Effective Date: July 16th, 2024

Privacy Policy

IGK LLC (“IGK” or “Company”) has created this Privacy Policy in order to demonstrate its firm commitment to privacy (“we”, “us”, or “our” as used in this Privacy Policy includes Company and may include IGK’s parent company, Luxury Brand Partners, LLC (“LBP”), and all LBP subsidiary companies and websites within the LBP family of companies). We respect your privacy and are committed to protecting your personal information and your right to privacy through our compliance with this Privacy Policy. This Privacy Policy describes the types of personal information we may collect from you or that you may provide when you visit “IGKhair.com” or any related website (collectively, “Website”) provided by us and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Privacy Policy applies to personal information we collect:

• On our Website and platforms.
• In email, text and other electronic messages between you and the Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.
• In certain offline formats as described herein.

It does not apply to personal information collected by:

Us from our employees, contractors, job applicants or business contacts. Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. For the purposes of the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“DPA 18”), IGK is the controller of the personal information we collect on the Website. For the purposes of the California Consumer Privacy Act (“CCPA”), IGK is characterized as a “business” in our use of personal information and our affiliates and the third parties with which we work may act as “service providers”.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices you should not use our Website. If you are in the European Economic Area (“EEA”) or the United Kingdom (“UK”), this Privacy Policy is provided for informational purposes only. If you are outside the EEA or the UK, by accessing or using this Website you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). If you are outside the EEA or the UK, your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

I. CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

II. COOKIES AND OTHER TECHNOLOGIES

We use a variety of tools on our website that collect data using both cookies or other similar technologies. Cookies are pieces of information that a website transfers to your computer’s hard drive for record-keeping purposes. We use cookies to track your preferences and purchases as you navigate through our Website and to save you from having to re-enter information every time you visit our Website.

The cookies we use fall into four categories:

1. Necessary Cookies: These cookies are required to enable technical site functionality and to provide the services explicitly requested by you. For example, necessary cookies enable services such as keeping you logged in, providing security and fraud prevention, having your digital shopping bag and wish list items stored while you browse.  This category of cookies cannot be disabled and does not require consent.
2. Analytic Cookies: These cookies are optional and collect information about how our Website is used and experienced in order to optimize design, operations, efficiency and to improve the user experience.
3. IGK Marketing Cookies: These cookies are optional and used to learn more about your interests, including which sites and advertisements you click on, which products and services you are interested in or purchase. IGK uses this information to show you more personal marketing and product recommendations.
4. Third-Party Marketing Cookies: These cookies are optional and allow third parties to collect information that allows us to present you with targeted marketing and advertisements of our products and services on other websites, applications, and on social media. These cookies allow the following third parties to set cookies tracking your interests and behavior: Google, Google Analytics, Good AdWords, Facebook (Meta), TikTok (ByteDance), Twitter (X), Bing, Shopify, Klaviyo, Attentive, YotPo, Vimeo, Quantserve, Rebuy, Afterpay, Upsellit, Youtube, Criteo, Studentbeans.

How to get rid of cookies:

Necessary cookies are essential for our Website and cannot be opted out of. For all other cookies, you can always adjust your settings and revoke your consent.

As you navigate through and interact with our Website, we may use automatic data collection technologies (including cookies and JavaScript libraries) to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

Information about your computer and internet connection, including your IP address, operating system, and browser type. As you navigate through and interact with our Website, we and third parties acting on our behalf may use automatic data collection technologies to collect certain information. Use of automatic data collection technologies helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Recognize you when you return to our Website.

Choices as to Cookies and Other Automatic Tracking Technologies: It may be possible to disable some (but not all) cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of all or a portion of our Website. The method for disabling cookies or other automatic collection technologies may vary by device and browser but can usually be found in preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking.

III. PERSONAL INFORMATION WE COLLECT

The personal information we collect from you on or through our Website may include:

• Information you provide by filling in forms on our Website or personal information you provide at the time of subscribing to our email lists or by placing orders through our Website. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

Name and Contact Data. Such as your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. Such as passwords, password hints, and similar security information used for authentication and account access.

Payment Data. Such as data necessary to process your payment if you make purchases, which may include your payment instrument number (such as a credit card number) and/or the security code associated with your payment instrument.

The personal information we collect will depend on the context of your interactions with us and the services, the choices you make and the products and features you use or purchase.

The personal information we collect from you through surveys.

From time-to-time, we may request Personal Information from you via online or offline surveys. All survey participation is, of course, voluntary, and you will be able to decide what information to provide. Personal Information we collect may include:

• Identifiers, such as your name and email address;
• Responses to our surveys or polls, which may include your opinions, preferences, and other information you provide us.

The personal information we collect when you enroll in a class.

