Propel Privacy Policy

Effective Date: January 1, 2023

This Privacy Policy describes how Propel Community, LLC d/b/a Propel and its subsidiaries or any of their affiliates or subsidiary companies (here defined collectively, “Community,” “we,” “us,” “our”), collect, use and otherwise process your information in the course of providing our products, access to our online properties (including the websites where this Privacy Policy is posted (our “Properties”)) and associated content and services (collectively, the “Services”).

This Privacy Policy does not apply to the other websites, including Hiring Partner Sites and social media sites you access and use, including those you may access from the Services. Your information is subject to the privacy policies of such other websites and social media sites.

Your use of the Properties and Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

“Personal Data” (or “Data”) means information relating to an identified or identifiable individual. Your Personal Data may identify you directly (e.g.name, address, telephone number, email address) or indirectly when combined with other information linked or linkable to you (e.g. IP Address & Device Identified Information).

1. PERSONAL DATA COLLECTED

a. Data You Provide.

Depending on how you interact with our Services, you may provide us, our agents, vendors, consultants, and other service providers (collectively, “Service Providers”) and/or our business clients, event/program operators, organizers or sponsors, and other business partners (“Business Partners”) with, and the Services may include hyperlinks to websites, locations, platforms, applications or services operated by such third parties (collectively, “Third-Party Services”) which requests certain Data that may include:

  • Personally Identifying Information (“PII”): information by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline;
  • Demographic Data: data related to your age, gender, race, occupation, income, residence, household/family status/size or lifestyle.
  • Transaction Information: data related to orders for any Services or purchases, if any, that you make from us;
  • Professional or Employment Information: information related to your work history, education history, certifications, licenses, patents, summary information, and any other job application or resume related information;
  • Personal Data that you otherwise provide us, such as when you contact us (e.g., for help); and

other Data related to your use of certain offerings on our Services (See User Generated Content, Job Listings, Events, and Social Features).

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b. Data Collected Automatically

We, our Service Providers, or Third-Party Services use common information-gathering tools such as cookies, web beacons, pixels and other similar tracking technologies (collectively, “Trackers”) to automatically collect information as you navigate our respective online properties, your accounts with us, our advertisements and/or when you interact with emails sent by or on our behalf.  

You can learn more about cookies and other tracking technologies and how to exercise your choices over the use of these in the section titled Cookies and Tracking Technologies below.

The Data collected via Trackers may include:

  • Service Use: information about your use of the Services, which may include a history of the pages you viewed, content you searched for, functionality you used and Third-Party Services you accessed.
  • IP Address: a unique number known as an Internet protocol (IP) address. We may obtain your general (imprecise) geolocation, information related to your Internet Service Provider and information about privacy promoting systems you may be using (e.g., if you are on a VPN or using a proxy server) from your IP Address. IP Addresses are assigned and reassigned by Internet Service Providers and companies regularly.
  • Device Identified Information (“DII”): data that is linked to a particular browser or device. DII may include, but is not limited to, unique identifiers associated with browsers or devices, such as:
  • Cookies: text files placed on a computer's browser that can be used to recognize you as a website user or to provide personalized content.
  • Mobile Advertising IDs or MAIDs: Apple assigns an "ID for Advertising" (IDFA) to each iOS device, and Google assigns an "Advertising ID" to all Android devices. These pseudonymous ID can be used to deliver ads and for advertising analytics in mobile applications.
  • Statistical Identifiers: Statistical IDs are generated by using information about your computer or devise including, operating system, user-agent string, IP Address, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device over time, including in environments where Cookies are not supported.
  • Internet Log Data: In addition to your IP Address, this Data may include including your Web request, IP address, browser type, browser language, configuration settings, operating system, Internet/mobile provider referring/exit pages and URLs, number of clicks/pages viewed, pseudonymous IDs such as Cookies, service specific information such as Service Use, Event Data, and data relating to malfunctions or problems that may occur when you use our Services; and
  • Event Data: data related to ads you see (advertiser ID, campaign ID), where and when you see the ad (date/time stamp, URL), and how you react to the ads you see (click, hover, convert, etc.). This data may be associated with pseudonymous IDs such as DII and other pseudonymous data such as Internet Log Data.

