Introduction

 

The Puro Ventures Limited t/a Speedy Freight (“PVL” or “Company”), is a company registered in England and Wales with company registration number 05822614, whose registered address is at Unit 2 The Pavilions, Cranford Drive, Knutsford Business Park, Knutsford, Cheshire, WA16 8ZR.

Maintaining the security of your data and your right to privacy is a priority to PVL. We will handle your personal data legally and fairly at all times and we will be transparent about what data we collect about you and how we use it.

This Privacy Policy (“Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.speedyfreight.com (our “Website”), our mobile applications (“Applications”), physical locations, and/or social networking sites and features (collectively with the Website and Applications, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect through the Services, including, but not limited to.

 

• On our Website;
• In email, text, and other electronic messages between you and PVL, whether direct email, text communications, or through our Website or Applications;
• Through any non-browser-based interaction between you and PVL.
• At any PVL physical locations.

 

This Policy does not apply to information collected by:

 

• PVL offline (except as noted above) or through any other means, including on any other website operated by PVL or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on our Website, or Application.

 

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.

If you do not agree with our policies and practices, your choice is not to use or access our Services. By accessing or using our Services, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

 

Person Under the Age of 18

 

Our Services are not intended for persons under 18 years of age. No one under age 18 may provide any information to PVL in connection with our Services. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information to PVL in connection with Services offered. If we learn we have collected or received personal information from a person under 18 we will delete that information. If we determine that a customer is under the age of 18, we will immediately terminate the associated account and delete any information provided. If you believe we might have any information from or about a person under 18, please contact us at:

2450 Lakeside Pkwy #150-215, Flower Mound, TX 75022

[email protected]

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information. We do not knowingly collect any information from person under the age of 18.

 

Information We Collect About You and How We Collect It

 

We collect several types of information from and about users of our Services, including information:

 

• By which you may be personally identified, such as first and last name, postal address, e-mail address, telephone number, IP address, browser type, account information, such as usernames and passwords, usage data, device identifying information, or any other identifier by which you may be contacted online or offline (“personal information”);
• You may decide to share your first and last name, date of birth, location, email address, phone number, biometric information, username and password, and the state in which you reside when you create an account to log in to our network (“Account”). We need this information to set up your Account, verify your identity, and provide you with our Services;
• When you use our Website, Application(s), and/or Services, or pay and/or deposit funds into your Account, we may collect all information necessary to complete the transaction and provide you with PVL’s Services, including your name, address, email address, phone number, credit or debit card information and other billing information, social security number, tax documents, and records of the products and goods or services you purchased, obtained, or considered;
• If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content provided in the email, in order to send you a reply, provide customer and technical support, improve and optimize the Services, satisfy our legal obligations, enforce our contracts, and address any existing or anticipated disputes;
• We may collect certain biometric information which you may upload, including, but not limited to a profile photo, with data derived from the photo you upload and username you choose for your public profile page including in connection with our Services. When you utilize our Services, other users may be able to see the information you selected for your Profile.
• If you tell us where you are (e.g., by allowing your mobile device to send us your location or by otherwise permitting us to geolocate you), we may store and use that information to verify your eligibility to use our Services, to comply with relevant laws, and for fraud prevention purposes.
• That is about you but individually does not identify you; and/or
• About your Internet connection, the equipment you use to access our Services, and usage details.
• Biometric information (see Biometric Privacy Policy for additional information) if you have affirmatively consented to our collection of such information.

 

We collect this information:

 

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website, Application or other platforms associated with our Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies and web beacons.

 

Information You Provide to PVL.

 

The information we collect on or through our Website, Applications, Services, or communications with you may include:

 

• Information that you provide by filling in forms. This includes information provided at the time of registering to use our Services or requesting further goods or services. We may also ask you for information when you report a problem with our Website, Applications, or other platform(s).
• Information that you provide within our Services or Applications to establish an account.
• Records and copies of your correspondence (including email addresses), if you contact us or provide us with feedback.
• Details of transactions you carry out through our Services and of the fulfillment of your participation in any Services.

