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California Consumer Privacy Act (“CCPA”) Privacy Policy Addendum
This Addendum is applicable for residents of the state of California. If you are a California resident, you have certain privacy-related rights under the California Consumer Privacy Act (“CCPA”). We honor those rights, as described below, and we are prohibited by law from discriminating against you for exercising any of those rights.
The CCPA gives you the right to know what PII we have collected about you, why we collected it, and the categories of third parties (excluding service providers) with whom we have shared the PII during the past 12 months. (See below on “How to Submit a Request.”) You may request that we provide a description of the categories of PII we have collected (a “Categories Request”) or a request for access to the specific pieces of PII we have collected (a “Specific Pieces Request.”)
If you make a Categories Request, you will need to provide us with at least two data elements specific to you, such as your cell phone number or driver’s license number (depending on the data elements we already maintain about you), so that we can verify your identity. After we confirm that your request is a verifiable consumer request, we will disclose to you:
• The categories of PII we collected about you.
• The categories of sources for the PII we collected about you (e.g.,social media websites, government records available to the public, etc.).
• Our business or commercial purpose for collecting that PII.
• The categories of third parties other than service providers (if any) with whom we shared the PII.
If you make a Specific Pieces Request, we need to be sure we have verified your identity with great certainty to safeguard the privacy of the PII we have collected. Therefore, in making such a request, you will need to provide to us at least three data elements specific to you, together with a signed declaration under penalty of perjury that you are the individual to whom the PII you are requesting pertains. After we confirm that your request is a verifiable consumer request, ww will, consistent with the CCPA, disclose to you the specific pieces of PII we collected about you that you requested.
You have the right to request that we correct inaccuracies in or delete any of your PII that we maintain. We will correct inaccuracies based on a verification of your identity, as described below. If you ask us to delete your PII, we may decline to grant the request if we have a legal basis to retain the PII.
We will neither correct nor delete any PII pursuant to your request unless we are able to verify that you are the individual to whom that PII pertains. If you make a request for us to correct or delete your PII, we may need you to provide us with at least two data elements specific to you so that we can verify your identity. If we are able to confirm that your request is a verifiable consumer request (see below on “How to Submit a Request”), we will make any corrections you requested (and will direct any service providers with whom we have shared your PII to do the same) and if you requested that we delete your PII, we will inform you as to whether we have deleted your PII (and directed our service providers to do the same) or are declining to grant your request to delete due to a legal basis for us to retain the PII.
The CCPA has certain exceptions to the rights it grants to residents of California. Under one such exception, information that is “medical information” under the California Confidentiality of Medical Information Act (“CMIA”) is protected in accordance with that Act, and the CCPA rights do not extend to such information in light of the protection provided by the CMIA.
To request access to or correction or deletion of your PII as described above, please submit a verifiable consumer request to us by either:
• Calling us at our toll-free number: 866-337-6996
• Submit a request using the Contact Us form here.
You may make a request on your own behalf, and if you are the parent or guardian of a minor child, you also may make a request related to your child’s PII. If you wish to designate an authorized agent to make a request on your behalf, please provide us with a signed declaration stating that your intent is to permit that individual to act on your behalf and include such individual’s full name, address, email address, and phone number. That way we will be sure you have fully authorized us to act in accordance with the requests of that individual.
As indicated above, in order to protect your PII from unauthorized disclosure or deletion at the request of someone other than you or your legal representative, we require identification verification before granting any request to provide copies of, know more about, or delete your PII. We take special precautions to help ensure this. We cannot respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm that the PII relates to you. We will only use PII collected in connection with a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.