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Important Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information
You can request the following information about how we have collected and used your Personal Information during the past 12 months:

  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share 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 third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient. 

Access
You can request a copy of the Personal Information that we have collected about you during the past 12 months.

Deletion
You can ask us to delete the Personal Information that we have collected from you.

Opt-out of sales
If we sell your Personal Information, you can opt-out.  In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

Opt-in
If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights. 

How to exercise your rights

You may exercise your California privacy rights described above as follows:

Right to information, access and deletion 
You can request to exercise your information, access and deletion rights by:

Right to opt-out of the “sale” of your Personal Information
We do not sell your Personal Information in the conventional sense (i.e., for money).  However, like many companies, we use services that help deliver interest-based ads to you.  California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you.    You can request to opt-out out of this “sale” of your personal information here by calling our toll-free number or sending an email to the above listed addresses.    

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

Statutory category of personal information (PI) Source of the PI Purpose for collection Categories of third parties to whom we “disclose” the PI for a business purpose Categories of third parties to whom we “sell” the PI
Identifiers ·  You
·  Public sources
·  Business partners
·  Our clients  
·  Service delivery
·  Research & development
·  Marketing
·  Compliance & Operations
·  Affiliates
·  Advertising partners
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
None
Commercial Information ·  You
·  Our clients  
·  Service delivery
·  Research & development
·  Marketing
·  Compliance & Operations
·  Affiliates
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
None
Financial Information ·  You
·  Public sources
·  Business partners
·  Our clients  
·  Service delivery
·  Research & development
·  Marketing
·  Compliance & Operations
·  Affiliates
·  Advertising partners
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
None
Online Identifiers ·  You
·  Our clients  
·  Service delivery
·  Research & development
·  Marketing
·  Compliance & Operations
·  Affiliates
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
·  Advertising partners (to facilitate online advertising)  
Internet or Network Information ·  You
·  Automatic collection
·  Service delivery
·  Research & development
·  Marketing
·  Compliance & Operations
·  Affiliates
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
·  Advertising partners (to facilitate online advertising)  
Geolocation Data ·  You
·  Automatic collection
·  Service delivery
·  Research & development
·  Marketing
·  Compliance & Operations
·  Affiliates
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
·  Advertising partners (to facilitate online advertising)  
Sensory Information ·  You
·  Collection
·  Service delivery
·  Research & development
·  Marketing Compliance & Operations
·  Production promotion
·  Use on social media
·  Affiliates
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
·  Advertising partners (to facilitate online advertising)  
Inferences ·  You
·  Collection
·  Service delivery
·  Research & development
·  Marketing
·  Compliance & Operations
·  Production promotion
·  Use on social media
·  Affiliates
·  Service-related third parties
·  Professional advisors
·  Authorities and others
·  Business transferees
·  Advertising partners (to facilitate online advertising)
·   
Glossary
Statutory category Definition (categories may overlap) What we collect
Commercial Information Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.   ·  Contact data
·  Identity data
·  Transaction data
·  Communications
·  Marketing data
Financial Information Financial Information Bank account number, debit or credit card numbers, insurance policy number, and other financial information. ·  Financial data  
Geolocation Data Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data.  
Identifiers Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. ·  Contact data
·  Identity data
·  Data about others
Inferences Inferences The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. May be derived from your:
·  Device data
·  Online activity data
Internet or Network Information Internet or Network Information Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement. ·  Device data
·  Online activity data
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device. ·  Device data
·  Identity data
Sensory Information Audio, electronic, visual, thermal, olfactory, or similar information. ·  Pictures and videos