Pramlux Privacy Policy

Privacy Policy

Last Updated: February 20, 2024

This Privacy Policy applies to information that Brivelle LLC (“Pramlux,” “our,” “we” or “us”) collects on Pramlux’s website, https://pramlux.com and any other website or services authorized by Pramlux that links to this Privacy Policy (collectively, the “Services”).

YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY TO LEARN ABOUT THE INFORMATION THAT WE COLLECT FROM YOU AND HOW WE USE THAT INFORMATION. BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.

PLEASE BE AWARE THAT PRAMLUX AND ALL ASSOCIATED SERVICES AND SYSTEMS ARE HOUSED ON SERVERS IN THE EUROPEAN UNION. IF YOU ARE LOCATED OUTSIDE OF THE EUROPEAN UNION, INFORMATION WE COLLECT (INCLUDING COOKIES) ARE PROCESSED AND STORED IN THE EUROPEAN UNION, WHICH MAY NOT OFFER THE SAME LEVEL OF PRIVACY PROTECTION AS THE COUNTRY WHERE YOU RESIDE OR ARE A CITIZEN. BY USING THE SERVICES AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO AND PROCESSING OF THE INFORMATION IN THE EUROPEAN UNION.

Table of Contents

  1. Scope
  2. Information We Collect
  3. How We Collect Information
  4. Cookies & Similar Technologies
  5. How We Process Personal Information
  6. How We Disclose Information
  7. Minor's Privacy
  8. Security of Personal Information and Copyright Protections
  9. Data Retention
  10. Accessing and Updating Your Personal Information
  11. The European and United Kingdom (“UK”) Data Protection
  12. California Consumer Privacy Act and other States’ Privacy Laws
  13. CAN-SPAM Act
  14. Changes To The Privacy Policy
  15. How To Contact Us

1. Scope

This Privacy Policy describes the information we collect (directly or indirectly), why we collect it, what we do with the information we collect, and how you can manage your Personal Information (defined below).

2. Information We Collect

“Personal Information” is information that directly or indirectly identifies you. Below are some examples of the Personal Information we may collect through the Services:

  • Identifiers: Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Customer Records: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, telephone number, credit card number, and debit card number.
  • Protected Classification Characteristics: Such as age (40 years or older).
  • Commercial Information: Such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other similar network activity: Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Geolocation Data: Such as physical location or movements.
  • Inferences drawn from other personal information: Such as profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may link together different types of information or link information to Personal Information. If linked information directly or indirectly identifies an individual person, we treat the linked information as Personal Information. In this Privacy Policy, to “process” Personal Information means to perform any operation on Personal Information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying. Where we need to collect Personal Information by law, or under the terms of the contract between us and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or Services). In this case, we may have to cancel a product or Service. We will notify you if this is the case.

3. How We Collect Information

We collect information as follows.

  • a) When you register for the Services: When you register for the Services, we collect your username, email address, and password.
  • b) When you use the Services: We may ask for contact information such as your name, address, telephone number, email address, contact preferences, and information related to our products and Services. We collect this information so we may: keep you informed, respond to your inquiries, and provide you with information about our products and Services.
  • c) When you make a purchase or payment: If you make a payment, we will ask for payment information and other information requested for processing your payment.

    We use a third party payment processor, which is currently Stripe, to assist with securely processing your payment information. If you pay with a credit card, the payment information you provide through the Services is encrypted and transmitted directly to Stripe. We do not store your payment information, do not control, and are not responsible for Stripe or its collection or use of your information. You may find out more about how Stripe stores and uses your payment information by accessing the Privacy Policy for Stripe’s services (https://stripe.com/privacy).

  • d) Through Server Logs: A server log is a list of the activities that a server performs. Our servers automatically collect and store in server logs your search queries, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and referral URL and certain cookies that identify your browser or account.
  • e) From Your Computer, Tablet or Mobile Telephone: We collect information about your computer, tablet or mobile telephone (“Device”), such as model, operating system version, mobile network information, telephone number, internet service provider and similar identifiers. We may associate your Device information with your account. We may collect and store information (including Personal Information) on your Device through browser web and web application data caches. We may collect information from sensors that provide us with information on nearby devices, Bluetooth address, Wi-Fi access points and information made available by you or others that indicates the current or prior location of the user. We also may collect IP address and MAC address. How we collect this data depends on how you access the Services. Certain Services may collect this data even when you are not actively using the Services.
  • f) Cookies and Similar Technologies: We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide the Services and help collect data. Our Cookies’ procedure in Section 4 below explains how we use Cookies to collect information about the way you use the Services and how you can control them.

