (the “CPA”) if You are a resident of Colorado, acting only in an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), Your rights with respect to Your Personal Data are described below.

1.1    DISCLOSURE OF OUR PERSONAL DATA COLLECTION AND PROCESSING PRACTICES.

Personal Data as defined in the CPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

• The categories of Personal Data that We collect or process (Section 1);
• The purposes for processing the Personal Data (Sections 1, 2 and 3);
• The categories of Personal Data shared with third parties (Sections 1, 2 and 3, and Section 3 in Appendix 1);
• The categories of third parties with whom We share Personal Data (Sections 1, 2 and 3, and Section 3 in Appendix 1); and
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3, and Section 3 in Appendix 1) therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)

1.2    RIGHT OF ACCESS.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3    RIGHT TO CORRECTION.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4    RIGHT TO DELETION.

You have the right to delete Personal Data concerning You.

1.5    RIGHT TO DATA PORTABILITY.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6    RIGHT TO OPT OUT.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising, (b) sale of Personal Data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising or profiling and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising or profiling, We will refrain from processing Your Personal Data for targeted advertising or profiling, unless You subsequently provide express authorization for the sharing of Your Personal Data.

We may disclose Your Personal Data to third parties in exchange for monetary or other consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our goods/services to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their Personal Data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7    YOUR “SENSITIVE DATA” MAY NOT BE PROCESSED WITHOUT YOUR CONSENT.

“Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; (b) the processing of genetic or biometric data for identification purposes and (c) Personal Data from a known child. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or lawful guardian.

2.    HOW TO EXERCISE YOUR CPA RIGHTS.

Unless otherwise specified, to exercise any of Your rights described in this Appendix 2, please submit Your request to Us at the email address [email protected] with the subject “CPA Consumer Request”. We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within forty-five (45) days of receipt of Your request. The notification will include a justification for declining to take action and instructions on how You may appeal.

Not more than sixty (60) days after receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision. If We deny the appeal, You may contact the Colorado Attorney General at https://complaints.coag.gov/s/?varCFT=2 or (720) 508-6000.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the CPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

You may designate another person to serve as Your authorized agent and act on Your behalf. We will comply with an opt-out request received from an authorized agent if We are able to verify, with commercially reasonable effort, Your identity and the authorized agent’s authority to act on Your behalf.

APPENDIX 3

CONNECTICUT PRIVACY RIGHTS NOTICE

Effective Date:  May 21, 2024

1.    YOUR CONNECTICUT PRIVACY RIGHTS.

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if You are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, nonprofit or governmental entity), Your rights with respect to Your Personal Data are described below.

1.1    DISCLOSURE OF OUR PERSONAL DATA COLLECTION AND PROCESSING PRACTICES.

Personal Data as defined in the CDPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

• The categories of Personal Data that We collect or process (Section 1);
• The purposes for processing the Personal Data (Sections 1, 2 and 3);
• The categories of Personal Data shared with third parties (Sections 1, 2 and 3, and Section 3 in Appendix 1);
• the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3, and Section 3 in Appendix 1); and 
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3, and Section 3 in Appendix 1) therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)

1.2    RIGHT OF ACCESS.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data, except if doing so would require Us to reveal a trade secret.

1.3    RIGHT TO CORRECTION.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4    RIGHT TO DELETION.

You have the right to delete Personal Data concerning You.

1.5    RIGHT TO DATA PORTABILITY.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6    RIGHT TO OPT OUT.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising, (b) sale of Personal Data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising or profiling and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising or profiling, We will refrain from processing Your Personal Data for targeted advertising or profiling, unless You subsequently provide Your express authorization.

We may disclose Your Personal Data to third parties in exchange for monetary or other consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our services/products to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their Personal Data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7    YOUR “SENSITIVE DATA” MAY NOT BE PROCESSED WITHOUT YOUR CONSENT.

“Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or immigration status; (b) the processing of genetic or biometric data for identification purposes; (c) Personal Data from a known child (individual under the age of 13); precise geolocation data. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or lawful guardian.

2.    HOW TO EXERCISE YOUR CDPA RIGHTS.

Unless otherwise specified, to exercise any of Your rights described in this Appendix 3, please submit Your request to Us at the email address [email protected] with the subject “CDPA Consumer Request”. We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within forty-five (45) days of receipt of Your request. The notification will include a justification for declining to take action and instructions on how You may appeal.

Not more than sixty (60) days after receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision. If We deny the appeal, You may contact the Connecticut Attorney General to submit a complaint at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page or (860) 808-5318.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the CDPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

You may designate another person to serve as Your authorized agent and act on Your behalf. We will comply with an opt-out request received from an authorized agent if We are able to verify, with commercially reasonable effort, Your identity and the authorized agent’s authority to act on Your behalf.

APPENDIX 4

NEVADA PRIVACY RIGHTS NOTICE

Effective Date: May 21, 2024

Under Nevada Revised Statues Section 603A., et. seq., residents of Nevada have certain rights with respect to the Personal Information that We collect on the Company Website.

1. The categories of Personal Information that We collect and the categories of third parties with whom We share Personal Information are described in the chart in the above Appendix 1 under the California Privacy Rights Notice.
2. You may review and request changes to the Personal Information that We collect or process on the Company Website by sending an e-mail to: [email protected].
3. Any material changes to this notice shall be posted in this Appendix 4 to this Privacy Policy.
4. When You use the Company Website, We may share Personal Information about Your online activities over time and across different internet sites or online services with third parties.

