Privacy Policy

Last updated: December 16, 2024

Thank you for visiting tuliplable.com (the “Site”). The Site and its owners, officers, directors, members, employees, agents, and representatives are collectively incorporated into and included in any reference to the Site, “Us”, “Our”, and/or “We” herein. Each party is individually referred to herein as a “Party” and collectively as the “Parties.”

You must be at least 18 years old to use the Site.  

We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on how and why We collect, store, use, and share your personal information when you use the Site. It also explains your rights in relation to your personal information and how to contact Us.

By accessing and using the Site, you explicitly agree, without limitation or qualification, to this Privacy Policy and Our Terms & Conditions. If you disagree with the way We collect and process your personal information, please do not use the Site.

Personal Information We Collect About You

We have collected personal information about individuals in the preceding twelve (12) months, as noted here:

 

Categories of (PI)

Categories of Sources from which the Personal Information is collected from?

Business Purpose

 

Length of Retention

 

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers), or information that identifies, relates to, describes, or is capable of being associated with, a particular individual

 

 

 

☐ not applicable (not collected)

☒ Consumer directly;

☒ Advertising networks;

☐ ISPs;

☐ Data analytics providers;

☐ Gov’t entities;

☐ Operating systems and platforms;

☐ Social networks;

☒ Data brokers;

☐ Other third parties

 

☐Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☐ Helping to ensure security and integrity;

 

☐ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☐ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Retained indefinitely unless requested to be removed.

Characteristics of protected classifications under California or federal law.

☒ not applicable

☒ not applicable

☒ not applicable

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

 

 

☐ not applicable (not collected)

☐ Consumer directly;

☒ Advertising networks;

☐ ISPs;

☐ Data analytics providers;

☐ Gov’t entities;

☐ Operating systems and platforms;

☐ Social networks;

☒ Data brokers;

☐ Other third parties

 

☐Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☐ Helping to ensure security and integrity;

 

☐ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☐ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Retained indefinitely unless requested to be removed.

Biometric information

☒ not applicable

☒ not applicable

☒ not applicable

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

 

 

☐ not applicable (not collected)

☐ Consumer directly;

☒ Advertising networks;

☐ ISPs;

☒ Data analytics providers;

☐ Gov’t entities;

☐ Operating systems and platforms;

☐ Social networks;

☒ Data brokers;

☐ Other third parties

☒Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☒ Helping to ensure security and integrity;

 

☒ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Retained indefinitely unless requested to be removed.

Geolocation data

☐ not applicable (not collected)

☐ Consumer directly;

☒ Advertising networks;

☐ ISPs;

☒ Data analytics providers;

☐ Gov’t entities;

☐ Operating systems and platforms;

☐ Social networks;

☒ Data brokers;

☐ Other third parties

 

☐Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☒ Helping to ensure security and integrity;

 

☐ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☐ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Retained indefinitely unless requested to be removed.

Audio, electronic, visual, thermal, olfactory, or similar information (sensory data)

☒ not applicable

☒ not applicable

☒ not applicable

Professional or employment-related information

☒ not applicable

 

☒ not applicable

☒ not applicable

Education information

☒ not applicable

☒ not applicable

☒ not applicable

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

☐ not applicable (not collected)

☐ Consumer directly;

☒ Advertising networks;

☐ ISPs;

☒ Data analytics providers;

☐ Gov’t entities;

☐ Operating systems and platforms;

☐ Social networks;

☒ Data brokers;

☐ Other third parties

 

☐Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☐ Helping to ensure security and integrity;

 

☐ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☐ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Retained indefinitely unless requested to be removed.

Sensitive personal information

 

 

☒ not applicable

☒ not applicable  

☒ not applicable

As noted in the chart above, We collect the above personal information directly from you via the Site, and from your interactions with the Site, including any personal information which you provide directly or indirectly; as well as through the third party sources noted above.