 

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, Application, or other platform, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website, Application, or Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

 

Information We Collect Through Automatic Data Collection Technologies.

 

As you navigate through and interact with our Website, Application, or Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

 

• Details of your visits to our Website, Website, Application, or Services, 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, device, and internet connection, including the hardware models, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information. If you have downloaded our mobile Application, we may also collect certain information from your mobile device, including information about how you use the Application(s). This information is generally used to help us deliver relevant information to you. In the event our Application crashes on your mobile device, we will also receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs, provide other technical support, and improve and optimize the performance of our Application.

• In order to improve, personalize, and optimize our Services and meet our legal obligations, we may automatically track certain information about your visits to and usage of our Website, Application, and Services, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), device identifier, domain name, clickstream data, referring/exist pages, geolocation, and a date/time stamp for your visit. We also use this information to analyze trends, administer the Website, gather demographic information about our user base, deliver advertising, perform research, provide technical and customer support, inform our product development efforts, protect our legal rights, address disputes, and prevent our Services from being used to commit harmful or unlawful activities, including fraud. Some of this information may also be collected so that when you use the Website, Application, or Services again, we will be able to recognize you and optimize your experience accordingly.

 

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services 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 Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to one of our platforms.

 

The technologies we use for this automatic data collection may include:

 

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information below.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

 

What to do if you don’t want cookies to be set or want them to be removed?

 

If you do not want to receive cookies, you can change your browser settings on your computer or other device you’re using to access our services. If you use our Website without changing your browser settings, or if you click the “Accept” button on our website page regarding cookies, we’ll assume that you’re happy to receive all cookies on the Website and that you have provided consent by such actions or conduct. Most browsers also provide functionality that lets you review and erase cookies, including our Website cookies. Please note that the Website may not work properly without cookies.

 

Third-Party Use of Cookies

 

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

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. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 

How We Use Your Information

 

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

 

• To present our Website and our Services to you.
• To improve our Website and/or Application.
• To provide you with other PVL products and/or services.
• To provide you with information, products or services that you request from us.
• To notify you about changes to our Website and/or Application
• To allow you to participate in interactive features on our Website and/or Application.
• To provide customer support.
• For internal recordkeeping.
• For market research.
• To investigate, deter, and protect against fraudulent, unauthorized or illegal activity.
• To inform you about promotions, events, and news related to our Website and/or Application.
• To contact you with respect to our Website and/or Application.
• In any other way we may describe when you provide the information.
• To fulfill any other purpose for which you provide it.
• For any other purpose with your consent.

 

We may also use your information to contact you about goods/ services that may be of interest to you. If you do not want us to use your information in this way, please contact us at [email protected] or check the relevant box located on the form on which we collect your data. For more information, see Choices About How We Use and Disclose Your Information.

 

Disclosure of Your Information

 

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Policy:

 

• To our subsidiaries and affiliates
• To our employees on a need-to-know basis.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PVL about our Service users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• From time to time, we may also need to share your information with professional advisers, including lawyers, auditors, bankers, insurers and consultants, in order to obtain advice or other professional services from them. Such advisers are bound by legal and/or contractual duties of confidentiality and other prohibitions against disclosure of personal information.
• Co-Branded Partners are companies with whom we may jointly offer a service or feature. You can tell when you are accessing a service or feature offered by a Co-Branded Partner because the Co-Branded Partner’s name will be featured prominently. You may be asked to provide information about yourself to register for a service offered by a Co-Branded Partner. In doing so, you may be providing your information to both us and the Co-Branded Partner, or we may share your information with the Co-Branded Partner. Please note that the Co-Branded Partner’s privacy policy may also apply to its use of your information. We are not responsible for the practices used by Co-Branded Partners. In addition, by using our Website, Application(s), and Services, you acknowledge and agree that we are not responsible for and do not have control over any Co-Branded Partners.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

 

We may also disclose your personal information:

 

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PVL, our customers, or others.

