Privacy Policy

Our Privacy Policy was last updated on October 10, 2024.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your data when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By Using the Service, You agree to the collection and use of data in accordance with this Privacy Policy. 

Contents

Interpretation and Definitions

Collecting and Using Your Personal Data

GDPR Privacy Policy

California Residents

Virginia Residents

Links to Other Websites

Changes to this Privacy Policy

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. 

Definitions

For the purposes of this Privacy Policy:

“Account” means a unique account created for You to access our Service or parts of our Service.

“Business“, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ Personal Data and determines the purposes and means of the processing of Consumers’ Personal Data, or on behalf of which such data is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ Personal Data, that does business in the State of California.

“Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Policy) refers to [site_title]. For the purpose of the GDPR, the Company is the Data Controller.

“Country” refers to United States.

“Consumer“, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

“Cookies” are small files that are placed on Your computer, mobile device or any other device by a Website, containing the details of Your browsing history on that Website among its many uses.

“Data Controller“, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

“Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet.

“Do Not Track” (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across Websites.

“Personal Data” is any data that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any data relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any data that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

“Sale“, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Data to another business or a third party for monetary or other valuable consideration.

“Service” refers to the Website.

“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

“Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

“Website” refers to [site_title], accessible from [site_url]

“You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the user as You are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Business name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’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.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

 Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain data. Tracking technologies used are beacons, tags, and scripts to collect and track data and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

 Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your Web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Analytics and Performance Cookies

 Type: Persistent Cookies

Administered by: Google Analytics

Purpose: These cookies collect data that is used either in aggregate form to help Us understand how Our Site is being used or how effective our marketing campaigns are, or to help Us customize Our Site for You. We may use these cookies to assess the performance of our Services, including as part of our analytic practices to improve content offered through the Services. We also use this data to tell Us if You have visited the Site before or if You are a new visitor and to help Us identify the features in which You may have the greatest interest.

Administered by: Google Analytics

How to Refuse: To refuse these cookies, please click on the relevant opt-out link below:

• https://newrelic.com/termsandconditions/privacy
• https://policies.google.com/privacy

Advertising Cookies

Type: Persistent Cookies

Administered by: Google Analytics (GA4), YouTube

Purpose: These cookies are used to make advertising messages more relevant to You. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on Your interests. We may use these to deliver content, including advertisements relevant to Your interests on the Services and third-party sites based on how You interact with our advertisements or content, as well as to track the content You access.

How to Refuse: To refuse these cookies, please follow the instructions below under the heading “How to control cookies.” Alternatively, please click on the relevant opt-out link below:

• https://support.google.com/ads/ansWer/2662922?hl=en
• https://policies.google.com/privacy
• https://www.xandr.com/privacy/platform-privacy-policy
• http://exponential.com/privacy

How to Control Cookies

You have the right to decide whether to accept or reject cookies. You can exercise Your cookie preferences by clicking on the appropriate opt-out links provided above.

You can set or amend Your web browser controls to accept or refuse cookies. If You choose to reject cookies, You may still use Our Service though Your access to some functionality and areas of Our Service may be restricted. As the means by which You can refuse cookies through Your web browser controls vary from browser-to-browser, You should visit Your browser’s help menu for more information. Please note as this opt out is cookie based it will only affect the specific browser or device on which the opt out is applied.

Some of the advertising service providers may be members of the Network Advertising Initiative, which offers a single location to opt-out of ad targeting from member companies. If You opt out of receiving targeted ads in this manner, You will continue to receive advertising messages, but they will not be customized to You based on Your use of the Services and third-party sites.

If You would like more information about advertisers’ use of tracking technologies and about Your option not to accept these cookies, You can go to https://www.networkadvertising.org. If You would like to learn more about how interest-based data is collected and to know Your choices about not having data used in this manner, You can go to https://www.aboutads.info. Some newer mobile device operating systems allow You to limit the use of data to deliver interest-based advertising in mobile applications. You can check the settings on Your mobile device for such options in Your mobile devices’ operating system. Alternatively, You may wish to download the TrustE mobile application and/or the Digital Alliance “App Choices” mobile application and follow the instructions provided.

If You would like to find out more information, please visit https://www.aboutads.info/choices/ or https://www.youronlinechoices.com.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

 To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

 For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

 To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

 To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.

 To manage Your requests: To attend and manage Your requests to Us.

 For business transfers: We may use Your data 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 Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your data for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and Your experience.