Indirectly 

Cookies and Tracking Pixels on the Site: We may use and store cookies and tracking pixels on the Site, as described further herein. A cookie is a small data text file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and which is stored on your computer’s web browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can later be retrieved to identify you to Us. Personal information that We store about you may be linked to the information stored in and obtained from cookies. Cookies make your use of the Site easier, make the Site run more smoothly, and help Us to maintain a secure Site. Tracking pixels (also known as web beacons, 1×1 pixels, or clear GIFs) are code requiring a call back to a server to render, and which deliver information to Us about your IP address and information from your browser. Cookies and tracking pixels are used to track your interaction with the Site. Cookies and tracking pixels may collect information about you, such as your IP address, your browser type and version, operating system, software and platform, your Internet service provider, geographic location, the area code and zip code associated with your server, time zone setting, the date and time of your visit, the time spent on the Site, referring and exit domain names and websites, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords, and clickstream data.  

You can instruct your web browser to refuse all cookies or to indicate when a cookie is being sent, by visiting the preferences or settings page of your web browser. In the event that your browser requests that We do not track you or store a cookie, unless otherwise required by law to honor the requests, We do not guarantee that the Site will honor such requests. Please note that We do not guarantee that the Site will work properly in the event that you elect to opt out of Our tracking or use of cookies.  

Cookies and Tracking Pixels in Our Emails: We and/or the applicable advertiser automatically collect information when an individual opens Our emails, through the use of cookies and tracking pixels. We and/or the applicable advertiser also automatically collect information on whether the individual clicked on any links included within Our emails. 

Directly

To the extent that you subscribe to receive email communications from Us through the Site, We collect the personal information you submit, including your name and email address. We use this information to send you email communications. We also collect information on whether you viewed the email and clicked on any links within such emails. If you do not want Us to communicate with you further, you may unsubscribe through the unsubscribe link featured in footer of such email; or via the Site by submitting an unsubscribe request through the Site; or by calling Us at the phone number listed on the Site and provide your email address in connection with your request to unsubscribe.

If you request to unsubscribe from receiving emails from Us, We will add your email address to our suppression file.  We may share your email address internally with Our parent company and any subsidiary and affiliated companies, to effectuate your request to unsubscribe and to comply with applicable laws. We do not share your information with any non-affiliated third parties. On occasion, We may be required by law enforcement or judicial authorities to provide information to the appropriate governmental authorities.

To the extent that you contact Us through the Site, and elect to submit your personal information, including your first name, last name, email address, and/or phone number, We collect the personal information which you submit. Further, to the extent that you elect to unsubscribe from receiving email communications from Us by unsubscribing through the Site, We collect your email address.

From Third Parties

As noted above in the chart, in addition to collecting personal information through the Site, We also collect personal information through third party advertising networks, data analytics providers, and data brokers.

Disclosure of Personal Information

 

We have disclosed personal information about individuals for a business purpose to third parties within the preceding twelve (12) months, as noted here:

 

Categories of Personal Information (PI)

Categories of Third Parties to Whom Such PI is Disclosed

Specific Business or Commercial Purpose for Disclosure

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers), or information that identifies, relates to, describes, or is capable of being associated with, a particular individual

☐ not applicable (not disclosed)

☐ direct lead buyers;

☐ email marketers/email marketing partners;

☒ email service providers;

☐ offline marketing partners;

☒ advertising networks;

☐ payment processors;

☒ data hygiene companies;

☐ ISPs;

☐ data analytics providers;

☐ gov’t entities;

☐ operating systems and platforms;

☐ social networks;

☐ data brokers;

☐ acquirer of assets;

☐ others

 

☒Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☒ Helping to ensure security and integrity;

 

☒ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Characteristics of protected classifications under California or federal law.

☒ not applicable (not disclosed)

☐ direct lead buyers;

☐ email marketers/email marketing partners;

☐ email service providers;

☐ offline marketing partners;

☐ advertising networks;

☐ payment processors;

☐ data hygiene companies;

☐ ISPs;

☐ data analytics providers;

☐ gov’t entities;

☐ operating systems and platforms;

☐ social networks;

☐ data brokers;

☐ acquirer of assets;

☐ others

 

☒ not applicable

 

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

☐ not applicable (not disclosed)

☐ direct lead buyers;

☐ email marketers/email marketing partners;

☒ email service providers;

☐ offline marketing partners;

☐ advertising networks;

☐ payment processors;

☐ data hygiene companies;

☐ ISPs;

☐ data analytics providers;