 

Choices About How We Use and Disclose Your Information

 

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form on which we collect your data (the order/registration form) or Contact by email or phone. You can also always opt out by logging into the Website and adjusting your user preferences in your account profile, by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected].

• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

 

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. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website at www.thenai.org/opt-out/.

 

Third Party Links On Our Site

 

Our Website may contain links to other third party Websites for your convenience. We are not responsible for the privacy policies and practices of other third parties and any information you submit to a third party is subject to their privacy policy. Once you leave our Website, or are otherwise redirected to a third-party Website, application, or other online service, we encourage you to read the privacy policy applicable to that third party.

 

Opt-Out Of Communications

 

You may opt-out of receiving promotional e-mail communication from us by sending us an e-mail at Privacy@ speedyfreight.com, or by clicking the “unsubscribe” button at the bottom of our emails that we send to you. Please note that you will not be able to opt-out of transactional e-mail communication, such as communication related to your account activities.

 

Data Security

 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet or other electronic method is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

 

Changes to Our Privacy Policy

 

It is our policy to post any changes we make to our privacy policy on this page with a notice that this Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you. The date the 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 Policy to check for any changes.

Some states provide their residents with a limited right to opt- out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: 2450 Lakeside Pkwy #150-215, Flower Mound, TX 75022. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

 

Contact Information

 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

2450 Lakeside Pkwy #150-215, Flower Mound, TX 75022

[email protected]

BIOMETRIC PRIVACY POLICY

 

The Company has instituted the following biometric information privacy policy:

 

Biometric Data Defined

 

As used in this policy, biometric data includes “biometric identifiers” and “biometric information” as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Likewise, this policy applies to the Texas Capture and Use of Biometric Identifier Act (“CUBI”) and the biometric protection laws of the State of Washington. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.

 

Purpose for Collection of Biometric Data

 

The Company and/or its vendors, may collect biometric data for purposes of the Services to be provided, including, but not limited to, identification of users and confirming identity of any party using the Services provided.

 

Disclosure and Authorization

 

To the extent that the Company or its vendors, capture, or otherwise obtain biometric data relating to a user, the Company must first:

 

• Inform the user in writing that the Company and its vendors, are collecting, capturing, or otherwise obtaining the user’s biometric data, and that the Company is providing such biometric data to its vendors;
• Inform the users in writing of the specific purpose and length of time for which the user’s biometric data is being collected, stored, and used; and
• Receive a written release acknowledged and executed by the user (or his or her legally authorized representative) authorizing the Company and its vendors to collect, store, and use the user’s biometric data for the specific purposes disclosed by the Company, and for the Company to provide such biometric data to its vendors.

 

The Company and its vendors will not sell, lease, trade, or otherwise profit from users’ biometric data.

 

Disclosure

 

The Company will not disclose or disseminate any biometric data to anyone other than its vendors providing products and services using biometric data without/unless:

 

• First obtaining written user consent to such disclosure or dissemination;
• The disclosed data completes a financial transaction requested or authorized by the user;
• Disclosure is required by state or federal law or municipal ordinance; or
• Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

 

Retention Schedule

 

The Company shall retain user’s biometric data only until, and shall request that its vendors permanently destroy such data when, the first of the following occurs:

 

• The initial purpose for collecting or obtaining such biometric data has been satisfied, such as the termination of the business relationship with User; or
• Within 3 years of the User’s last interaction with the Company, unless a shorter period is required by law.

 

Data Storage

 

The Company shall use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which the Company stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing information, account numbers, PINs, driver’s license numbers and social security numbers.

 

Your California Privacy Rights

 

We do not sell, trade, or otherwise transfer your Personal Information to third parties, except as expressly stated in this Policy. California Civil Code Section § 1798.83 permits California residents to request certain information regarding our use

and disclosure of Personal Information to third parties. To make such a request, please send an e-mail to [email]. Please see CALIFORNIA-SPECIFIC PRIVACY RIGHTS (for California residents only) for more information.

 

California “Shine the Light” Law

 

Separate from CCPA, California residents may, pursuant to California Civil Code Section 1798.83 (the California “Shine the Light” law), request certain information regarding our disclosure (if any) of personal data to third parties for their direct marketing purposes. To make such a request, please contact us, identify yourself as a California resident and provide sufficient information so we can take appropriate action, such as your name, email address or any additional information required.

 

Colorado

 

Colorado enacted the Colorado Privacy Act (the “CPA”) in July 2021, which goes into effect on July 1, 2023. It applies to any legal entity conducting business in Colorado or delivering

products or services targeted to Colorado residents that control or process the personal data of 100,000 or more consumers during a year. The CPA affords certain rights to Colorado residents with respect to their data. The rights afforded to consumers under the CPA include the right to opt out of the processing of personal data for targeted advertising or for the sale of such personal data. Based on the consumer threshold, we do not believe these laws currently apply to us. If you are a resident of Colorado and have any questions or concerns about your state’s consumer privacy protection law or its non- applicability to us, please contact us.

 

Other States

 

Currently, Connecticut, Utah and Virginia have enacted laws that went into effect on January 1, 2023, or that will go into effect during 2023. In addition, in 2023, to date, Iowa, Montana, Indiana, and Tennessee enacted laws that go into effect in 2024 and later. We do not believe these laws currently apply to us. If you are a resident of one of these states and have any questions or concerns about your state’s consumer privacy protection law or its non-applicability to us, please contact us.

 

International Transfers

 

To deliver products and services to you, it is sometimes necessary for PVL to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers.

 

Call Recording

 

The Regulation of Investigatory Powers Act 2000 (RIPA) permits a company to lawfully record conversations only to:

 

• Establish facts;
• Ensure regulatory compliance; or
• demonstrate standards that are achieved or need to be achieved by training.

 

Any recordings that are retained are relevant to our business and only used for that business. We make all reasonable efforts to inform the parties involved that our calls are recorded.

Calls are stored for 90 days at which point they are then deleted.

If you wish to exercise any of the above rights, please contact us at [email protected].

CALIFORNIA-SPECIFIC PRIVACY RIGHTS (for California residents only)

 

California Consumer Privacy Act (CCPA)

 

This California Privacy Notice supplements the Privacy Policy (“Policy”) and contains the disclosures required under the California Consumer Privacy Act (CCPA). For individuals who are California residents, the CCPA requires certain disclosures about the categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it. You have also the right to exercise certain rights regarding your personal information.

Please note that for California residents, the term personal information means information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household as defined in the CCPA. All other capitalized terms have the same meanings as given them in the Policy.

 

Data Subject Requests

 

If you are a California resident who has provided personal information to us, or a California resident that reasonably believes that we have collected or stored their personal information, you have the right to request Company to:

 

• (1) Disclose the categories of personal information we collected about you in the preceding twelve months; categories of sources from which the personal information was collected; the business or commercial purpose for which we collected or sold the personal information; the categories of third parties with which we have shared your personal information; categories of personal information that we sold in the preceding twelve months, and for each category identified, categories of third parties to which we sold that particular category of personal information; and the categories of personal information that we disclosed for a business purpose in the preceding twelve months, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information (“Request to Know”);
• (2) Disclose the specific pieces of personal information that we have collected on you (“Request to Know”);
• (3) Delete personal information we have collected on you (“Request to Delete”); and
• (4) Opt out of the sale of the personal information we have collected on you (“Right to Opt Out”).

 

You can only make two Requests to Know in a twelve-month period, and the information provided need only cover the twelve-month period prior to receipt of your request.

 

Methods for Submitting Request

 

You may submit Requests to Know and Requests to Delete in one of the following methods: (a) writing to us at [address]; (b) by sending an email to [email protected] (c) by calling the following number: 817-369-9144.

 

Verification of Requests

 

We will need to verify your identity to respond to Requests to Delete and Requests to Know. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account.

If you do not have an account with us, and your request concerns “categories” of personal information collected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific pieces of personal information, we can request from you at least three data points of personal information as well as a signed declaration made under penalty of perjury to verify your identity.

If a request concerns household information, and the household does not have a password-protected account with us, we will not comply with a Request to Know specific pieces of personal information about the household or a Request to Delete household personal information unless all of the following conditions are satisfied: (1) all consumers of the household jointly request access to specific pieces of information for the household or the deletion of household personal information; (2) we have individually verified all the members of the household under the CCPA; and (3) we have verified that each member making the request is currently a member of the household.

 

Time for Response

 

Please note that once you have submitted a Request to Know or Request to Delete, we will send you a receipt, acknowledging your request, within ten business days. If, for some reason, you do not receive such a receipt within ten days of your submitted request, please send us an email to [email protected] as an error may have occurred.

We will respond to Requests to Know and Requests to Delete within forty-five calendar days after they are received. If we cannot verify you within the forty-five-day time period, we may deny the request. If necessary, we may take up to an additional forty-five calendar days to respond to the consumer’s request, for a maximum total of ninety calendar days from the day the request is received, provided that we provide you with notice and an explanation of the reason that we will take more than forty-five days to respond to the request.

In the case of a Request to Delete, we may use a two-step process for online requests to delete where you must first, submit the Request to Delete and then second, separately confirm that you want your personal information deleted.

 

Notice of Opt Out

 

You have the right to opt out of the sale of your personal information by us. To exercise this right, you can use this form or send an email to [email protected]. We will comply with a Request to Opt Out as soon as feasibly possible, but no later than fifteen business days from the date we received the request.

 

Authorized Agent

 

As a California resident, you have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us [email protected] for more information if you wish to submit a request through an authorized agent.

 

Right to Non-Discrimination for the Exercise of CCPA Rights

 

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.

 

Contact Us

 

If you have questions about our privacy policies or practices or this notice, please contact us at [email protected].

 

Notice at Collection

 

Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of personal information that we collect through the Website and Services, the business or commercial purposes for which such personal information was collected, the categories of sources of such personal information, and the categories of third parties to whom such information was disclosed in the past twelve 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).	No
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.	No
I. Professional or employment- related information.	Current or past job history or performance evaluations.	Yes
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.	Yes
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

 

Highly Sensitive Information

 

Certain of the categories listed above represent “Highly Sensitive Information” as such term is defined in the CPRA. We do not collect, use, share or store Highly Sensitive Information except for purposes of performing our services, providing our products or for such purposes as requested by you. For example, we may collect Highly Sensitive Information such as credit card or financial information for purposes of a transaction involving our products or services. We may also use Highly Sensitive Information to conduct background checks or for other purposes authorized by yourself. We do not share Highly Sensitive Information with third parties unless they are necessary to assist us in performing the services requested.

For example, we may share Highly Sensitive Information with payment processors to conduct transactions or with third-party vendors who assist us with performing background checks if required. We do not sell Highly Sensitive Information to any third parties. We also may collect Highly Sensitive Information in an employment context if you are applying for a position with our company or are currently or formerly employed by our company.

 

Retention Periods for Highly Sensitive Information

 

Pursuant to the requirements of the CPRA [Specifically, Cal. Civ. Code § 1798.100(a)(3)], we would like to inform you that we will only keep personal information and Highly Sensitive Information for so long as it is reasonably necessary to do so in accordance with the provisions of the CPRA and our internal policies. If you are concerned regarding our retention of your personal information including Highly Sensitive Information you may request deletion of such information in accordance with the provisions of this Notice in the manner set forth. We may be required by law to retain certain information including your personal information and Highly Sensitive Information in accordance with applicable laws requiring us to maintain such information or for a legitimate business purpose to maintain such information including but not limited to prevent fraud or to enforce our policies.

 

Changes to Our Privacy Policy

 

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.