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c. Third Party Sources

We may obtain Personal Data from third parties, including our Business Partners, Service Providers and Third-Party Services as follows:

  • Data Providers. We may obtain Personal Data from reputable third party providers of licensed data derived from public and non-public sources to correct or supplement Personal Data we collect.
  • Business Partners. If access to any Services is obtained for you by a third-party organization (e.g., your employer or representative trade organization), such third-party may provide us with your Personal Data pursuant to the agreement between us. If you participate in a professional or social event sponsored by or otherwise contributed to by the Community, the event operator/organizer may provide us with your Personal Data pursuant to the agreement between us.
  • Service Providers. Our Service Providers, such as payment processors and third parties who conduct marketing/advertising and analytics activities may share with us some or all of the Personal Data they collect in the course of performing services to us. For example, we may engage and work with Service Providers and other third parties to serve advertisements on the Services and/or on Third-Party Services. Some of these ads may be tailored to your interest based on your browsing, across time, of the Services and elsewhere on the Internet, which may include use of data from cross-device usage, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Services (i.e., “retargeting”). Our advertisers' and ad networks’ use of Trackers are governed by their own privacy policies.
  • Third-Party Services. Third Party Services may use their own Trackers to independently collect Personal Data and may solicit Personal Data from you and share that Data with us. For example, the Community maintains its own branded pages on various social networks. When you visit these branded social media pages, the provider of the social network and other Third-Party Services may set Trackers on your browser or device and provide us with the types of Personal Data identified in the section titled Data Collected Automatically above.

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d. Data Inferred

We may derive insights regarding your preferences, characteristics, predispositions, behavior, attitudes and aptitudes from other Personal Data we have collected, obtained from our Service Providers or Third Party Services or that is available publicly. We may use these insights to improve our Services and to tailor the Services to you.

e. Non-Personal Information & Information You Disclose Publicly or to Others

We will treat information that does not personally identify you as non-personal information, and we may de-identify, anonymize or otherwise convert your personal information to non-personal information. As permitted by applicable law, we reserve the right to use, process, share and otherwise exploit your non-personal information without limitation.

The Services may permit you to post or submit User Generated Content (“UGC”) including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Data. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and may be accessible by anyone, including the Community. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Data included in UGC is not subject to our usage or sharing limitations, or other obligations, and may be used and shared by the Community and third parties to the fullest extent not prohibited by applicable law. We encourage you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Terms of Use click here.

2. OUR USE OF PERSONAL DATA.

We may use Personal Data to:

  • process your registration, manage your account (including your payment information and preferences), and deliver our Services and features desired by you (including any customization features requested by you);
  • fulfill our obligations pursuant to agreements with those Business Partners that have supplied Personal Data to us;
  • improve our Services;
  • fulfill other purposes disclosed to you at the time you provide us with your Data or otherwise where we are legally permitted to do so;
  • personalize content and offers and serve you advertising that may be of interest to you;
  • respond to your inquiries;
  • fulfill your request for Services;
  • provide you with updates and other information regarding the Services;
  • keep our Services safe and secure and to prevent detect fraud and abuse;
  • evaluate candidate submissions for Community jobs;
  • comply with our legal obligations, policies, and procedures;
  • administer and manage our Services including content and layout, site usage, troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  • improve our Properties to ensure that consent is presented in the most effective manner for you and your computer, device or other item of hardware through which you access our Properties.

3. SHARING OF PERSONAL DATA.

We may share your information as follows:

  • With our Service Providers in connection with their work on our behalf.
  • If the Services include access to Job Listings, we may share your Personal Data with Hiring Partners as set forth in our Terms of Use.
  • If you register for, attend, or participate in any Events, we may share your Personal Data with event sponsors in circumstances where either you agreed to be contacted by the applicable sponsor(s) or where such sponsor(s) are otherwise permitted by local law to contact you for marketing purposes. Please refer to Event sponsors’ privacy policies for information on how to opt out of their communications.
  • If access to any Services is obtained for you by a third-party organization (e.g., your employer or representative trade organization), we may share your Personal Data such organization. The use of your Data by such organizations will be governed by their privacy policies.
  • If you use of certain Services, such as participating in Events or registering to participate in a subgroup within the Community, we may disclose your identity as a Community Member to other Event participants and/or subgroup Members, as applicable.
  • With Third-Party Services where the Services permit interactions that you initiate between the Services and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Services and a Third-Party Services; “liking” or “sharing” Community content; logging into the Services using your Third-Party Services account (e.g., using Facebook Connect to sign-in to the Services); and to otherwise connect the Services to a Third-Party Services (e.g., to pull or push information to or from the Services). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Services (see “Information You Disclose Publicly or to Others” section above) or by the Third-Party Services that you use. Similarly, if you post information on a third-party service that references the Services (e.g., by using a hashtag associated with the Community or its affiliates in a tweet or status update), your post may be used on or in connection with the Services or otherwise by the Community and its affiliates. Also, both the Community and the third party may have access to certain information about you and your use of the Services and any Third-Party Services.
  • with communities and websites under common ownership with the Community;
  • with our family of Community affiliates who may have content and offers of interest to you;
  • With our trusted third-party advertising partners to serve you ads about our products or those of others;
  • if we believe your actions are inconsistent with our terms of use or other applicable terms or policies, or to protect the rights, property, life, health, security and safety of the Community, the Services, or its users, or any third party;
  • in the event of a change of ownership as a result of a merger, acquisition, or any transaction involving the transfer of some or all of our assets by another company, your Services information may be transferred. We will provide you notice prior to any such transfer of your Personal Data;
  • to comply with law, law enforcement or other legal process, and, where permitted, in response to governmental requests or legal process (for example, a court order, search warrant or subpoena); and
  • to other circumstances in which we have a good faith belief that a crime has been or is being committed by a user.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES.

