GENERAL DATA PROTECTION REGULATION (GDPR)
GDPR Privacy Statement
Effective Date: May 25, 2018
www.DirectionalAlpha.com ("Directional Alpha") owns and operates this DirectionalAlpha.com website business. All references to "we", "us", or “our” shall be construed to mean Directional Alpha.
Directional Alpha will be acting as the “Controller” of the personal data you provide to us. This includes your personal contact information and the contact information of your affiliated organization. We only collect basic personal information about you which does not include any special types of information or location-based information (GPS data).
If you are an employee or other personnel of one of our customers which have entered into an agreement with us for the provision of our products or services, we will be acting as the “Processor” of your personal data which will be governed by our Data Processing Agreement. For more information, visit our Trust and Compliance Pages:
WHY WE NEED YOUR DATA
We need to know your basic personal data consisting of contact information for purposes of responding to your inquiry on our Contact Us section in our web page and similar web pages.
In addition, we need to know your personal data to send you emails for other specific purposes only if you have explicitly given your consent to receive these emails.
WHAT WE DO WITH YOUR DATA
Your personal data is processed by our personnel located in Maryland; however, for purposes of hosting and maintenance, your personal data may be archived on servers provided by Godaddy.com, which are located in 14455 North Hayden Road, Suite 219, Scottsdale, AZ, 85260, USA and by Paypal.com on servers which are located in 12312 Port Grace Blvd, La Vista, NE, 68128, USA. Except for these two sub-processors, we won’t share your personal information with third parties outside our organization unless authorized by applicable law.
If we are acquired by another party, we will share your personal data with the acquiring party.
We maintain a data protection regime for the effective and secure processing of your personal data. For more information, visit the following:
Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practices to ensure your data is encrypted to the standard required in the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.
HOW LONG WE KEEP YOUR DATA
We will not retain your personal data for longer than required. This means that we will keep your personal information: (i) for as long as required by law, (ii) until we no longer have a valid reason for keeping it, or (iii) until you request us to stop using it. When we delete your personal data from our databases, it will remain in our backup system until it cycles out.
We will delete your personal data that you provide for purposes of responding to your inquiry on our Contact Us web page and similar web pages after 1 year, unless you are continuing to request information from us.
WHAT ARE YOUR RIGHTS
You have right to: (i) request access to and rectification or erasure of your personal data, (ii) request restriction of processing your personal data, and (iii) withdraw your consent at any time. If you provide a notice to us regarding your exercise any of the above rights, we will forward your notice to other authorized parties which are holding and processing your personal data, where appropriate.
If you wish to raise a complaint regarding how we have processed your personal data, you can contact us with the Contact Us information below, and we will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you may complain to the data protection officer in the country in which you reside.
HOW TO CONTACT US
Effective Date: May 1, 2018
www.DirectionalAlpha.com (“Directional Alpha”) owns and operates this DirectionalAlpha.com website business. All references to "we", "us", “our”, this "website" or this "site" shall be construed to mean Directional Alpha.
Regarding Personal Data (defined below), if any modifications are materially less restrictive regarding our use or disclosure of the Personal Data previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information.
LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
We may process your Personal Data because:
· We need to perform a contract with you
· You have given us permission to do so
· The processing is in our legitimate interests and it’s not overridden by your rights
· For payment processing purposes
· To comply with the law
THE TYPES OF DATA WE COLLECT
"Personal Data" means data about a living individual who can be identified from those data (or from those data and other information either in our possession or likely to come into our possession).
Personal Data may include, but is not limited to:
· First name and last name
· Email address
· Phone number
· Business name
· Website URL
· Address, State, Province, ZIP/Postal code, City
· Any Personal Data you post on our website
· Any Personal Data you post on a social media platform
· Data about how you use our website
· Technical data such as your IP address, your login data, details about your browser, time zone settings and other technology on the devise you use to access our website
· Your marketing and communication preferences
· Any information that you directly provide to us whether through our contact form ,over the phone, by email or otherwise
· Geo-location data
· Cookies and Usage Data
Passively or Automatically Collected Data ("Usage Data").
We may also collect information regarding how our service is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Geo-Location Data. If you are accessing a page from a computer or a mobile device, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience when we work with a marketing partner such as a third-party service provider, advertiser, or advertising network and platform. If you agree to the collection of location data, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device.
HOW AND WHEN WE COLLECT DATA
Personal Data. We collect Personal Data on the public areas of our site through optin forms. We may collect publicly available Personal Data posted publicly with social media profile information.
Your Communications with Us. We collect your Personal Data on the public areas of this site if you complete any of our optin and/or contact forms and/or participate in our follow-up.
Usage Data. We collect Usage Data as you use the public areas of this site, including your interactions with emails we send, and via social media platforms, and services of our marketing partners. This data may be passively or automatically collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies, web beacons, locally stored objects, and mobile device identifiers and SDKs, and other similar methodologies as well as similar technologies developed in the future. (See below, SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS.)
HOW WE USE YOUR DATA
We may use your Personal Data collected from the public areas of this site if you complete any of our optin forms and/or participate in our follow-up.
We may use publicly available Personal Data posted on social media profile information including photos for purposes of assisting us, and our marketing partners with marketing and advertising activities and with contact management.
RETENTION OF DATA
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.
TRANSFER OF DATA
We are located in the United States. Your submission of your Personal Data via this website will transfer your Personal Data to us. We will not transfer your Personal Data outside the United States unless the transfer is made to a country or territory recognized by the EU as having an adequate level of data security, or is made with your consent, or is made to satisfy our legitimate interest regarding our contractual arrangements with our subscribers that have contracted for access and use of our online services.
DISCLOSURE OF DATA
General Disclosure Policy. We may share and disclose your Personal Data as described below.
Affiliated Entities. We may provide your Personal Data and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.
Service Providers. We may provide access to your Personal Data and Usage Data to our trusted service providers that assist us with the operation and maintenance of this site. For example, we may contract with third parties to host our servers, provide security, and optimization, analytics, reporting, and software maintenance and development services. In addition, our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.
Legal Process, Enforcement and Security Notice. We may disclose your Personal Data and Usage Data if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity, and (iii) to investigate, respond to, or enforce violations of our rights or the security of this site.
Marketing Partners. We may share your Usage Data with our marketing partners to serve and offer personalized ads. We may share Personal Data with our marketing partners to correlate and match our list with our marketing partners' lists for purposes of creating an "audience" for serving personalized ads.
With Your Consent. We may share your Personal Data with other parties with your consent.
YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
· The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
· The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
· The right to object. You have the right to object to our processing of your Personal Data.
· The right of restriction. You have the right to request that we restrict the processing of your personal information.
· The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
· The right to withdraw consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the
European Economic Area (EEA).
SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS
"Cookies" are tiny pieces of information stored by your browser on your computer's hard drive. Cookies are also used to customize content based on your browser. Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our site.
Flash Cookies - third party cookies that use an Adobe Flash Media Player local shared object (LSO) - may be used along with other third-party cookies for purposes of crediting any purchase you may make on this site to one of our joint venture partners that may have referred you to us. These cookies will be used for purposes of crediting sales to the referring joint venture marketing partner. Flash cookies are not the same as "browser cookies". The Adobe Flash Media Player is software that enables users to view content on their computers. Flash cookies are also accompanied by a browser cookie. If you delete the browser cookie, the Flash cookie may automatically create (or re-spawn) a replacement for the browser cookie.
Web Beacons (sometimes called single-pixel gifs or clear gifs) are used to assist in delivering cookies, and they allow us to count users who have visited pages of our site. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.
Locally Stored Objects – we may employ locally stored objects ("LSOs") and other client-side storage tracking technologies in certain situations where they help to provide a better user experience, such as to remember settings, preferences and usage similar to browser cookies, or in order to target or help our Partners target ads, analyze ad performance, or perform user, website or market analytics. For LSOs utilized by Adobe Flash you can access Flash management tools from Adobe's website: --> http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html . In addition, some, but not all browsers, provide the ability to remove LSOs, sometimes within cookie and privacy settings.
We may participate with our marketing partners for purposes of providing personalized ads based on your interests. This activity is performed by collecting Usage Data and by using cookies and other tracking and data collection methodologies discussed above to transfer information to our marketing partners which manage advertising activities.
AdWords (Google) - We may participate in AdWords program which is a personalized ad service provided by Google Inc. that connects the activity of this site with the Adwords advertising network and the Doubleclick cookie. Information collected: cookie and Usage Data. For the opt-out, visit --> https://support.google.com/ads/answer/2662922?hl=en
Google Analytics for Display Advertising (Google) - We may participate in any and all of the following Google Analytics Advertising Features provided by Google: Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features use first party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google Analytics and its cookies with the Adwords advertising network and the DoubleClick cookie (a third-party cookie). Information collected: cookie and Usage Data, including audience data such as age, gender, and interests. For the opt-out, visit --> https://support.google.com/ads/answer/2662922?hl=en You may opt-out of the Google Analytics service with the Google's Browser Add-on that's available at --> https://tools.google.com/dlpage/gaoptout
For information in general about Google's personalized ad campaigns, and specifically about information regarding DoubleClick cookies and how to control and manage Google's advertising cookies for these campaigns, visit --> http://www.google.com/policies/technologies/ads/
For information regarding how Google uses data when you use Google's partners' sites or apps, visit --> http://www.google.com/policies/privacy/partners/
Custom Audience (Facebook). We may participate in Facebook.com's Custom Audience program which enables us to display personalized ads to persons on our email lists when they visit Facebook.com. We provide Personal Data such as your email address and phone number to Facebook to enable Facebook to determine if you are a registered account holder with Facebook. You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to the email address provided in our contact information below. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email - "Opting Out of Facebook.com Website Custom Audience Ads", and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.
Tailored Audiences/Conversion Tracking Programs (Twitter). We may participate in Twitter.com's Tailored Audiences/Conversion Tracking Programs which enable us to display personalized ads. You may opt-out of participation in these programs by visiting https://support.twitter.com/articles/20170405 .
Other Personalized and Behavioral Advertising services. We may participate in additional retargeting and behavioral advertising services that will be similar to the services described above.
Managing Personalized Ads. You can control the placement of cookies and other data collection methodologies for purposes of opting out.
Managing Cookies via Your Browser. You should note that although most browsers are initially set up to accept cookies, you may be able to change your browser settings to cause your browser to refuse first party or third-party cookies or to indicate when a third-party cookie is being sent. However, disabling or limiting cookies may cause certain features of this website to not function properly or optimally. Check your browser's "Help" files or other similar resources to learn more about handling cookies on your browser. In addition, visit --> http://www.allaboutcookies.org/manage-cookies/
Managing Flash Cookies. Flash cookies, also called local shared objects (LSOs), function similarly to standard cookies except that they are often larger and are downloaded to a computer or mobile device by the Adobe Flash Player. In some cases, these Flash cookies can be managed through browser settings. Adobe also provides a means of controlling Flash cookies on its Flash Player: Setting Manager page.
Digital Advertising Alliance (DAA). DAA member advertising associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties, please visit DAA Consumer Opt-Out page --> http://www.aboutads.info/consumers.
Opting Out with Ad Choices for Mobile Devices. When using mobile applications you may receive personalized in-application advertisements. Depending on your device, you may be able to reset your mobile device's advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of personalized in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of these advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.
We may participate with third party analytics partners to monitor and analyze Web traffic and to keep track of user behavior on this site.
DO NOT TRACK REQUESTS
Some Web browsers incorporate a "Do Not Track" feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates "Do Not Track" signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to "Do Not Track" signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor "Do Not Track" signals and may make changes to our policy.
We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect data from unauthorized access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Data by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive at this site.
UPDATING PERSONAL DATA
Upon request, we will permit you to request or make changes or updates to your Personal Data for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We reserve the right to permit you to access your Personal Data in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian who has discovered that your child under the age of 18 has submitted his or her Personal Data without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child's information, please contact our site as provided below under "Contact Us", and be sure to include in your message the same login information that your child submitted.
Your California Privacy Rights. Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to the email address provided in our contact information below and include the phrase "California Privacy Request" in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. We will respond to you within thirty days of receiving such a request.
Directional Alpha Processors and Sub-processors
A list of Processors and Sub-processors currently authorized by www.DirectionalAlpha.com (“Directional Alpha”) to process Customer Data and assist Directional Alpha with respect to the provision of the applicable Services under the Directional Alpha customer agreement is set out below. Your personal data is processed by us in the United States of America (USA). In case of travels, we access the data remotely. For purposes of hosting and maintenance, payments, electronic payments, Email Marketing Services, Email Management Services, Social Media Services, Affiliate Marketing Services, your personal data may be archived on servers provided by:
- GoDaddy.com, LLC or GoDaddy.com which are located in Corporate Headquarters 14455 N. Hayden Rd., Ste. 226. Scottsdale, AZ 85260 USA. Phone number: +1 (480) 505-8800. Fax number: +1 (480) 624-2546. Website: https://www.godaddy.com
Description: Website Hosting, Website Domain management, Email Management and Marketing, Secure Sockets Layer - SSL Certificates, Website Security Services, and Internet Management Services, WordPress Services and Management.
- The Rocket Science Group LLC d/b/a MailChimp or www.MailChimp.com. 675 Ponce de Leon Ave NE, Suite 5000. Atlanta, GA 30308. USA. Website: https://mailchimp.com/
Description: Email Marketing, Email List Building, Contact Forms, Pop-up Forms, Mat Forms, Email collection, and related Email, Traffic Tracking, Website Traffic related Software Company.
- Zoho Corporation or www.Zoho.com . 4141 Hacienda Drive. Pleasanton, California 94588, USA. Website: https://www.zoho.com/
Description: Email Marketing, Email List Building, Contact Forms, Pop-up Forms, Mat Forms, Email collection, and related Email, Traffic Tracking, Website Traffic related Software Company.
- Sumo Group Inc. (d/b/a “AppSumo”,”Sumo”,”Sumo.com”) 1305 E. 6th St #3. Austin, TX 78702. USA. Website: https://sumo.com/
Description: Email Marketing, Email List Building, Contact Forms, Pop-up Forms, Mat Forms, Email collection, and related Email, Traffic Tracking, Website Traffic related Software Company.
- Zoom Video Communications, Inc. San Jose Headquarters55 Almaden Boulevard, 6th Floor, San Jose, CA, USA. Website: https://zoom.us/
Description: Online Meetings, Training & Technical Support, Video Webinar Marketing Events & Town Hall Meetings, Conference Rooms Build Collaboration-Enabled Conference Rooms, Zoom Phone Services, Business IM Cross-Platform Messaging & File Sharing.
- Shopify Inc or www.Shopify.com. 150 Elgin Street, Suite 800. Ottawa, ON K2P 1L4. Canada. Website: https://www.shopify.com/
Description: E-commerce, Online Payment, and related e-commerce and affiliate marketing software Company.
- Stripe. 185 Berry Street, Suite 550. San Francisco, CA 94107. USA. Website: https://stripe.com/
Description: Online Payment, processing and related E-Commerce software Company.
- PayPal, Inc. or www.paypal.com. 2211 North First Street San Jose, California 95131. USA. Website: https://www.paypal.com/
Description: Online Payment, processing and related E-Commerce software Company.
- Dropbox, Inc. or Dropbox International Unlimited Company or www.Dropbox.com. Address: 333 Brannan Street. San Francisco, CA 94107. USA. Website: https://www.dropbox.com/
Description: Online data and information storage services, online users’ collaboration services, and data processing and analysis related services.
- Amazon.com, Inc. or Amazon Services LLC or Amazon’s website www.Amazon.com or any of its affiliate companies. Amazon.com, Inc. P.O. Box 81226. Seattle, WA 98108-1226. Website: https://www.amazon.com/
Description: Affiliate Marketing, Merchandise, Products, Services, Online Payments, and related e-Commerce Company/Services.
- Printful Inc. or www.Printful.com . Printful, Inc. 11025 Westlake Dr, Charlotte, NC, 28273, USA
Description: Print-on-Demand (P.O.D.) products.
- Udemy, Inc. www.udemy.com. 600 Harrison St. 3rd Floor. San Francisco, CA 94107. USA. Website: https://www.udemy.com/
Description: Online Learning Management System Services, Online Courses and Classes Delivery System, Online Payment and Management System, Online Tracking traffic services.
- WordPress.com and/or WordPress.com and/or Automattic Inc. 60 29th Street #343. San Francisco, CA. 94110. USA. Website: https://wordpress.com/ , https://wordpress.org/
Description: Web Blog and website hosting and Traffic Online Platform
- Google LLC. Or www.Google.com. 1600 Amphitheatre Parkway. Mountain View, CA 94043. USA. Website: https://about.google/ , https://www.google.com/
Description: Website, traffic, tracking, data analysis, data analytics, Data Analysis and Management, Video services, Music & Video Management and streaming services, Website tracking and related website information, email services, and online tools, e-commerce, data online storage services, online users collaboration services, and data processing and analysis related services.
which are located in the USA, Canada, the EU and/or other locations where each Processor and/or of their designated Sub-Processor(s) operates. If we are acquired by another party, we will share your personal data with the acquiring party.
How to Subscribe to Receive Notification of Change in Sub-processors:
If you are a current Directional Alpha customer with a Data Processing Agreement in place with Directional Alpha, you may subscribe to receive notifications of new Sub-processor(s) for each applicable Directional Alpha Service before Directional Alpha authorizes any new Sub-processor(s) to process personal data in connection with the provision of the applicable Service.
You can subscribe to receive email notifications for changes to Directional Alpha Sub-processors by emailing the following information to info@DirectionalAlpha.com:
· Customer Name
· Customer Address
· Executed copy of the Customer-Directional Alpha Data Processing Agreement
To edit your email notification information, please re-submit a request to info@DirectionalAlpha.com with the title “Change in Contact Information”.