4. Cookies & Similar Technologies

How We Use Cookies

We use Cookies to track how you use the Services by providing usage statistics. Cookies are also used to allow product authentication to you based upon your browsing history and previous visits to the Services. Information supplied to us using cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them, as the case may be.

While this information on its own may not constitute Personal Information, we may combine the information we collect via Cookies with Personal Information we have collected from you to learn more about how you use the Services to improve them.

Types of Cookies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on the Services can be grouped into the following categories:

  • Strictly Necessary: These Cookies are necessary for the Services to work properly. They include any essential authentication and authorization cookies for the Services.
  • Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing the Services, including any preferences you set. They also include sign-in and authentication cookies and IDs that enable you to return without additional sign-in.
  • Performance/Analytics: These Cookies allow us to collect certain information about how you navigate the Services or utilize the Products running on your device. They help us understand which areas you use and what we can do to improve them.
  • Marketing and Customer Support: These Cookies are used to deliver relevant information related to the Services to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit the Services. Some of these types of Cookies on the Services are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to the Services.

Cookies Set by Third Party Sites

To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the Services. We currently use and may in future use, content from websites such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the third parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.

We also use Google, a third-party analytics provider, to collect information about Services usage and the users of the Services, including demographic and interest-level information. Google uses cookies in order to collect demographic and interest-level information and usage information from users that visit the Services, including information about the pages where users enter and exit the Services and what pages users view on the Services, time spent, browser, operating system, and IP address. Cookies allow Google to recognize a user when a user visits the Services and when the user visits other websites. Google uses the information it collects from the Services and other websites to share with us and other website operators’ information about users including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies, and collection and use of information, see the Google Privacy Policy. If you would like to opt out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on.

Other Similar Technologies

Our web pages may use other technologies such as web beacons to help deliver cookies on the Services and count users who have visited those websites. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.

In addition to standard cookies and web beacons, the Services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments.

If you are using a mobile device to access the Services, you will need to refer to your instruction manual or other help/settings resource to find out how you can control cookies on your device.

Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Services may not operate properly, and you may not have access to the Services available through the Services. We shall not be liable for any impossibility to use the Services or degraded functioning thereof, where such are caused by your settings and choices regarding cookies.

To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Do Not Track

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including us, do not respond to DNT signals.

5. How We Process Personal Information

We will only use, sell, or disclose your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • With your consent.

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note, we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We use information collected for the following purposes based on our legitimate interests:

  • To communicate with you;
  • To administer and protect our business and the Services including troubleshooting, data analysis, security, testing, system maintenance, support, reporting, technical functionality, hosting of data, and in the context of a business reorganization or group restructuring exercise;
  • To prevent and investigate fraud and other misuses of the Services;
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  • To use data analytics to improve our website, products/Services, marketing, client relationships and experiences;
  • To provide marketing related information, promotions, or program membership-related benefits and updates; or
  • To make suggestions and recommendations to you about products or Services that may be of interest to you.

We also use your Personal Information when necessary for the performance of a contract in the following contexts:

  • To process your payments, orders, and transactions including:
    • Delivering products to you;
    • Managing payments, fees and charges; and
    • Collecting and recovering money owed to us
  • To set up and maintain your account with us;
  • To manage our relationship with you which will include:
    • Notifying you about changes to our terms or privacy policy;
    • Asking you to leave a review or take a survey; and
    • Responding to your questions and inquiries

We may also use your Personal Information when necessary to comply with legal obligations.

5.1 Via our Website

We may process your information as part of your visit to our web pages. This is done to ensure a problem free operation of the web pages and to improve our offerings and services.

5.2 Online shop

If you place an order and register via our Online Shop, we process the data provided by you in order to process your order.

Program Membership: If you register for participation in our Membership Program by opening a Membership account, we will process the data you provide or that accrues in the course of your use of the program in order to set up and manage your membership account, to credit your Points and to grant you the benefits available within the program.

Guest order: If you place an order as a guest, you do not need to register as a customer prior to placing an order but you will then have to re-enter your data for each subsequent order. We process the data provided by you as part of a guest order.

Communication during order: During or after your order in our Online Shop we may contact you via the contact data provided by you, where this should be necessary to eliminate any discrepancies in your order, to make suggestions to optimise your order or because of important information in connection with or following your order.

5.3 Shopping cart abandonment, items on your wish list

If you have made a purchase in our Online Shop, are a member of our Program or have agreed to receive marketing emails, you will receive emails informing you about the products you have added to your shopping cart and not purchased, or about products you have added to a wish list. You may Opt-out of receiving these courtesy reminders in the Privacy Settings section of the website.