a. Types of Trackers.

Trackers that collect the Personal Data identified above in the section titled Data Collected Automatically used by us and our Service Providers and Third-Party Services may include:

  • Cookies: Text files that a website sends to your computer's browser that can be used to recognize you as a website user or to provide personalized content.
  • Pixel Tags / Web Beacons / Clear GIFs: Images (often transparent) placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and are often used in combination with Cookies.
  • Flash Cookies or Locally Shared Objects (Flash LSOs): Messages used in Adobe Flash that are sent from a Web server to a Web browser and is then stored as a data file in the browser. Flash cookies behave like conventional cookies by personalizing the user’s experience, but they can hold much more data than conventional Cookies. Flash LSOs may stay installed on a drive after ordinary Cookies are deleted.

b. Your Tracking Choices.

  • Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the Services may not work and that when you revisit the Services your ability to limit browser-based Trackers is subject to your browser settings and limitations.
  • Many advertisers and service providers that perform advertising-related services for us and third parties participate in voluntary programs that provide tools to opt-out of such interest-based advertising such as the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising for DAA members, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies also are members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.
  • Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected, participating members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective.
  • In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by using Trackers, or by matching common factors between our databases and the databases of the third-party services. We are not responsible for these third-party services, including without limitation their security of the data. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions as they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
  • Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit; such signals may prevent third parties from collecting information about your online activities over time and across different websites. California law requires us to disclose how the Services respond to these kinds of “Do Not Track” signals. Like many websites, the Services currently are not designed to respond to “Do Not Track” signals from visitors’ browsers. To learn more about “Do Not Track” you may wish to visit this site.

5. DATA RETENTION & SECURITY.

The Community will retain your Personal Data only for as long as necessary for the purposes it was retained, such as to enable you to use our Properties and provide the Services to you. In some instances, we may retain data for longer periods in order to comply with applicable laws (including those regarding document retention), resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business.  All Personal Data we retain will be subject to this Privacy Policy and our internal retention guidelines.We take reasonable measures to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we cannot guarantee the security of Personal Data collected through the Services.

6. YOUR RIGHTS.

a. Choices Concerning Analytics.

We may use Third-Party Services such as Google Analytics to help us analyze our performance and our delivery of services and advertising to you. For example, we may use Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager and Google Analytics Demographics and Interest Reporting.

  • You may exercise your choices regarding the use of cookies by Google Analytics by using the Google Analytics Opt-out Browser Add-on or by going to https://tools.google.com/dlpage/gaoptout/ and following the instructions.
  • We and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site. You may limit the use of these Cookies as provided in the Your Tracking Choices above.

b. Opting Out of Promotional Communications.

You can make choices about how your Data may be used by us to provide information and offers to you. You may opt out of commercial messages by clicking on the “opt out” or “unsubscribe” link provided with each message. These preferences do not apply to transactional communications, such as those that are related to your registration with us, required or important notices related to your use of our Services, or the fulfillment of a specific transaction.

c. Accessing and Changing Information.

We may provide web page(s) or other mechanisms or processes allowing you to delete, correct, or update some of the Personal Data that we collect from you, and potentially certain other information about you (e.g., profile and account information). We will make good faith efforts to make requested changes in our then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from our databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data: (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

d. Region Specific Rights.

Your personal information may be stored in, transferred to, and processed in the United States and in any other country in which we, and/or Service Providers and Third Party Services maintain facilities. The data protection laws in these countries may provide a different standard of protection for Personal Data than the country in which you are located or your country of residence.