APPENDIX 5

UTAH PRIVACY RIGHTS NOTICE

Effective Date:  May 21, 2024

1.    YOUR UTAH PRIVACY RIGHTS UNDER THE UTAH CONSUMER PRIVACY ACT.

Under the Utah Consumer Privacy Act (the “UCPA”) if You are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) Your rights with respect to Your Personal Data are described below.

1.1    DISCLOSURE OF OUR PERSONAL DATA COLLECTION AND PROCESSING PRACTICES.

Personal Data as defined in the UCPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices in general, including:

• The categories of Personal Data that We collect or process (Section 1);
• The purposes for processing the Personal Data (Sections 1, 2 and 3);
• The categories of Personal Data shared with third parties (Sections 1, 2 and 3, and Section 3 in Appendix 1);
• The categories of third parties with whom We share Personal Data (Sections 1, 2 and 3, and Section 3 in Appendix 1); and
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3, and Section 3 in Appendix 1) therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)

1.2    RIGHT OF ACCESS.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3    RIGHT TO CORRECTION.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4    RIGHT TO DELETION.

You have the right to delete Personal Data concerning You.

1.5    RIGHT TO DATA PORTABILITY.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6    RIGHT TO OPT OUT.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising or (b) sale of Personal Data.

We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising, We will refrain from processing Your Personal Data for targeted advertising, unless You subsequently provide express authorization for the sharing of Your Personal Data.

We may disclose Your Personal Data to third parties in exchange for monetary consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our goods/services to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7    YOUR “SENSITIVE DATA” MAY NOT BE PROCESSED WITHOUT YOUR CONSENT.

“Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin; religious beliefs; sexual orientation; citizenship or immigration status; or medical history, mental or physical health condition, or medical treatment or diagnosis by a health care professional; (b) the processing of genetic or biometric data for identification purposes and (c) specific geolocation data. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or guardian.

2.    HOW TO EXERCISE YOUR UCPA RIGHTS.

Unless otherwise specified, to exercise any of Your rights described in this Appendix 5, please submit Your request to Us at the email address [email protected] with the subject “UCPA Consumer Request”. We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within 45 days of receipt of Your request.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the UCPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

APPENDIX 6

VIRGINIA PRIVACY RIGHTS NOTICE

Effective Date:  May 21, 2024

1.    YOUR VIRGINIA PRIVACY RIGHTS UNDER THE VCDPA.

Under the Virginia Consumer Data Protection Act, as amended (the “VCDPA”) if You are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), You have the following rights with respect to Your Personal Data.

1.1    DISCLOSURE OF OUR PERSONAL DATA COLLECTION AND PROCESSING PRACTICES.

Personal Data as defined in the VCDPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

• The categories of Personal Data that We collect or process (Section 1);
• The purposes for processing the Personal Data (Sections 1, 2 and 3);
• The categories of Personal Data shared with third parties (Sections 1, 2 and 3, and Section 3 in Appendix 1);
• The categories of third parties with whom We share Personal Data (Sections 1, 2 and 3, and Section 3 in Appendix 1); and
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3, and Section 3 in Appendix 1) therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)

1.2    RIGHT OF ACCESS.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3    RIGHT TO CORRECTION.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4    RIGHT TO DELETION.

You have the right to delete Personal Data concerning You.

1.5    RIGHT TO DATA PORTABILITY.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6    RIGHT TO OPT OUT.

You have the right to opt out of the processing of Your Personal Data for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising or profiling and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising or profiling, We will refrain from processing Your Personal Data for targeted advertising or profiling, unless You subsequently provide Your express authorization.

We may disclose Your Personal Data to third parties in exchange for monetary consideration. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our goods/services to You based on Your activity on other websites or apps. We may share Your Personal Data with Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by emailing us at [email protected] with the subject “Delete My Data”. If You exercise Your right to opt-out of the sale of Your personal data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

1.7    YOUR “SENSITIVE DATA” MAY NOT BE PROCESSED WITHOUT YOUR CONSENT.

“Sensitive Data” means (a) Personal Data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (b) the processing genetic or biometric data for the purpose of uniquely identifying You; (c) the Personal Data from a known child; or (d) precise geolocation. We do not process “Sensitive Data” If We intend to do so, We will obtain Your consent or in the case of a known child, the consent as required by the federal Children’s Online Privacy Protection Act.

2.    HOW TO EXERCISE YOUR VCDPA RIGHTS.

Unless otherwise specified, to exercise any of Your rights described in this Appendix 6, please submit Your request to Us at the email address [email protected] with the subject “VCPDA Consumer Request”. We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within forty-five (45) days of receipt of Your request. The notification will include a justification for declining to take action and instructions on how You may appeal.

We shall provide information in response to Your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

Within a reasonable time, not to exceed sixty (60) days, after You have received a notice that We have declined to take action on Your request, You may appeal by sending Your appeal to Us at the email address [email protected] with the subject “VCPDA Appeal”. We shall respond to You within sixty (60) days of receipt of the appeal in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If We deny Your appeal, You may file a complaint with the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint or call (804) 786-2042.