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CCPA Policy And Rights

Effective January 1, 2020, you may, in accordance with the California Consumer Privacy Act (the “CCPA”):

If you are a California resident, you have the following rights:

Information.  To request that we disclose the following information about our collection and use of your personal information during the past 12 months:

  • The categories of personal information that we have collected about you;
  • The categories of sources from which personal information is collected;
  • The business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share your personal information;
  • Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient; and
  • Whether we have sold your personal information, and, if so, the categories of personal information received by each category of recipient.

Access.  To request a copy of the personal information that we have collected about you during the past 12 months.

Deletion.  To request that we delete personal information about you that we have collected from you.

Opt out of sales.  To direct us not to sell your personal information if we do, and if you are under 16 years of age, we are required to ask for affirmative authorization from you (or it you are under 13, your parent or guardian) to sell your personal information before we do so.

Nondiscrimination. To exercise your rights described above free from discrimination, such as denial of goods or services; price/rate increases for goods or services (including through grants of discounts/benefits or imposing penalties); decreases in service quality; or suggesting that such discriminatory acts may occur if you exercise your rights.  However, a difference in price or service quality is not discriminatory if reasonably related to the value to our business of the personal information we are unable to use due to the exercise of your rights, and we may offer you certain financial incentives that can result in different prices, rates or service quality.

Financial incentive program disclosures.  Receive a clear description of the material terms of any program involving financial incentives for the collection, sale or deletion of your personal information, and decide if you want to consent to be entered in it (you can revoke this consent at any time).

How to Exercise Your Rights.

You may exercise the rights described above as follows:

  • Right to opt out of sales

To exercise your right to opt out of sales, please submit a verifiable request by:

You may exercise the information, access and deletion rights described above by submitting a verifiable request to us by:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child under 13.

The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are a California resident about whom we collected personal information or their authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

These rights are not absolute, are subject to exceptions, and we may be required or permitted by law to decline your request.

Personal Information That We Collect, Use, and Share

The chart below provides information that we are required to give you under California law about the categories of personal information that we have collected, used and shared in the preceding 12 months.  See above for a description of the sources of the personal information we collect, as well as the business and commercial purposes for which we collect, use and share this information.

 

Categories of Third Parties to Whom the Personal Information May Be Sold:

Categories of Personal Information Sold

Advertising companies (like ad servers, advertising agencies, technology vendors, providers of sponsored content, email software providers and others)

  • Identifiers
  • Device and online identifiers
  • CA customer records categories
  • Commercial information
  • Internet or Network information
  • Purchase history information including Commercial Information
  • Demographic information
  • Financial information
  • Inferences
  • Protected Classification Characteristics
  • Other Personal Information

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