We may share Your Personal Data in the following situations:

With Service Providers: We may share Your Personal Data with Service Providers to build, maintain, monitor and analyze the use of our Service, for payment processing, or to contact You.

 For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

 With Affiliates: We may share Your data with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates may include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

 With business partners: We may share Your data with Our business partners to offer You certain products, services or promotions.

 With other users: when You share Personal Data or otherwise interact in the public areas with other users, such data may be viewed by all users and may be publicly distributed outside.

 With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

 Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company 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 Your Personal Data

Your data, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this data may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such data represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other Personal Data.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal 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 Personal Data, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We use Google Analytics to track website traffic. Google Analytics is a web analytics service offered by Google. Google uses the data collected to track and monitor the use of Our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms Web page. We also encourage You to review Google’s policy for safeguarding Your data.

Email Communications

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. We use Constant Contact or MailChimp to do this. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. For more information, We encourage You to visit the Constant Contact Privacy Center and Mail Chimp’s Privacy Statement.

Facebook Pixel

We utilize the Facebook pixel. This tool allows Us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. Using this data also allows Us to improve our advertising for a better experience to the users and also retarget You with further advertising on Facebook. To learn more, visit Facebook’s Opt Out and Privacy Policy

Google AdSense

Third-party vendors, including Google, use cookies to serve ads based on Your prior visits to this website or other websites. Google’s use of advertising cookies enables it and its partners to serve ads to users based on visits to this website and/or other sites on the Internet. You may opt out of personalized advertising by visiting Ads Settings.

Exercising Your Rights to Your Personal Data

You have the right to request that We not sell Your Personal Data. [contact_link] to request that We not sell Your Personal Data. However, please note that, as stated above, we do not sell Personal Data for monetary consideration.

You have the right to request and receive Personal Data that We have received from You, to correct Your Personal Data and to ask Us to delete Your Personal Data. We will comply with these requests as required by the state You reside in.

In order to exercise any of Your rights under this Privacy Policy, You can [contact_link]

Only You, or a person You authorize to act on Your behalf, may make a verifiable request related to Your Personal Data.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data 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 the required information if We cannot:

• Verify Your identity or authority to make the request
• And confirm that the Personal Data relates to You

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

GDPR Privacy Policy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

 Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

 Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

 Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

 Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

 Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. You have the right to access, update or delete the Personal Data We have on You.

 Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate Personal Data We hold about You corrected.

 Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

 Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

 Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated data which You initially provided consent for Us to use or where We used the data to perform a contract with You.

 Withdraw Your consent. You have the right to withdraw Your consent on Using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

California Residents

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Data Collected

We collect data 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. The following is a list of categories of Personal Data which We may collect or may have been collecting from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that data from the applicable category may be and may have been collected. For example, certain categories of Personal Data would only be collected if You provided such Personal Data directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique Personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal Data 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 data, medical data, or health insurance data. Some Personal Data included in this category may overlap with other categories.

Collected: Yes.

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).

Collected: No.

Category D: Commercial data.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric data.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying data, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar data.

Collected: No.

Category I: Professional or employment-related data.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education data (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 data, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other Personal Data.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, Personal Data does not include:

• Publicly available data from government records
• Deidentified or aggregated consumer data
• Data excluded from the CCPA’s scope, such as:
  • Health or medical data covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Data Act (CMIA) or clinical trial data
  • Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Data Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Data

We obtain the categories of Personal Data listed above from the following categories of sources:

Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.

 Indirectly from You. For example, from observing Your activity on our Service.

 Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

 From Service Providers. For example, third-party vendors to monitor and analyze the use of Our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Data for Business Purposes or Commercial Purposes

We may use or disclose Personal Data We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the data. For example, if You share Your contact data to ask a question about our Service, We will use that Personal Data to respond to Your inquiry. If You provide Your Personal Data to purchase a product or service, We will use that data to process Your payment and facilitate delivery.
• 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 Data or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how We use this data, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of Personal Data or use the Personal Data We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Data for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Data for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial Data
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Data Were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that Data from the applicable category may be and may have been disclosed.

When We disclose Personal Data for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.

Sale of Personal Data

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Data by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing Personal Data, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data Were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that Data from the applicable category may be and may have been shared for value in return.

We have not and will not in the last twelve (12) months sell the following categories of Personal Data:

• Category A: Identifiers
• Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial Data
• Category F: Internet or other similar network activity

We may share Your Personal Data identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your Personal Data in connection with products or services We provide to You

Sale of Personal Data of Minors Under 16 Years of Age

We do not knowingly collect Personal Data from minors under the age of 16 through our Service, although certain third party websites that We link to may do so. These third-party Websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children’s Internet Usage and instruct their children to never provide information on other Websites without their permission.

We do not sell the Personal Data 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 the sale of Personal Data 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: [contact_link].

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with Personal Data, please [contact_link] with sufficient detail to enable Us to delete that data.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their Personal Data. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of Personal Data. Once We receive and confirm Your request, We will disclose to You:

• The categories of Personal Data We collected about You
• The categories of sources for the Personal Data We collected about You
• Our business or commercial purpose for collecting or selling that Personal Data
• The categories of third parties with whom We share that Personal Data
• The specific pieces of Personal Data We collected about You

If We sold Your Personal Data or disclosed Your Personal Data for a business purpose, We will disclose to You:

• The categories of Personal Data categories sold
• The categories of Personal Data categories disclosed

 The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your Personal Data. To submit an opt-out request please [contact_link]. Please note, though, that we do not sell Personal Data.

 The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personal Data from our records, unless an exception applies. We may deny Your deletion request if retaining the data is necessary for Us or Our Service Providers to:

• Complete the transaction for which We collected the Personal Data, 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 data’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 data that are compatible with the context in which You provided it.

 The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:

• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

 Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can [contact_link].

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your Personal Data.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data 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 the required information if We cannot:

• Verify Your identity or authority to make the request
• And confirm that the Personal Data relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your Personal Data that is readily usable and should allow You to transmit the data from one entity to another entity without hindrance.

Do Not Sell My Personal Data

You have the right to opt-out of the sale of Your Personal Data. Once We receive and confirm a verifiable consumer request from You, We will stop selling Your Personal Data. To exercise Your right to opt-out, please [contact_link]. Please note, however, that We do not sell Personal Data.

The Service Providers We partner with (for example, our analytics or advertising partners) may use technology on the Service that sells Personal Data as defined by the CCPA law. If You wish to opt out of the use of Your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, You may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are Personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.Youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of data about the apps You use in order to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location data from Your mobile device by changing the preferences on Your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect Personally identifiable data from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please [contact_link]. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that data from Our servers.

If We need to rely on consent as a legal basis for processing Your data and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that data.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If You’d like to request more information under the California Shine the Light law, and if You are a California resident, You can [contact_link].

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or data they have publicly posted.

To request removal of such data, and if You are a California resident, You can [contact_link].

Be aware that Your request does not guarantee complete or comprehensive removal of content or data posted online and that the law may not permit or require removal in certain circumstances.

Virginia Residents

This section provides information specific to Virginia Residents.

 Privacy Request

If You are a Virginia resident, You may request the following:

• Confirmation from Us that We hold Personal Data about You; and a copy of Your Personal Data held by Us. To submit a request, please [contact_link].
• A correction of inaccuracies in Your Personal Data held by Us. To submit a request, please [contact_link].
• A deletion of Your Personal Data held by Us. To submit a request, please [contact_link]

Decisions made by Us pursuant to any above request may be appealed to Us by contacting Us. If Your appeal is denied and You are unsatisfied with the outcome, You may contact the Attorney General of Virginia Using the following link to submit a complaint: https://www.oag.state.va.Us/consumercomplaintform/form/start.

 Profiling

We do not conduct “profiling” as defined by Virginia law.

 Sale of Personal Data

We do not sell Personal data as defined by Virginia law.

 Sensitive Data

As described in this Privacy Policy, We may process certain Personal Data that is considered “Sensitive Data” as defined by Virginia law. Processing of sensitive data only occurs when You knowingly take affirmative action to provide such data to Us for processing.

 Targeted Advertising

As described under the Detailed Information on the Processing of Your Personal Data section of this Privacy Policy, We may share Your Personal Data with social media sites for the purpose of providing You with customized ads. Refer to the Detailed Information section above for more information on how to opt out.

We may use cookies, Web beacons and other similar tracking technologies to enable essential features, or for data analytics and marketing purposes. You may opt-out of these technologies by following the instructions below:

Website

You can opt out of receiving ads that are Personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.Youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of data about the apps You use in order to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location data from Your mobile device by changing the preferences on Your mobile device.

Links to Other Websites

Our Service may contain links to other Websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us by visiting this page on our Website: [contact_link]