5.4 Surveys. Customer Satisfaction Surveys

If you have made a purchase in our Online Shop, contacted us for customer service, are a member of our Program or have agreed to receive marketing emails, you will from time to time receive invitations to participate in surveys. These surveys are sent out to ensure customer satisfaction and improve our service quality. If you wish to Opt-out of receiving these customer satisfaction surveys, you may change your preferences in the Privacy Settings section of the website.

6. How We Disclose Information

We may disclose Personal Information collected via the Services with service providers. We disclose information to our third-party service providers that perform Services on our behalf, such as payment processing, delivery services, customer relationship management, web hosting, or data storage. Additionally, we may disclose your information to companies that are conducting marketing and advertising to benefit us. These third-party companies may use your contact information for communications and marketing purposes that support our activities. You are under no obligation to respond and the companies are restricted from using your contact information for any other purpose. We will ensure that any service provider with which we disclose Personal Information agrees to safeguard it in substantially the same manner as we have described in this Privacy Policy and in accordance with all applicable laws.

Remarketing, Retargeting, and Advertising

We do use third party service providers to serve advertisements or collect data on our behalf across the internet and on the Services (“Advertisers”). Some of these Advertisers may collect your Personal Information about your Service visits and your interactions with our products and services to tailor marketing messages on the Services or other sites, or to trigger real-time interactions, customize the Services, or enhance your profile (“Retargeting” or “Remarketing”). Advertisers may use cookies, Pixels and other technologies to collect your Personal Information, measure the effectiveness of their advertisements, and personalize the advertisements on the Services. Some of these Advertisers may collect your Personal Information that you share on the Services via a web form automatically and prior to your submission of the Personal Information (i.e., before you click, “Submit”). Advertisers may be able to use information from your visits to the Services to send marketing messages to you in a way that could personally identify you. The information collected by Advertisers may include your IP address, email addresses and other user and device level information. For example, when Advertisers send advertisements and links that appear on the Services directly to your browser, they automatically receive your IP address. Please keep in mind that your browser settings may not permit you to control Advertisers’ technologies, and this Privacy Policy does not apply to, and we cannot control the activities of, Advertisers. If you would like more information about Advertisers’ practices, please see http://optout.aboutads.info/#!/.

You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org) and DAA website (http://www.aboutads.info/choices/).

If you do not wish to participate in third-party Retargeting or Remarketing, you can find out more information about how to opt-out by visiting the links above.

We may aggregate information collected though the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Anonymized Information”). We disclose Anonymized Information with third parties and do not limit third parties' use of the Anonymized Information because it is no longer Personal Information.

We may disclose Personal Information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part). We require that the shared Personal Information remain subject to the promises made in the then-current Privacy Policy, unless and until you agree to a new privacy terms.

Applicable law may require us to disclose your Personal Information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) disclosure would mitigate our liability in an actual or threatened lawsuit; (iii) necessary to protect legal rights of us, users, customers, business partners or other interested parties; or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law).

7. Minor's Privacy

The Services are not directed to or intended for use by individuals under the legal age of majority in the individual’s country of residence (“minors”). Consistent with the requirements of applicable law, if we learn that we have received any information directly from a minor without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Services and subsequently will delete that information.

8. Security Of Personal Information and Copyright Protections

We take precautions intended to help protect information we process, but no system or electronic data transmission is completely secure. Any transmission of your Personal Information is at your own risk and we expect that you will use appropriate security measures to protect your Personal Information.

You are responsible for maintaining the security of your account credentials for the Services. We will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

If we become aware of a breach that affects the security of your Personal Information, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, we will provide any such notice that we must provide to you under applicable law at your account’s email address. By using the Services, you agree to accept notice electronically.

All payments received via credit card are processed securely by Adyen, using measures that comply with the Payment Card Industry Data Security Standard ("PCI DSS").

At times some of our customers may post pictures or other content in our reviews. Our company respects the intellectual property rights of others and expects the same from our users. We comply with the Digital Millennium Copyright Act (DMCA), which is a federal law that provides certain protections and obligations for online service providers and copyright owners in relation to digital content.

Some of the actions we take to comply with the DMCA are:

  • We have designated an agent to receive notifications of claimed infringement from copyright owners and to respond to such notices in accordance with the DMCA. Our agent’s contact information is available on our website.
  • We have adopted and implemented a policy that provides for the termination in appropriate circumstances of users who are repeat infringers of copyright or who repeatedly submit or post infringing content on our platform.
  • We have developed and maintained a system that allows users to flag or report any content that they believe is infringing, abusive, illegal, or otherwise violates our terms of service or community guidelines.
  • We have established and followed a process for removing or disabling access to any content that is identified as infringing or that is subject to a valid DMCA takedown notice, and for restoring access to any content that is subject to a valid DMCA counter-notice, in accordance with the DMCA.
  • We have provided information and resources to our users on how to respect and protect the intellectual property rights of others, how to file a DMCA notice or counter-notice, and how to dispute a DMCA claim.

We are committed to complying with the DMCA and cooperating with all parties involved in resolving any issues related to online content. We value the creativity and innovation of our users, and we strive to create a safe and respectful environment for everyone.

9. Data Retention

We retain Personal Information in identifiable form only for as long as necessary to fulfill the purposes for which the Personal Information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements and similar essential purposes. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Accessing and Updating Your Personal Information

You may request access to your personal information or correct an error or omission in your personal information by contacting us at [email protected] or write to us at: Brivelle LLC, 2232 Dell Range Blvd, Suite 245, #3164, Cheyenne, WY 82009. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical. Residents of the EEA and California may have additional rights concerning the access and updating of their Personal Information (see Sections 12 and 13 below).

11. The European and United Kingdom (“UK”) Data Protection

For individuals located in the European Economic Area (EEA) and the United Kingdom (UK), Brivelle LLC ("Pramlux") is committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable UK data protection laws. As a data controller, we determine the purposes and means of processing your personal data. We process your personal data when you have given consent, where processing is necessary for the performance of a contract with you, where processing is necessary for compliance with a legal obligation to which we are subject, and where processing is necessary for the purposes of our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms. You have the right to access your personal data, the right to rectify inaccurate personal data, the right to erase your personal data which is sometimes referred to as the "right to be forgotten", the right to restrict processing, the right to data portability allowing you to obtain and reuse your personal data for your own purposes across different services, the right to object to processing, and the right not to be subject to a decision based solely on automated processing, including profiling. To exercise these rights, please contact our Data Protection team. You also have the right to lodge a complaint with a supervisory authority in your country of residence. When we transfer personal data outside the EEA/UK, we implement the appropriate safeguards. These include the Standard Contractual Clauses approved by the European Commission, which ensures a level of protection for your personal data..

12. California Consumer Privacy Act and other States’ Privacy Laws

California residents are afforded specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include: (1) the right to know what categories and specific pieces of personal information we collect about you, the sources of the information, the purposes for collecting and/or selling it, and the categories of third parties with whom we share it; (2) the right to request deletion of your personal information, subject to certain exceptions under law; (3) the right to correct inaccurate personal information that we maintain about you; (4) the right to opt-out of the sale or sharing of your personal information for cross-context behavioral advertising purposes. and (5) the right to limit the use of your sensitive personal information for purposes other than those specifically permitted by the CCPA/CPRA. To exercise these rights, please submit a verifiable consumer request to us by emailing [email protected] or writing to us at Brivelle LLC, 2232 Dell Range Blvd, Suite 245, #3164, Cheyenne, WY 82009. We will verify your request using the information associated with your account, which may include asking you to provide additional information to verify who you are before fulfilling your request. We will not discriminate against you for exercising your CCPA/CPRA rights. Information on data collection and data and uses are provided by the list under "How We Disclose Information section". If an authorized agent makes a request on your behalf, we need both, a power of attorney or a written document where authorized agent has authority to act on your behalf. If both requirements are not presented at the time of the request from agent we are subject to deny it

Use of Personal Information

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the categories of third parties indicated in the chart below.

We may also disclose your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, we have [has NOT/HAS] sold the following categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights below.

Categories of Third Parties Business Purpose Disclosures Sales
Identifiers Payment processing, marketing, delivery services, customer relationship management, web hosting, or data storage None
California Customer Records personal information categories Payment processing, marketing, delivery services, customer relationship management, web hosting, or data storage None
Protected Classification Characteristics Marketing, customer relationship management, or data storage None
Commercial information Payment processing, marketing, delivery services, customer relationship management, web hosting, or data storage Remarketing, retargeting, and advertising providers
Internet or other similar network activity Marketing, customer relationship management, web hosting, or data storage Remarketing, retargeting, and advertising providers
Geolocation data Marketing, delivery services, customer relationship management, web hosting, or data storage Remarketing, retargeting, and advertising providers
Inferences drawn from other personal information Marketing, customer relationship management, web hosting, or data storage Remarketing, retargeting, and advertising providers

Your Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Access Specific Information and Data Portability Right

You have the right to request we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting or selling that personal information;
  • The categories of third parties with whom we disclose that personal information;
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Exercising Your Rights

To exercise the access, data portability and deletion rights described above, please contact us using the contact information provided in Section 15. The information necessary to process your request includes your name, address, telephone number, email address, and proof of residency. You will also be asked to provide details regarding the personal information you are requesting access to or have deleted from our systems, including without limitation, time frames, dates, names, types of documents, file numbers, or any other information to help us locate your personal information. Additional information may be requested.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make such a request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California Shine the Light Law

California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If