☐ gov’t entities;

☐ operating systems and platforms;

☐ social networks;

☐ data brokers;

☐ acquirer of assets;

☐ others

 

☐Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☐ Helping to ensure security and integrity;

 

☐ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☐ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Biometric information

☒ not applicable

☒ not applicable

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

☐ not applicable (not disclosed)

☒ direct lead buyers;

☐ email marketers/email marketing partners;

☒ email service providers;

☐ offline marketing partners;

☒ advertising networks;

☐ payment processors;

☐ data hygiene companies;

☐ ISPs;

☒ data analytics providers;

☐ gov’t entities;

☐ operating systems and platforms;

☐ social networks;

☐ data brokers;

☐ acquirer of assets;

☐ others

☐Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☐ Helping to ensure security and integrity;

 

☐ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☐ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Geolocation data

☐ not applicable (not disclosed)

☐ direct lead buyers;

☐ email marketers/email marketing partners;

☒ email service providers;

☐ offline marketing partners;

☐ advertising networks;

☐ payment processors;

☐ data hygiene companies;

☐ ISPs;

☐ data analytics providers;

☐ gov’t entities;

☐ operating systems and platforms;

☐ social networks;

☐ data brokers;

☐ acquirer of assets;

☐ others

☐Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

 

☐ Helping to ensure security and integrity;

 

☐ Debugging to identify and repair errors that impair existing intended functionality.

 

☐ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

☐ Undertaking internal research for technological development and demonstration.

☐ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Audio, electronic, visual, thermal, olfactory, or similar information

☒ not applicable

☒ not applicable

Professional or employment-related information

☒ not applicable

☒ not applicable

Education information

☒ not applicable

☒ not applicable

Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, etc.

☒ not applicable

☒ not applicable

Sensitive personal information

 

☒ not applicable (not disclosed)

 

☒ not applicable

 

Sale or Sharing of Personal Information

 

We have not sold or shared any personal information for a business purpose in the preceding 12 months. We do not have any actual knowledge of the sale of personal information of minors under 16 years of age.

 

In the event We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or Our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court. In the event of a merger, acquisition, or sale of Our business, We may disclose and transfer your information to a third-party who acquires any or all of Our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of Our assets.

Security 

Your personal information may be transferred to and maintained on computers located outside of your state, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Please note that the data We collect through the Site, may be processed in and outside of the United States and Canada. We will take all the steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and that no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data. Your consent to this Privacy Policy followed by your submission of such personal information represents your agreement to that transfer. 

We take strong precautions and measures to protect the security of your personal information and to ensure that your choices for its intended use are honored, and to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. The security of your data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your data, We cannot guarantee its absolute security. As a result, you acknowledge that there are security and privacy limitations of the Internet which are beyond Our control; the security, integrity and privacy of any and all information and data exchanged between you and Us through this Site cannot be guaranteed; and any such information and data may be viewed or tampered with in transit by a third party. We make no warranty, express, implied, or otherwise, regarding the security of the Site and your personal information.

Children

You must be an adult of 18 years or older to use the Site. We do not target the Site to children. Consistent with the federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), We will never knowingly collect personal information from anyone under the age of 13 without requesting parental consent.  If you are aware that your minor child under the age of 13 has provided Us with personal information, please contact Us.

Updates to Privacy Policy

This Privacy Policy was published and last updated as of the date indicated at the top. We may update this Privacy Policy and its sections from time to time. Updates to this Privacy Policy are effective when they are posted. You acknowledge and agree that it is your responsibility to review this Site and this Privacy Policy periodically and to be aware of any modifications. Your use of the Site after such modifications will constitute your acknowledgment of the modified Privacy Policy; and agreement to abide and be bound by the modified Privacy Policy. 

Contact Us

If you would like to opt-out of receiving email advertisements from Us, please send an email (from the address you wish us to opt-out) to [email protected], or use the unsubscribe feature on the Site. If you have questions specifically about this Privacy Policy or Our practices, or otherwise wish to contact Us, please contact Us via email at [email protected] or through the Site.

Need More Information or Do You Need Extra Help?

Further, if you have a disability which interferes with your ability to access this Privacy Policy, We can make accommodations to present the policy in an alternative format to assist you. If you would like to receive this Privacy Policy in another format that is accessible to your needs (for example: audio, large print, etc.), please contact Us. 

State Privacy Supplemental Notice

Information for residents of each of the featured states below is intended to supplement the information contained in Our primary Privacy Policy.

California Residents – Your Privacy Rights

This section is specific and applies only to California residents, under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations.

California Rights Under Shine the Light

Under California’s Shine the Light law (California Civil Code § 1789.83), California residents have the right to request, once a year, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and the names and addresses of such third parties with whom We have shared the personal information. As noted above, We do not share personal information with third parties for their direct marketing purposes.

California Rights Under the CCPA

We adopt this notice to comply with the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and all final, implementing regulations. Any terms defined in the CCPA and CPRA have the same meaning when used in this section. The CCPA and CPRA are collectively referred to as the “CCPA” for the purposes of this section.

If you are a California resident under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations, your use of the Site is subject to the CCPA, and all final and implementing regulations.

Under the CCPA, subject to certain legal limitations and exceptions, a consumer has the following rights:

·       Notice at Collection: at or before the point of collection, the right to receive notice of Our practices, including the categories of personal information and any sensitive personal information to be collected; the purposes for which such information is collected or used; whether such information is sold or shared; and the length of time that such information is retained. This information is found in this Privacy Policy.

·       Right to Know What Personal Information is Collected & Right to Access Personal Information: The right to know what personal information the business has collected about the consumer, including the categories of personal information, categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about the consumer.

·       Right to Delete: The right to request that a business delete personal information that the business has collected from the consumer, subject to certain exceptions.

·       Right to Correct: The right to correct inaccurate personal information that a business maintains about a consumer.

·       Right to Opt-Out of the Sale or Sharing of Personal Information: If the business sells or shares personal information, the right to opt-out of the sale or sharing of personal information by the business.

·       Right to Limit the Use or Disclosure of Sensitive Personal Information: If the business uses or discloses sensitive personal information for reasons other than those in § 7027(m), the right to limit the use or disclosure of such sensitive personal information.

·       Right to No Discrimination: The right not to receive discriminatory treatment by the business for the exercise of CCPA privacy rights.

Information regarding Our collection, disclosure, and sale/sharing practices are detailed below, in addition to instructions on how to exercise your CCPA rights.

What Personal Information Do We Collect?

We have collected personal information about consumers within the preceding twelve (12) months as detailed above under the “Personal Information We Collect About You” section.

What Personal Information Do We Disclose?

We only disclose personal information about consumers as identified in the “Disclosure of Personal Information” section above and for the specified purposes.

What Personal Information Do We Sell or Share?

As noted in the “Sale or Sharing of Personal Information” section above, We have not sold or shared personal information for a business purpose in the preceding twelve (12) months. We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.

In the event that We, or substantially all of Our assets, are acquired, such personal information may be included within the transferred assets. In the event We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or Our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

How to Submit a Request Under the CCPA

California residents that wish to exercise any of the above rights under the CCPA may submit a request that specifies the right(s) they wish to invoke by emailing Us at [email protected]. To process your request, We may require that you submit the following information in conjunction with your request: your email address. The information which you provide in conjunction with your request will be used to verify your request and to attempt to identify you within Our data records. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required. Please note that We utilize a two-step process for requests to delete, whereby you first submit your request to delete, and second, you separately confirm that you want your personal information deleted. The CCPA permits requests to know regarding collection and sale or sharing from the same consumer no more than twice in a twelve (12) month period.

How an Authorized Agent Can Make a Request Under the CCPA

If you elect to use an authorized agent to exercise your right to submit a request to know, request to delete, and/or request to correct, before processing the request, We require the purported authorized agent to provide proof of your signed permission to submit the request (unless there is a power of attorney in place pursuant to Probate Code §§ 4121-4130). We also require that you directly verify your own identity with Us, and directly confirm with Us that you provided the authorized agent permission to submit the request on your behalf. The information submitted will not be used for any purposes other than to verify the request, fulfill the request, and fraud prevention.

Updates

We may revise this section from time to time as implementing regulations further develop and come into effect and We are able to provide you with better information on your CCPA rights and how to exercise them.