We occasionally host classes for existing or potential customers on how to use our products and services. If you register, we will collect the following information:

• Identifiers, such as your name and email address;
• Information about your use of our products and services, current needs, and other information you may provide us to administer the class.

We may collect personal information about you from other sources, including:

• Public databases.
• Our marketing partners.
• Social Media Platforms.

Examples of the personal information we receive from other sources include social media profile information, marketing leads, and search results and links, which including paid listings (such as sponsored links).

 

Information we receive from third parties: We may obtain information about you from sources other than you, such as from our payment processing services provider and our online e-commerce platform provider (currently Shopify, Inc.) when you make payments for a product, or service offering on or through our Website. Any content or information submitted by you to third parties will be used and disclosed by such third parties in accordance with their respective privacy policies. You should review the privacy policies and practices of such third parties prior to disclosing information to them.
We may also collect information on third party platforms such as Google AdWords, Google Analytics, etc.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Third-party content, features or application providers may collect information: Some content, features or applications on our Website may be served by third parties, including our third-party service providers, ad networks and servers, content providers and other application providers. These third parties may collect information about you when you use our Website using cookies alone or in conjunction with web beacons or other tracking technologies. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Please note that the information collected by these third parties may be associated with your personal information and that these third parties may collect information, including your personal information, about your online activities over time and across different websites and other online services.

IV. HOW WE USE YOUR PERSONAL INFORMATION

We use information that we collect about you or that you provide to us, including any personal information as follows:

• To perform a contract with you or to take steps to enter into a contract at your request.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for delivery, billing and collection.
• To facilitate account creation and the logon process (including where your account with us is linked to a third-party account such as your Google or Facebook account).
• To fulfill and manage your orders, payments, returns, and exchanges.
• To send you information about changes to our terms or policies.
• To present our Website and its contents to you.
• To send information you have requested, provide customer services, and investigate and respond to your concerns or complaints.
• To perform marketing, promotions and advertising, either directly or through third-parties.
• To conduct data analysis to identify usage trends and determine the effectiveness of our promotional, marketing campaigns, and advertising campaigns and to improve our products and services.
• To conduct research, surveys and similar inquiries to help us understand trends and the needs of our customers and others using our websites or other products or services.
• To administer classes regarding the use of our products and services.
• To ensure the security of the Website (for example, for fraud monitoring and prevention).
• To enforce compliance with our terms of use and other policies and to help other organizations (such as copyright owners) enforce their rights.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
• Where you ask us to send marketing information and applicable law requires that we obtain your consent before sending you marketing, promotional communications, and tailored content and advertising.
• To post public testimonials about our services that use your name and testimonial.
• In cases where you give us consent, you may withdraw it at any time.
• For purposes which are required by law.
• Responding to legal requests by government or law enforcement authorities conducting an investigation.
• To fulfill any other purpose for which you provide it; For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

V. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

Data Subject Rights

Depending on your residency, you may have certain data subject rights, which may be subject to limitations and restrictions. These rights vary by jurisdiction, and may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) the right to data portability. If you wish to exercise one of these rights, please send us your request at the contact information below. You may also have the right to lodge a complaint about the processing of your personal data with your local data protection authority.

How to Exercise Data Subject Rights

If you wish to exercise your data subject rights please email [email protected] with the phrase “Data Subject Rights” in the subject line. You may also call us toll-free at (855) 445-3322. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.

If you make a request related to Personal Information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying the request. For requests related to particularly sensitive information, we may require additional proof of identification.

If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

We will process your request within the time provided by applicable law.

VI. HOW WE SHARE YOUR PERSONAL INFORMATION

We may share or disclose personal information that we collect, or you provide, as follows:

 

• To Service Providers. We may employ companies and individuals to help provide the Website or services on our behalf or help us operate our business (such as processing of your payment for a product, fulfilling orders, IT services and support, customer service or support, hosting, website analytics, email delivery, delivery of promotional, marketing and transaction materials, Website maintenance and security, marketing and advertising, research, surveys, event management, product reviews, data verification, and data storage). The service providers are permitted to use your personal information only as authorized to perform these services or tasks.
  For example, we use (and thus disclose certain of your personal information to):
  o Google Analytics so that they can help us understand how our customers use our Website -- you can read about how Google uses your information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
  o Shopify - in order to power our online store--you can read about how Shopify uses your information here: https://www.shopify.com/legal/privacy.
  o Klaviyo – our email service provider -- you can read about how Klaviyo uses your information here: https://www.klaviyo.com/legal.
  o Attentive - in order to provide SMS messaging -- you can read about how Attentive uses your information here: https://www.attentivemobile.com/privacy.

