CALIFORNIA PRIVACY RIGHTS
(Last updated June 21, 2021)

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA defines “Personal Information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “California Privacy Rights” policy, we will refer to this information as “Personal Information.”

Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you. This right includes the right to request any or all of the following:
(1) Specific pieces of Personal Information that we have collected about you;
(2) Categories of Personal Information that we have collected about you;
(3) Categories of sources from which the Personal Information was collected;
(4) Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
(5) Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
(6) The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

Collection of Personal Information
A list of the categories of Personal Information that we currently collect and have collected for the 12 months preceding the Effective Date of this Privacy Policy is provided in Section 2 of the Privacy Policy above. A list of the categories of sources from which we have collected that Personal Information is provided in Section 2 above. A list of the business or commercial purposes for collecting that Personal Information is provided in Section 2 above.

Disclosure or Sale of Personal Information
A list of categories of Personal Information that we have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy is provided in Section 3 of the Privacy Policy above. The categories of third parties to whom the information was disclosed are also identified in Section 3 above.
We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

Right to Request Deletion of Personal Information
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

How to Submit a Request to Know or Delete
You may submit a request to know or delete (or to exercise any other right in this Policy and the CCPA) by submitting the form located here: ____. Our response time for such requests is subject to the verification process outlined below. All other requests or inquiries may be submitted by emailing your request to [email protected].

Our Process for Verifying a Request to Know or Delete
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt-Out of Sale of Personal Information
If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed in this Notice. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Shine the Light Law
We do not disclose personal information obtained through our website or services to third-parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

Accessibility
We are committed to ensuring that this Privacy Statement is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

How to Contact Us
To contact us with questions or concerns about our privacy policies, please email [email protected].