We may choose or be required by law to provide different or additional disclosures about our data privacy practices depending on your state or country of residence:

  • European Economic Area or United Kingdom: If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”)\please see the 'European Privacy Notice' section for additional European-specific privacy information, including what constitutes your personal data, the lawful bases we rely on to process your personal data, and your rights in respect of your personal data.
  • California: If you are a California resident, please see the 'California Privacy Notice' section below.

7. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to change at our discretion. We will indicate changes, including material changes, to the Privacy Policy by updating the “Effective Date” at the top of this page. Your continued use of the Services and our Properties after any update to this Privacy Policy will constitute your acceptance of the changes.

8. CONTACT US

Please direct comments or questions regarding this Privacy Policy via email to privacy@propel.run.

EUROPEAN PRIVACY NOTICE

For Users Located in the European Economic Area (EEA) or the United Kingdom (UK).

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i. Controller of your Personal Data

The controller of your personal data under this Privacy Policy is Propel Community, LLC, with an address of 228 Park Ave. S PMB 48593, New York, NY 10003-1502, USA.

ii. Legal Bases for Using Personal Data

We process your personal data only if we have a legal basis to do so, including:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party;
  • where you have given consent to our specific use.

The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is further explained below.

Purposes for which we will process the information

Legal Basis for the processing

To deliver services and features desired by you.

It is necessary for us to process your personal data in order to deliver the services and process transactions according to the applicable contract between us.

To improve our services to you.

It is necessary for us to process your personal data in order to improve our services to you according to the applicable contract between us. 

To personalize content and offers and serve you advertising that may be of interest to you.

We will personalize content and offers to you and serve you advertising based on your interests and online activities if you have consented to this processing.

To respond to your inquiries. 

It is necessary for us to process your personal data in this manner to respond to your inquiries according to the applicable contract between us.

To fulfill your request for products or services. 

It is necessary for us to process your personal data to fulfill your request for products or services according to the applicable contract between us. 

To provide you with updates and other information regarding the Services. 

It is necessary for us to process your personal data to provide you with updates and other information regarding the Services according to the applicable contract between us. 

To analyze statistically site usage and to customize our site’s content, layout and services.

It is in our legitimate interests to process your personal data to analyze our site usage and to customize our site’s content, layout and services.  We consider this use to be proportionate and will not be prejudicial or detrimental to you.

To enable our family of companies and affiliates and with trusted business partners that we do business with who may have content and offers of interest to you.

It is in our legitimate interests to process your personal data to enable our family of companies and affiliates who may have content of interest to you.  We process your personal data to enable our family of companies and affiliates and trusted business partners to send you offers and market to you only if you have consented to these activities. 

To enable our agents and service providers to perform certain activities on our behalf.

It is necessary for us to process your personal data in this manner in order to deliver the services and process transactions according to the applicable contract between us. It is also in our legitimate interest to enable our service providers to perform certain activities on our behalf. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

To administer our Website including troubleshooting, data analysis, testing, research, statistical and survey purposes; and

To improve our Website to ensure that consent is presented in the most effective manner for you and your computer, Device or other item of hardware through which you access the Website.

For all these categories, it is in our legitimate interest to continually monitor and improve our services and your experience of the Website and to ensure network security. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

To keep our Website safe and secure and to prevent detect fraud and abuse; and

To comply with our legal obligations, policies, and procedures.

We may process your personal data to respond:

  • To governmental requests or legal process (for example, a court order, search warrant or subpoena);
  • To other circumstances in which we have a good faith belief that a crime has been or is being committed by a user;
  • To an emergency that poses a threat to the safety of you or another person;
  • When necessary to protect our property;
  • In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy.

We conduct this processing to comply with our legal obligations and to protect the public interest.

To process otherwise for internal administrative and analytics purposes.

It is in our legitimate interest to process your personal data for internal administrative or analytics purposes. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

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iii. International Transfers

Some of our processing of your data will involve transferring your data outside the EEA and/or the UK.  Some of our external third-party service providers are also based outside of the EEA and UK, and their processing of your personal data will involve a transfer of data outside the EEA and UK. This includes the United States. Where personal data is transferred to and stored in a country not determined by the European Commission and/or the UK as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including entering into standard contractual clauses approved by the European Commission and/or the UK, obliging recipients to protect your personal data.

iv. Retention of Personal Data

The Community will retain your personal data only for as long as necessary for the purposes it was retained, such as to enable you to use the Website and your products or to provide services to you. In some instances, we may retain data for longer periods in order to comply with applicable laws (including those regarding document retention), resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business.  All personal data we retain will be subject to this Privacy Policy and our internal retention guidelines.

v. Data Subject Access Rights

You have the following rights:

  • Right of access to your personal data: You have the right to ask us for confirmation on whether we are processing your personal data, and access to the personal data and related information.
  • Right to correction: You have the right to have your personal data corrected, as permitted by law.
  • Right to erasure: You have the right to ask us to delete your personal data, as permitted by law.
  • Right to withdraw consent: You have the right to withdraw consent that you have provided.
  • Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority in the member state of your habitual residence.
  • Right to restriction of processing: You have the right to request the limiting of our processing under limited circumstances.
  • Right to data portability: You have the right to receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
  • Right to object: You have the right to object to our processing of your personal data, as permitted by law, under limited circumstances.

