Version: 1.0
Date of last update: October 17, 2023
The following applies to you only if you are a California resident.
Please note the following:
Information We Collect From California Consumers
We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal Information does not include:
Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers. Some of the categories may overlap with each other:
| Category of Personal Information | Examples | Collected |
|---|---|---|
| A. Identifiers | A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number | YES |
| B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e)) | All of the Identifiers listed above, plus: Signature, social security number, bank account number, credit card number, debit card number, or any other financial information (as through our third-party payment processor, as applicable) | YES |
| C. Legally Protected Characteristics | Age (40 years or older) | YES |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | YES |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or similar network activity | Browsing history, search history, information regarding a consumer's interaction with a website, mobile application, or online advertisement | YES |
| G. Geolocation data | Physical location or movements | YES |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information | NO |
| I. Employment information | Professional or employment-related information | NO |
| J. Education information, defined as non-public personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records | NO |
| K. Inferences drawn of other categories of Personal Information | A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | YES |
We obtain the categories of Personal Information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We may also use or disclose the Personal Information we collect for the following commercial purpose: to advance our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business and/or commercial purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories
Category C: Legally Protected Characteristics
Category D: Commercial information
Category F: Internet activity
Category G: Geolocation data
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a commercial purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories
Category D: Commercial information
Category F: Internet activity
We disclose your Personal Information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have not sold any Personal Information for monetary consideration. We do, however, disclose information for a commercial purpose by working with companies to deliver advertisements to you across the Internet. If you do not wish to have your Personal Information used for this purpose, please email [email protected].
Your Rights and Choices
The California Consumer Privacy Act (“CCPA”) provides consumers who are California residents with specific rights regarding their Personal Information. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit an email request to the following email address: [email protected] and include the words “CALIFORNIA PRIVACY” in the subject line, and you must put the statement “Your California Privacy Rights” in the body of the request and state the name of our specific website with respect to which you are requesting the information as well as your name, street address, city, state, and zip code.
Right to Know About Personal Information Collected, Disclosed, or Sold
As a California consumer, you have a right to request what Personal Information we collect, use, disclose, and sell.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request as described below, we will disclose to you:
In addition, if we sold or disclosed your Personal Information for a business purpose, we will provide you with two separate lists disclosing:
Right to Request Deletion of Personal Information
As a California consumer, you have the right to request that we delete any or all of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request to delete your Personal Information if retaining the Personal Information is necessary for us or our service providers to:
Right to Opt-Out of the Sale of Personal Information
As a California consumer, you have the right to opt-out of the sale of your Personal Information. If you would like to opt-out of the sale of your Personal Information, please email [email protected] including Opt-Out of the Sale in the subject line.
Right to Non-Discrimination if You Exercise any of Your Rights
As a California consumer, you have the right not to be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your California rights, we will not:
How to Exercise Your Rights to Know and to Delete
To exercise your rights to know and/or to delete described above, please submit a verifiable consumer request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with your Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We will confirm receipt of your verifiable consumer request within ten (10) days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding our receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is useable and should allow you to transmit the information from one entity to another entity.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Grievances and Complaints
Under California Civil Code Section 1789.3, residents of California who use this Website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at [email protected].
Contact for More Information
If you have any questions or concerns about our Privacy Policy or this Notice regarding your privacy or Personal Information, please contact us at [email protected].