 

• To Payment Processors. Any payment card information you use to make a purchase on or through the Website or the service is collected and processed directly by-our payment processor, and we never physically receive or store your full payment card information.

 

• To Advertising Partners. We work with third party advertising companies that collect information about your activity on the Website and other online services to help us advertise our services and goods (including, through interest-based advertising), and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms. [If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by clicking on “Reject All” when landing on the website.]

 

• To Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates for use consistent with this Privacy Policy.

 

• To Professional Advisors. We may disclose your personal information to professional advisors such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.

 

• For Compliance and Protection. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.

 

• Business Transfers. We may disclose, lease, sell, assign, or transfer the information we collect (including your personal information) to third parties in connection with a Business Transfer. A “Business Transfer” means a sale, acquisition, merger, consolidation, reorganization, bankruptcy, or other corporate change involving us, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part of or our whole business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity, or assets (including our Website) to an affiliate or independent third party at any time, for any lawful purpose, without notice or compensation to you.
  • We may share or disclose information we collect or that you provide us (including your personal information) to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, or with your consent.
  • We may also disclose your personal information: (i) to enforce or apply our terms of use and other agreements and policies, including for billing and collection purposes, and (ii) if we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers, or others.
  • Aggregation and De-Personalization. We may use and disclose any de-identified information for any lawful purpose, including for any commercial purpose. De-identified Information means information that does not identify you, including any identifiable information de-identified by either combining it with information about others, for example, by aggregating your information with information about other persons, or by removing characteristics, such as your name, that make the information personally identifiable to you.

 

Please note that the list above is not exhaustive and that we may, to the extent permitted by applicable law, disclose the information we collect to third parties at any time, for any lawful purpose, without notice or compensation to you.

 

When we disclose the information we collect to third parties, such information will become permanently subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of such information. Furthermore, these third parties may further disclose, share and use this information. By submitting information (including your personal information) to us, you expressly consent to such disclosure and use of such information. If you do not want this information (including your personal information) shared as described above, then you should not provide us with such information.

 

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. We may, however, share originator opt-in data and consent with our third-party text-messaging provider as may be necessary for us to send you messages. Notwithstanding any other provisions of this Privacy Policy, we may disclose your information, including mobile information, as we deem necessary to satisfy any law, regulation, or governmental request, or to protect our rights or property.

 

Choices About How We Use and Disclose Your Information

 

We strive to provide you with choices regarding our collection, use and disclosure of the information that we collect. Below are some mechanisms that provide you with control over such collection, use or disclosure:

 

Cookies and Other Tracking Technologies. It may be possible to disable some (but not all) cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of our Website. The method for disabling cookies or other automatic collection technologies may vary by device and browser, but can usually be found in preferences or security settings.
You can exercise your preferences in relation to cookies served on our Website by taking the steps outlined below.

First-Party Cookies. You can use the browser with which you are viewing our Website to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our Website. Also, if you disable certain cookies, other parts of our Website may not work properly. You can find more information about how to change your browser cookie settings at allaboutcookies.org.

 

Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to aboutads.info/choices.

 

We do not control third-parties’ collection or use of your information to serve interest-based advertising. However, these third-parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:

 

Google Chrome https://support.google.com/chrome/answer/95647?hl=en-GB

 

Safari (Desktop) https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

 

Internet Explorer https://support.microsoft.com/en-us/topic/description-of-cookies-ad01aa7e-66c9-8ab2-7898-6652c100999d

 

Android Browser https://support.google.com/nexus/answer/54068?visit_id=638334280823499290-393147675&hl=en&rd=1

 

Mozilla Firefox https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

 

Opera https://www.opera.com/help

 

E-mail Offers. If you do not wish to receive e-mail offers or other information or communications from us, you can opt-out of receiving such e-mail offers or other information or communications from us (other than e-mails or other information or communications related to correction of user data, change of password and other similar communications essential to your transactions or purchases on or through our Website) by using the unsubscribe process at the bottom of the e-mail. Please be aware that it can take up to 10 business days to remove you from our marketing e-mail lists. If you opt-out from receiving our marketing e-mails, you may continue to receive certain status e-mails relating to your transactions and purchases on or through our Website.

 

Online Behavioral Advertising. We may use your information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. Certain third-party advertising networks that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You can prevent NAI member companies from collecting preference data about you by visiting http://www.networkadvertising.org/choices/ and following the NAI’s directions. Note that if you opt-out through the NAI, you will still receive advertising. In addition, if you opt-out through the NAI and later delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice. Additional options for opting out of target advertising include, without limitation:

 

FACEBOOK - https://www.facebook.com/settings/?tab=ads

 

TWITTER - https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

 

GOOGLE - https://www.google.com/settings/ads/anonymous

 

BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

 

Digital Advertising Alliance - http://optout.aboutads.info/
• [If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by clicking on “Reject All” when landing on the website.]