 

In order to exercise any of these rights, please contact us according to the “How to Contact Us” section herein contact us. Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act ("CCPA") provides California Consumers certain rights regarding their personal information ("PI") as those terms are defined in the CCPA. We are providing you with notice of the PI we collect, and our purposes for that collection of data that may be subject to the CCPA ("CCPA Notice"). This CCPA Notice does not cover information that is outside of the scope of the CCPA. This notice also does not apply to data collected from employees, applicants, or contractors or to data collected from individuals acting as representatives of another business in connection with business communications or transactions.

1. Notice of Collection and Use of Personal Information

We collect PI directly from you, your device or browser, and our service providers. We use and share PI for the following business purposes: 

  • to provide requested products and services;
  • to advertise and offer new products and services;
  • to improve our products and services;
  • for quality assurance;
  • for research development;
  • for prevention of fraud and illegal activity; and
  • for marketing purposes.

We may also collect, use, and share PI for our operational purposes as set forth in our Privacy Policy.

We collect the following categories of PI from California Consumers, which we share with service providers:

  1. identifiers (e.g., name, phone number, email address, I.P. address);
  2. personal records (e.g., name, phone number, email address);
  3. internet usage information (e.g., information regarding your
  4. interaction with our online services);
  5. geolocation data (e.g., your general location based on your I.P. address); and
  6. inferences from PI collected (e.g., your preferences).

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2. Rights of California Consumers‍

If you are a California Consumer and would like to register a request under your "right to know about personal information collected, disclosed or sold" (including the right to obtain copies of specific pieces of information about categories of PI practices), "right to request deletion of personal information," or "right to opt-out of the sale of personal information," you can contact us according to the “How to Contact Us” section herein contact us. You have the right to not receive discriminatory treatment in a manner prohibited by the CCPA because of you exercising your rights under the CCPA.

To fulfill your CCPA request, we may require you to provide sufficient information to reasonably verify you are the California Consumer about whom we collected PI. This verification process may include providing us at least two unique data points, depending on the type of request.

California Consumers have the right to exercise CCPA privacy rights via an authorized agent who meets the agency requirements of the CCPA. Authorized agent requests must include a copy of the agency agreement between the authorized agent and the California Consumer. We will ask you to independently confirm the agency relationship if this section applies to you.

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  • The Right to Know Categories of Information.

You have the right, subject to statutory exceptions, 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; and
  • a list of the categories of PI disclosed for a business purpose in
  • the prior 12 months, or that no disclosure occurred.

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  • Right to Know Specific Pieces of Information. 

You have the right, subject to statutory exceptions, 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.

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  • The Right to Deletion.

You have the right, subject to statutory exceptions, to request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.

 

  • The Right to Opt-Out of the Sale of Personal Information.

We may work with service providers and partner with advertising companies that use Trackers to collect information about your visits to the Site and Third-Party Services, and then use that information to deliver advertisements relevant to your interests. There is not yet a consensus as to whether third party cookies and/or other Trackers associated with our Site and Apps constitute a "sale" of your PI as defined by the CCPA. You may opt out of Interest-based Advertising using ad industry opt out tools by visiting here or here. To effectively manage cookies via this cookie settings tool, you must set cookie preferences on all browsers and all devices that you use. If you clear the cookies on your device, you may need to set your cookie preferences again.

We are not responsible for the completeness, accuracy or effectiveness of any third-party programs, tools or frameworks, or the information they provide.

3. California's "Shine the Light" Law.

If you are a California resident, in addition to the rights set forth above, California's "Shine the Light" law permits customers in California to request certain details about how their personal information is shared with third parties if that personal information is shared for those third parties' own direct marketing purposes. We do not share personal information with third parties for those third parties' own direct marketing purposes. Californians may request information about our compliance with this law by contacting us according to the “How to Contact Us” section herein contact us.

To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify "California Privacy Rights Request" in the subject line of the email or the first line of the letter and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.