The Company collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). For clarity, Personal Information does not include:
- Publicly available information from governmental records.
- De-identified or aggregated consumer information.
In particular, the Company may collect the following categories of Personal Information from our consumers:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (Abridged)
A name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
The Company may obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
Disclosures of Personal Information for a Business Purpose
In the preceding 12 months, Company has disclosed the following above Categories of Personal Information for a business purpose:
- Category A: Identifiers
- Category B: California Customer Records Personal Information categories
- Category C: Commercial information
- Category D: Internet or other similar network activity
Use of Personal Information
The Company may use or disclose the Personal Information the Company collects for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, the Company will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, the Company will use that information to process your payment and facilitate delivery. The Company may also save your information to facilitate new product orders or process returns.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments.
- To provide you with support, respond to your inquiries, address your concerns, and monitor and improve our responses.
- To personalize your Website experience and to deliver content, product, and service offerings relevant to your interests, including targeted offers via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.
The Company will not collect additional categories of Personal Information or use the Personal Information the Company collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
The Company may disclose your Personal Information to a third party for a business purpose. When the Company discloses Personal Information for a business purpose, it enters 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.
The Company may share your Personal Information with the following categories of third parties:
- Service providers.
- Parent or subsidiary organizations
The Company may disclose your Personal Information for a business purpose to the following categories of third parties:
- Service providers.
- Parent or subsidiary organizations
Sales of Personal Information
In the preceding 12 months, Company has not sold Personal Information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Federal law may also provide you with similar rights.
Access to Specific Information and Data Portability Rights
You have the right to request that the Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once the Company receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), the Company will disclose to you:
- The categories of Personal Information collected about you.
- The categories of sources for the Personal Information collected about you.
- The business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom that Personal Information is shared.
- The specific pieces of Personal Information collected about you (also called a data portability request).
- If your Personal Information is disclosed for a business purpose, disclosures identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that the Company delete any of your Personal Information that it collected from you and retained, subject to certain exceptions. Once the Company receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), it will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
The Company may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which the Personal Information was collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
- 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using the Contact Information located at the end of this Policy.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, you must provide a valid power of attorney under California’s Probate Code or other verifiable written documentation granting the agent permission to make the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom the Company collected Personal Information or an authorized representative, which may include:
- For password-protected account holders, you can access our secure request form by logging into your account and using the submission form link.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
The Company cannot respond to your request or provide you with Personal Information if it 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. However, the Company does consider requests made through your password protected account more easily verifiable when the request relates to Personal Information associated with that specific account.
The Company 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
The Company endeavors to respond to a verifiable consumer request within 45 days of its receipt. If it requires more time (up to an additional 45 days), you will be informed of the reason and extension period in writing.
Any disclosures the Company provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response it provides will also explain the reasons it cannot comply with a request, if applicable. For data portability requests, it will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
The Company does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If it is determined that the request warrants a fee, the Company will tell you why it made that decision and provide you with a cost estimate before completing your request.
The Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, the Company will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, the Company may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive it offers will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights
The Company does not generally engage third parties for direct marketing purposes. However, it provides notice here of California’s “Shine the Light” Law (Civil Code Section § 1798.83), which permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email with the subject “Shine the Light Law Request” to the email address listed below under Contact Information.
Changes to Our Privacy Notice
The Company reserves the right to amend this Policy notice at our discretion and at any time. When it makes changes to this Policy, it will post the updated notice on the Website and update the notice’s effective date. Your continued use of this Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which the Company collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
THIS POLICY WAS LAST UPDATED: APRIL 27, 2021