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Do Not Sell My Information

Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes.

California Residents

The California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et. seq. (“CCPA”), requires that we provide California residents with a privacy notice that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is publicly available, deidentified or aggregate information. For purposes of this “California Residents” section, we will refer to this information as “Personal Information.”

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

(i) Right to Know About Personal Information Collected, Disclosed, or Sold

Your Right

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you. This right includes the right to request any or all of the following:
Specific pieces of Personal Information that we have collected about you;
Categories of Personal Information we have collected about you;
Categories of sources from which the Personal Information was collected;
Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
The business or commercial purpose for collecting or, if applicable, selling Personal Information.
How to Submit a Request to Know

You may submit a request to us.

Our Process for Verifying a Request to Know

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us. We will verify your identity as follows:

Request to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

Request to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Collection of Personal Information

The below table presents the categories of Personal Information that we have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we shared that Personal Information for the 12 months preceding the “Last revised” date of this Privacy Notice.

The CCPA defines “business purposes” to mean:

  1. Auditing related to a current interaction with the consumer and concurrent transaction, including, but not limited to, counting ad impressions to unique visitors;
  2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  3. Debugging to identify and repair errors that impair existing intended functionality;
  4. Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  5. Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
  6. Undertaking internal research for technological development and demonstration; and
  7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device.

The CCPA defines “commercial purposes” to mean “to advance a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.”

Categories of Personal Information Collected Categories of Sources from which Personal Information was collected Business or Commercial Purpose for the Collection Categories of Third Parties with whom We Share Personal Information
Name Consumer (1), (2), (3), (5), (6), (7), & (8)  

  • Data analytics provider
  • External marketing entity
  • Social network
  • Advertising network
Email Address Consumer (1), (2), (3), (5), (6), (7), & (8)
  • Business partners / affiliated companies
  • Data analytics provider
  • External marketing entity
  • Social network
  • Advertising network
Postal Address Consumer (1), (2), (3), (5), (6), (7), & (8)  

  • Data analytics provider
  • External marketing entity
  • Advertising network
Telephone Number Consumer (1), (2), (3), (5), (6), (7), & (8)  

  • Data analytics provider
Credit card and debit card number Consumer (2) and (5)
  • N/A
Records of products or services purchased, obtained or considered Consumer (5), (6), (7), & (8)
  • Business partners / affiliated companies
  • Data analytics provider
  • External marketing entity
  • Social network
  • Advertising network
Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology Consumer (1), (2), (3), (5), (6), & (8)  

  • Data analytics provider
  • External marketing entity
  • Social network
  • Advertising network
Customer number Consumer (1), (2), (3), (5), & (7) N/A

 

The following is a list of categories of Personal Information that we have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

Name
Account name
Email address
Postal address
Telephone number
Professional or employment-related information
Records of products or services purchased, obtained or considered
Geolocation data
Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology
Education information
Inferences drawn from above information to create a profile about consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Purchasing or consuming histories or tendencies
We do not knowingly or intentionally collect or sell the Personal Information of minors under 16 years of age.

(ii) Right to Request Deletion of Personal Information

Your Right

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain. However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request to Delete

You may submit a request to delete by please contact us as stated above under the section Contacting Us.

If you submit a request to delete online, you will be asked to confirm separately that you want your Personal Information deleted.

Our Process for Verifying a Request

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us. We will verify your identity as follows:

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion.

We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

If we are unable to verify your identity to the applicable standard, we will treat your request to delete as a request to opt-out of the sale of the personal information that you provided as part of processing the request to delete. See the following section for a description of the right to opt-out of the sale of personal information.

(iii) Notice of Right to Opt-Out of Sale of Personal Information

Your Right

If you are a California resident, you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Opt-Out

You may submit a request to opt-out of sales by please contact us as stated above under the section Contacting Us.

How We Process a Request to Opt-Out

We will act upon your request to opt-out within 15 days from the date that you submit the request. The CCPA does not require that we verify the identity of individuals who submit requests to opt-out of sales. However, we may deny the request if we have a good-faith, reasonable, and documented belief that the request is fraudulent. If we deny the request on this basis, we will notify the requesting party and provide an explanation why we believe the request is fraudulent.

(iv) Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section California Residents. As such, we will not deny goods or services to that California resident; 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 the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

California residents may use an authorized agent to submit a request to know, delete, or opt-out of sales on your behalf.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission and (2) you verify your identity directly with us. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

If you use an authorized agent to submit a request to opt-out of sales, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in the statute). To make such a request, please send an email to us or by contacting us as stated above under the section Contacting Us.

Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as stated above under the section Contacting Us.

Changes

We may update this Privacy Notice from time to time. We will notify you of any such changes, including when they will take effect, by updating the “Last revised” date above or as otherwise required by applicable law.

Last Revised Date: January 2020

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