California Privacy Policy Addendum

Last Updated: Feb. 11, 2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“Notice”) supplements the information contained in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). This Notice is designed to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. This Notice describes the personal information we collect from visitors to and users of our website (“Site”) and how we collect, use, and share that personal informational. Any terms defined in the CCPA (including, without limitation, “personal information”) have the same meaning when used in this Notice. California residents also have the option to exercise the following rights under California law. California residents may exercise these rights by utilizing our online webform for CCPA Rights Requests here: Click Here

We reserve the right to modify this Notice at any time by updating this document and alerting users with a notification on the Site.

Information We Collect
While visiting our Site, you may complete a registration process. During the registration process, we collect, with your consent, personal information such as your name, email address and date of birth. When you choose to opt into certain other features provided via the Site, such as requesting text messages, we collect personal information, such as your phone number.

Generally, the information we collect identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. The chart below summarizes the personal information that we collect from consumers, the category of information, a description of the information collected, examples of what the information may include and a statement indicating whether the information was actually collected within the last twelve (12) months:
Category Description Examples
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.
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.
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).
D. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
E. Geolocation data. Physical location or movements.
F. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources: Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes: We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.

We disclose your personal information for a business purpose to the following categories of third parties: For more information about the use and disclosure of personal information, please consult our general Privacy Policy. This Notice is intended to supplement, and not replace, our general Privacy Policy.

Your Rights and Choices
The CCPA provides consumers (who are California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to
  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Rights to Opt Out of Sale of Your Personal Information
California privacy laws require us to provide California residents with the option to opt out of current or future sales of your information. This information includes, but is not limited to name, postal or email address, and other personally identifying information. You need not be physically present in California to exercise this right so long as you have a current California residence.

This right is subject to certain exemptions. For example, the law does not apply to information that has been aggregated and/or de-identified such that it could not reasonably be used to identify you. It also does not apply to information that we share with third-party service providers in order for them to perform certain business functions for us.

Exercising Access, Data Portability, Deletion and Opt Out Rights
If you would like to exercise any of your rights provided by the CCPA, such as the right to access or delete your personal information, or to opt out of the sale or future sale of your personal information you or your authorized agent or representative may contact us via form submission Click Here
As with the right to opt out, the other rights provided by the CCPA are subject to certain exemptions and exceptions, as specified in the applicable federal statutes and/or associated regulations issued by California’s Office of the Attorney General. Those statues and/or regulations may also stipulate the maximum time allowed for acknowledging and responding to a request. There is no charge for making privacy-related requests.

Verifying a Request
Please note that only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. In order to better safeguard your privacy and the privacy of others, we may be required to verify your identity before processing certain data-related requests.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Additionally, in some cases, we may be unable to fulfill your request because we have no way to verify your identity to the standard the law and/or its associated regulations require. For example (but without limitation), if you have visited our website, but never left a comment, submitted a Contact Form, completed a financial transaction with us, or interacted with us via email or other means, we probably do not have enough information to confirm your identity to even a “reasonable degree of certainty” (as the applicable regulations may define that term). Please note that making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Please be aware that, in addition to any other exemptions applicable law and/or regulation may provide to your rights under the CCPA, specifically with regard to the deletion of your personal information, we may be unable to delete certain information due to regulatory requirements or other technical reasons (e.g., our web host’s server and error logs).

Response Timing and Format
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. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless and to the extent permitted by the CCPA, we will not: Changes to Our Privacy Notice
We reserve the right to amend this privacy Notice at our discretion and at any time. When we make changes to this privacy Notice, we will notify you by email or through a notice on our website homepage.

Contact Information
If you have any questions or comments about this Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us via form submission Click Here