 

Accessing and Correcting Your Information. You can review and change your personal information by logging into the Website and visiting your account profile page or you may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

VII. DO WE USE GOOGLE MAPS?

This Website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

If you are outside the EEA or the UK, by using our Maps API Implementation you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you also agree to allow us to gain access to information about you including personal information (such as your usernames) and non-personal information (such as your location). You agree to allow us to obtain or cache your location. You may revoke your consent at anytime. We use information about location in conjunction with data from other data providers.

VIII. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your personal information to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for another one of our business purposes.

IX. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will take commercially reasonable efforts to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment. Despite our efforts, please be aware that methods of transmission and electronic storage are not completely secure. We cannot guarantee the privacy or security of your personal information, as third parties may unlawfully intercept or access transmissions or electronic storage. Further, to the extent permitted by law, we are not responsible for circumvention of any privacy settings or security measures of our Website. Therefore, you use our Website at your own risk, you should not expect that your information will always remain private, and we do not guarantee the performance or adequacy of our security measures. In the event that an unauthorized third party compromises our security measures, to the extent permitted by law, we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disseminate your information.

X. EUROPEAN RESIDENTS

This Website and the services on this Website are targeted for users in the United States of America. Any personal information you enter on this Website may be transferred outside of the EEA or the UK to countries (including the United States of America) which do not offer an equivalent level of protection to that required in the EEA and the UK. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. By using this Website or the services, you understand and acknowledge that your personal information will be transferred to the United States of America and that it will be processed by the Company on its servers located in the United States of America as described in this Privacy Policy.

XII. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

XIII. CHANGES TO OUR POLICY

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat your personal information, we will notify you through a notice on the Website home page, by email, and/or other notification method. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

XIV. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Privacy Policy, you may write to us by email at [email protected] or by mail to:

IGK LLC
Attn: Legal Department
331 NW 26th St. STE 103
Miami, FL 33127
United States

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, see our Privacy Notice for California Residents / Notice at Collection below.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please email us at [email protected]. To appeal a decision regarding a consumer rights request please email us at [email protected] or send by mail at 3800 NE 1st Ave, Suite 600, Miami, FL 33137.

Nevada law permits our users who are Nevada consumers to request that their personal data (as defined under applicable Nevada law) not be sold, even if their personal data is not currently being sold. Requests may be sent to [email protected] and are free of charge.

Privacy Notice for California Residents / Notice at Collection 

This section supplements the information contained in this Privacy Policy, but applies solely to all visitors, users, and others who reside in the State of California (for purposes of this section only, “consumers” or “you”). We have adopted this section to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).

Additional Detail on the Information We Collect:

We collect your personal information as described in Section 2 and 3 of this Privacy Policy. In particular, we have collected the following categories of your personal information 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).	YES
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.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
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

 

We obtain the categories of your personal information listed above directly and/or indirectly from you, as described in Section 2 and 3 of this Privacy Policy. For example, from observing your actions on our Website or from forms you complete or products and services you purchase.

[The Right to Limit the Use of Sensitive Personal Information

California residents have the right to limit the use of sensitive personal information. We only collect sensitive personal information, as defined by applicable California law, with your consent and only use the sensitive personal information for the use disclosed at the time of collection. We do not use sensitive personal information for inferring characteristics about you.]

Additional Restriction on Our Use of Your Information:

We use your personal information as set forth in Section 4 of this Privacy Policy. We will not use your personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Additional Detail on Our Disclosure of Your Information:

We disclose or share your personal information as set forth in Section 6 of this Privacy Policy. When we disclose personal information for a business purpose, we do so pursuant to an agreement 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 agreement. We do not sell your personal information. We have not sold any of your personal information in the last 12 months.

In the preceding twelve (12) months, we have disclosed the following categories of your information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category H: Sensory data.
• Category K: Inferences drawn from other personal information.

Your Additional Rights and Choices under the CCPA:

The CCPA provides California residents (consumers) with specific rights regarding their personal information.

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:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

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 or deidentify (and direct our service providers to take similar action) 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 provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. 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.

Exercising Your Access, Data Portability, and Deletion Rights:

How to Exercise. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at [email protected]. Only you, or someone legally authorized 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.

General Requirements. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. It must also 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 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.

Response Timing and Format. We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected]. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we may 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 permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights:

If you are under 18 years of age, reside in California, and have a registered account with the services, you have the right to request removal of unwanted data that you publicly post on the services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the services, but please be aware that the data may not be completely or comprehensively removed from our systems.

California's “Shine the Light” law permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]om or write us at: