California Consumer Privacy Act

Effective from 1st May 2020

This section applies solely to the personal information collected online and offline of California consumers (excluding our employees, applicants, staff and contractors). This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 (the “CCPA”) and uses certain terms that have the meaning given to them in the CCPA.


Personal Information (“PI”) We Collect

The table below sets forth the categories of PI we have or have not collected from Consumers within the last twelve (12) months.

Category of PI
Examples
Collected (YES/NO)
1. Identifiers
A full name, a physical or mailing address, Social Security number, driver’s license number, email address, telephone number, or other similar unique personal identifiers.
YES
2. Personal Records
A full name, date of birth, marital status, genderattribute, marital status attribute, maiden nameattribute, financial account number, a credit bureau report, credit/debit card number, veteran identification number, passport number, or any other personally identifying financial, medical or health insurance information.
YES
3. Consumer Characteristics Information
A non-specific age or age range, race, colorancestry, national origin, gender, religion, sexual orientation, familial genetic information, or other similar protected classes of consumer characteristics.
NO
4. Customer Account Details/Commercial Information
Account numbers, account types, records ofpersonal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
5. Biometric Information
Biometric derived information, typically used for identity authentication purposes, includinginformation such as fingerprint, facial recognition patterns, voice prints and retina images.
NO
6. Internet Usage Information
Browsing history, search history, Internet Protocol (IP) address, Internet cookies or other information designed to identify consumer interaction on a website, application or digital advertisement.
YES
7. Geolocation Data
Information identifying consumers’ physicallocation or movements.
NO
8. Sensory Data
Audio, electronic, visual, thermal, olfactory orother similar information typically used forconsumer identification or verification purposes.
NO
9. Professional or Employment Information
Current or prior job history or performance evaluations.
NO
10. Non-public Education Information
Student education records maintained by aneducational institution or party activing in itsbehalf, such as grades, transcripts, class rank,financial information or disciplinary records.
NO
11. Inferences from PI Collected
Consumer profile information that when usedalone or in combination, could suggest consumer product marketing preferences, or other similar products and services interest. Profile information may include psychological trends, behavior, intelligence, attitudes and other similar characteristics.
NO

Your information, sources and purposes:

Please refer to the sections above headed “Information you provide to us and how we use it” and “Cookies and other information that we automatically collect” for a description of the personal information we may collect about you (or have collected in the preceding 12 months) and the sources of such information (such as directly from you and your device or through certain third parties). These sections also describe the purposes for which we may use or have used such information.

Sharing your information

We may have shared your personal information with certain categories of third parties, as described in the section headed “Sharing your information” above.

Selling your information

We have not sold personal information in exchange for monetary compensation. As described in the sections headed “Cookies and other information that we automatically collect” and “About Advertising”, we may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our Platforms in an effort to serve you content and advertisements that may be of interest to you. You have the right to opt out of this disclosure of your information, as described in the section headed “How to control or delete cookies.”

Your rights

Subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:

A. The Right to Know:

I. Information Rights

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

• The categories of PI we have collected about you.

• The categories of sources from which we collected your PI.

• The business or commercial purposes for our collecting or selling your PI.

• The categories of third parties to whom we have shared your PI.

• The specific pieces of PI we have collected about you.

• A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.

• A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:

• The categories of your PI we have sold.

• The categories of third parties to which we sold PI, by categories of PI sold for each third party.


Please note that we retain records, data and information for multiple retention periods by design, in accordance with our records retention and data governance policies and procedures. As a result, certain

information requested may no longer exist or be available for us to provide in response to your request for potentially relevant information going back 12 months in time from the date your request was received by us.


II. Obtaining Copies of PI

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.


B. Your Deletion Request Rights:

You have the right to request that we delete any of your PI 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 PI wherever it exists, unless an exception applies.

We have the right and may deny your deletion request under allowed exception bases provided by the CCPA, where retaining the information is necessary for us, or our service providers, to:

1. Complete the transaction for which we collected the PI, provide a product 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 and respond to security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Correct or debug products with errors where your information may contribute to resolution of the errors which 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.

8. Comply with a legal obligation or regulatory requirement directed by a governing regulatory agency.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it, and are reasonably aligned with your expectations as a Consumer with a business relationship with us.

We are not required to delete your PI that we did not collect directly from you.


C. Your Do Not Sell Protections and Rights:

We do not sell your PI as such is defined under the CCPA, and until such time as we change this policy by updating this Privacy Notice, will treat PI collected under that policy as subject to a do not sell request.

As we do not sell PI, we also do not knowingly sell the PI of Consumers we know are under 16.


D. 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 products or services, including through granting discounts or other benefits, or by imposing financial penalties.
  • Suggest that you may receive a different price or rate for products or services or a different level or quality of goods or services.
  • Provide you a different level or quality of products or services.
  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure and sale, if any, of such information.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.
  • Opt-Out of Sale: You have the right to opt out of certain cookie use, as described in the section headed “How to control or delete cookies.”

To exercise your rights, please contact us as described in the section headed “Contact Us” below. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address) or the authority of any third person acting on your behalf.

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. This section is available in alternative formats upon request by contacting us as described in the section headed “Contact Us” below.

Personal, family and household clients

In addition, under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail message to our e-mail address below with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.