Colorado Residents– Your Privacy Rights

Pursuant to the Colorado Privacy Act (“CPA”), the categories of personal data outlined in the “Personal Information We Collect About You” section above are collected and processed for the specified purposes. We only disclose your personal information as identified in the “Disclosure of Personal Information” section above and for the specified purposes. As noted in the “Sale or Sharing of Personal Information” section above, We have not sold or shared personal information for a business purpose in the preceding twelve (12) months.

We do engage in targeted advertising. To opt out of targeted advertising, please submit your request by emailing Us at [email protected]. Your authorized agent may opt out on your behalf.

Colorado residents have the following data rights under the CPA:

·       Right to opt-out: of the processing of personal data for targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer;

·       Right to access: may request confirmation on whether We process personal data concerning the consumer and to access the consumer’s personal data;

·       Right to correction: may correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing;

·       Right to deletion: may delete personal data; and

·       Right to data portability: in conjunction with the right to access, a consumer may obtain the personal data in a portable and, to the extent technically feasible, readily usable format.

Colorado residents that wish to exercise any of the above data rights under the CPA may submit a request that specifies the right(s) they wish to invoke by emailing Us at [email protected]. We require the following information to authenticate your identity: your first and last name, your Colorado address and email. Authorized agents of Colorado residents may submit a request in the same manner. Please note that We must be able to authenticate, with commercially reasonable effort, the identity of the consumer and the authorized agent’s authority to act on such consumer’s behalf, by requiring the following information: the Colorado resident’s first and last name, Colorado address, email and proof that such Colorado resident has authorized the agent to submit a request on their behalf.

Our contact information is below. To the extent that We decline to act upon your request, you may appeal by emailing Us at [email protected]. You may contact the Attorney General if you have concerns about the result of the appeal.

Connecticut Residents– Your Privacy Rights

Pursuant to the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the categories of personal data outlined in the “Personal Information We Collect About You” section above are collected and processed for the specified purposes. We only disclose your personal information as identified in the “Disclosure of Personal Information” section above and for the specified purposes. As noted in the “Sale or Sharing of Personal Information” section above, We have not sold or shared personal information for a business purpose in the preceding twelve (12) months.

We do engage in targeted advertising, but do not sell personal data to third parties for targeted advertising. To opt out of targeted advertising, please submit your request by emailing Us at [email protected]. Your authorized agent may opt out on your behalf.

Connecticut residents have the following rights under the CTDPA:

 

·       Right to confirmation and access: Confirm whether or not a controller is processing the consumer’s personal data and access such data (unless confirmation or access would require the controller to reveal a trade secret);

·       Right to correct: may correct inaccuracies in the consumer’s personal data;

·       Right to delete: may delete personal data provided by, or obtained about, the consumer;

·       Right to data portability: may obtain a copy in a portable and, to the extent technically feasible, readily usable format that allows consumer to transmit data to another controller without hindrance, where processing is carried out by automated means, provided that controller shall not be required to reveal any trade secret; and

·       Right to opt-out of certain data processing: may opt-out of the processing of personal data for targeted advertising, sale of personal data, or profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.

 

Connecticut residents that wish to exercise any of the above rights under the CTDPA may submit a request that specifies the right(s) they wish to invoke by emailing Us at [email protected]. You are permitted to designate an authorized agent. Information provided in response to a consumer request shall be provided free of charge, once per consumer during any twelve-month period. To the extent that We decline to act upon your request, you may appeal by emailing Us at [email protected].

 

Montana Residents– Your Privacy Rights

Pursuant to the Montana Consumer Data Privacy Act (“Consumer Data Privacy Act”), the categories of personal data outlined in the “Personal Information We Collect About You” section above are collected and processed for the specified purposes. We only disclose your personal information as identified in the “Disclosure of Personal Information” section above and for the specified purposes. As noted in the “Sale or Sharing of Personal Information” section above, We have not sold or shared personal information for a business purpose in the preceding twelve (12) months.

We do engage in targeted advertising. To opt out of targeted advertising, please submit your request by emailing Us at [email protected].

Up to once during any 12-month period, Montana consumers can exercise the following rights (including through a designated authorized agent) (and a parent or legal guardian of a child may also exercise the consumer rights on behalf of the child, or a guardian or conservator) by submitting a request which specifies the consumer rights that they wish to exercise:

·       confirm whether a controller is processing the consumer’s personal data and access the personal data, unless such confirmation or access would require the controller to reveal a trade secret;

·       correct inaccuracies in the consumer’s personal data, considering the nature of the personal data and the purposes of the processing of the personal data;

·       delete personal data about the consumer;

·       obtain a copy of the consumer’s personal data previously provided by the consumer to the controller in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the personal data to another controller without hindrance when the processing is carried out by automated means, provided the controller is not required to reveal any trade secret; and

·       opt out of the processing of the consumer’s personal data for purposes of: targeted advertising; the sale of personal data (except as provided in § 7(2); or profiling in furtherance of a decision that produces a legal or similarly significant effect concerning the consumer

 

Montana consumers that wish to exercise any of the above rights under the Consumer Data Privacy Act,  may submit a request to Us that specifies the right(s) you wish to invoke emailing Us at [email protected]. To the extent that We decline to act upon your request, you may appeal by emailing Us at [email protected]. To the extent that you have previously consented to Our use of personal data in accordance with this Privacy Policy and wish to revoke your consent, you may do so by contacting Us through the above method. You may contact Us at the following email address: [email protected].

 

Oregon Residents– Your Privacy Rights

Pursuant to the Oregon Consumer Privacy Act (“OCPA”) (ORS 646A.570-646A.589), the categories of personal data outlined in the “Personal Information We Collect About You” section above are collected and processed for the specified purposes. We only disclose your personal information as identified in the “Disclosure of Personal Information” section above and for the specified purposes. As noted in the “Sale or Sharing of Personal Information” section above, We have not sold or shared personal information for a business purpose in the preceding twelve (12) months.

We do engage in targeted advertising. To opt out of targeted advertising, please submit your request by emailing Us at [email protected].

Oregon residents have the following rights under the OCPA:

-       Right to access: may request confirmation on whether We are processing or have processed the consumer’s personal data and obtain a copy of such personal data;

-       Right to correct: may correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing;

-       Right to delete: may delete personal data, including personal data the consumer provided to the controller, personal data the controller obtained from another source and derived data);

-       Right to opt-out of certain data processing: may opt-out of the processing of personal data for targeted advertising, sale of personal data, or profiling the consumer in furtherance of decisions that produce legal effects or effects of similar significance.

 

Oregon residents that wish to exercise any of the above rights under the OCPA may submit a request to Us [identify controller, including any business name registered with Oregon Secretary of State and any assumed business name used in Oregon] that specifies the right(s) you wish to invoke by emailing Us at [email protected]. To the extent that We decline to act upon your request, you may appeal by emailing Us at [email protected].

Virginia Residents – Your Privacy Rights

Pursuant to the Virginia Consumer Data Protection Act (“CDPA”) (Code of Virginia § 59.1-571 et seq.), the categories of personal data outlined in the “Personal Information We Collect About You” section above are collected and processed for the specified purposes. We only disclose your personal information as identified in the “Disclosure of Personal Information” section above and for the specified purposes. As noted in the “Sale or Sharing of Personal Information” section above, We have not sold or shared personal information for a business purpose in the preceding twelve (12) months.

We do engage in targeted advertising. To opt out of targeted advertising, please submit your request by emailing Us at [email protected].

Virginia residents have the following rights under the CDPA:

-       Right to access: may request confirmation on whether We process the consumer’s personal data and obtain access such personal data;

-       Right to correct: may correct inaccuracies in the consumer’s personal data;

-       Right to delete: may delete personal data;

-       Right to data portability: may obtain a copy in a portable and, to the extent technically feasible, readily usable format; and

-       Right to opt-out of certain data processing: may opt-out of the processing of personal data for targeted advertising, sale of personal data, or profiling.

Virginia residents that wish to exercise any of the above rights under the CDPA may submit a request that specifies the right(s) they wish to invoke by emailing Us at [email protected]. To the extent that We decline to act upon your request, you may appeal by emailing Us regarding your appeal at [email protected].