Right to Object to New Sub-processor:
A Customer with a Data Processing Agreement in place with Directional Alpha may object to Directional Alpha’s use of a new Sub-processor by notifying Directional Alpha promptly in writing within ten (10) business days after receipt of Directional Alpha’s notice in accordance with the mechanism set out above.
If you object to a new Sub-processor, and that objection is not unreasonable, Directional Alpha will use reasonable efforts to make available to you a change in the applicable Service or recommend a commercially reasonable change to your configuration or use of the applicable Service to avoid processing of personal data by the objected-to new Sub-processor without unreasonably burdening you.
If Directional Alpha is unable to make available such change within a reasonable period of time, which shall not exceed thirty (30) days, you may terminate the applicable Order form(s) or customer agreement with respect only to those Service(s) which cannot be provided by Directional Alpha without the use of the objected-to new Sub-processor by providing written notice to Directional Alpha at:
10411 Motor City Drive, Suite 750
Bethesda, Maryland, 20817
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: May 1, 2020
Last Reviewed on (prior effective date): May 1, 2020
INFORMATION WE COLLECT
Our website collects 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 or device ("Personal Information").
In particular, we indicate below the categories of Personal Information collected from California residents within the last twelve (12) months.
CATEGORY A: Identifiers
Examples: A real name, Internet Protocol address, email address, or other similar identifiers.
CATEGORY B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
CATEGORY C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
CATEGORY D: Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
CATEGORY E: Biometric information.
Examples: 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.
CATEGORY F: Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
CATEGORY G: Geolocation data.
Examples: Physical location or movements.
CATEGORY H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
CATEGORY I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
CATEGORY J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: 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.
CATEGORY K: Inferences drawn from other Personal Information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
* Publicly available information from government records.
* De-identified or aggregated consumer information.
* Information excluded from the CCPA's scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
* Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We collect 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).
USE OF PERSONAL INFORMATION
We may use, or disclose the Personal Information we collect for one or more of the following business purposes (a business purpose is defined as “the use of Personal Information for the business’s or a service provider’s operational purposes, or other notified purposes, provided that the use of Personal Information shall be reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed or for another operational purpose that is compatible with the context in which the Personal Information was collected”):
* To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
* To provide, support, personalize, and develop our website, products, and services.
* To create, maintain, customize, and secure your account with us.
* To process your requests, purchases, transactions, and payments and prevent transactional fraud.
* To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
* To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and retargeted ads through our website, third-party sites, and 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, and business.
* 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.
In case, we collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes, we notify you beforehand asking for your approval.
SHARING AND DISCLOSURE OF PERSONAL INFORMATION - THIRD PARTIES
We may share your Personal Information with a third party for a business 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.
We share your Personal Information with the following categories of third parties:
* Affiliated entities
* Service providers
* Legal Process
* Joint venture partners
* Marketing partners including third party service providers, advertisers, advertising networks, and advertising agencies
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE - CATEGORIES
In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose:
* Category A: Identifiers.
* Category B: California Customer Records Personal Information categories.
* Category D: Commercial information.
* Category F: Internet or other similar network activity.
SALES OF 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.
Access to Specific Information and Data Portability Rights
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 (see EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS), we will disclose to you:
* The categories of Personal Information we collected about you.
* The categories of sources for the Personal Information we collected about you.
* Our business or commercial purpose for collecting or selling that Personal Information.
* The categories of third parties with whom we share that Personal Information.
* The specific pieces of Personal Information we collected about you (also called a data portability request).
* If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS below), 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 if retaining the information is necessary for us or our service provider(s) to:
* Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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 by either:
* Calling us or emailing us with the contact information described below under CONTACT US.
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 also make a verifiable consumer request on behalf of your minor child.
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 we collected Personal Information or an authorized representative.
* Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with 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. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For instructions on exercising sale opt-out rights, see PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS below.
RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within forty-five (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.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. 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 readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
PERSONAL INFORMATION SALES OPT-OUT and OPT-IN RIGHTS
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us (see our CONTACT INFORMATION below).
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by visiting our website and sending us a message. We will only use Personal Information provided in an opt-out request to review and comply with the request.
OTHER CALIFORNIA PRIVACY RIGHTS
California's "Shine the Light" law (Civil Code Section § 1798.83) 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 contact us with the CONTACT US information below.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice's effective date. YOUR CONTINUED USE OF OUR WEBSITE FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE OF SUCH CHANGES.
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