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This privacy notice (“CCPA Privacy Notice”) for California residents (hereinafter, “Consumer” or “you”) supplements the information contained in our Privacy Policy and applies solely to each Consumer.  If you are an employee, job applicant, or contractor, please refer to the CCPA Notice to Employees, Job Applicants & Contractors.  This CCPA Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act (“CCPA”).  Any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Notice.

Definition Specific to this CCPA Privacy Notice:

“Personal Information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household.  Personal Information does not include publicly available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you.

  1. Information We Collect About You
    Our website has collected the following categories of Personal Information from Consumers within the last twelve (12) months: 
 Category Examples Collected  
A. Identifiers. 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. YES 
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.  YES 
C. Protected classification characteristics under California or federal law. 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). NO 
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES 
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.  NO 
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES 
G. Geolocation data. Physical location or movements NO 
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO 
I. Professional or employment-related information. Current or past job history or performance evaluations. YES 
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO 
K. Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES 
  1. List Consumer Rights

You have the right under the CCPA to exercise:

a. Disclosure of Personal Information We Collect About You

You have the right to know:

Please note that we are not required to:

b. Disclosure of Personal Information Sold or Used for a Business Purpose

c. Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Please note that we may not delete your Personal Information if it is necessary to:

d. Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to you by your Personal Information.

  1. How to Exercise Consumer Rights and Responding Time

If you would like to exercise any of your rights as described in this CCPA Privacy Notice, please:

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 

Please note that you may only make a data access or data portability disclosure request twice within a 12-month period.

  1. Verifying Your Identity

If you choose to contact us directly by email, phone or in writing, you will need to provide us with:

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

  1. Sharing Personal Information  

We may disclose your Personal Information for a business purpose to the following third parties:

We may disclose your Personal Information to a third-party for the following purpose:  

  1. Changes to Our CCPA Privacy Notice 

We reserve the right to amend this CCPA Privacy Notice at our discretion and at any time. When we make changes to this CCPA Privacy Notice, we will post the updated CCPA Privacy Notice on the Website and update the its effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes. 

  1.  Contact Information 

Any questions regarding this CCPA Privacy Notice can be addressed to our Data Protection Officer (DPO) here.


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