Supplemental Privacy Notice for California Residents

Effective Date: January 1, 2020

Last Revised: March 16, 2020

This Notice supplements the information in our Privacy Policy and applies solely to California Residents.  We adopt this Supplemental Notice to comply with the California Consumer Privacy Act of 2018 (CCPA). 

Information We Collect:

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information. 

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).  Personal information does not include: 

  • Publicly available information from government records. 
  • Deidentified or aggregated consumer information.

We or our service providers may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law): 

  • Our or our service provider’s operational purposes; 
  • Auditing consumer interactions on our site, including counting ad impressions and verifying the quality of ad impressions; 
  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity; 
  • Bug detection and error reporting;
  • Providing the Services (e.g., account servicing and maintenance, order processing and fulfillment, customer service, financing, advertising, marketing, analytics, and communication about the Services); 
  • Verifying and maintaining quality or safety or improving products and services owned, manufactured or controlled by or for the business; 
  • Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners; 
  • Other uses about which we notify you. 

 

Examples of these types of uses are identified below.  We may also use the below categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.  

Categories or Personal Information

Categories of Sources

Examples of Uses

Identifiers (such as real name, postal address, email address, unique personal or online identifier, account name, telephone number, social security or tax ID number, internet protocol (IP) address, and driver’s license or passport number) 

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Indirectly/automatically collected from you through use of our services 
 
Service providers 
 
Affiliates and partners 
 
Third parties 
 
Distributors

Providing you with the products, services and support you request; 
 
Processing your transactions and shipping your orders; 
 
To create, maintain, customize and secure your account with us;  
 
Communicating with you about your account or transactions, changes to our policies and other administrative matters, or your questions and comments; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Improving our products, services and operations; 
 
Ensuring compliance with our policies and the law, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others; 
 
For compliance purposes; 
 
To support the operation and to maintain proper functioning of the subscription service. 

Education, employment history, medical information, or health information (i.e., personal information categories described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Service Providers 
 
Third Parties 
 
Distributors 
 
Affiliates and partners 

 Providing you with the products, services and support you request; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Improving our products, services and operations; 
 
Ensuring compliance with our Company policies and the law, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others. 

Bank account number, credit card number, debit card number, or any other financial information (i.e., personal information categories described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Service providers 
 
Third parties 
 
Affiliates and partners 
 
Merchants 

Providing you with the products, services and support you request; 
 
Processing your transactions and shipping your orders; 
 
To create, maintain, customize and secure your account with us;  
 
Communicating with you about your account or transactions, changes to our policies and other administrative matters, or your questions and comments; 
 
Ensuring compliance with our Company policies and the law, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others; 
 
For compliance purposes; 
 
To support the operation and to maintain proper functioning of the subscription service. 

Characteristics of protected classifications under California or federal law (such race, gender and national origin) 

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Service providers 
 
Third parties 
 
Affiliates and partners 

Providing you with the products, services and support you request; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Ensuring compliance with our Company policies and the law, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others; 
 
For compliance purposes; 
 
To support the operation and to maintain proper functioning of the subscription service. 

Commercial information (such as transaction data) 

You 
 
Indirectly/automatically collected from you through use of our services 
 
Service providers 
 
Affiliates and partners 
 
Third parties 
 
Distributors 

Providing you with the products, services and support you request; 
 
Processing your transactions and shipping your orders; 
 
To create, maintain, customize and secure your account with us;  
 
Communicating with you about your account or transactions, changes to our policies and other administrative matters, or your questions and comments; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Improving our products, services and operations; 
 
Ensuring compliance with our Company policies the law, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others; 
 
For compliance purposes; 
 
To support the operation and to maintain proper functioning of the subscription service. 

Internet or other electronic network activity information (such as browsing history, search history, or information regarding a consumer’s interaction with an internet website, application, or advertisement)

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Indirectly/automatically collected from you through use of our services 
 
Service providers 
 
Third parties 
 
Affiliates and partners

Providing you with the products, services and support you request; 
 
Communicating with you about your account or transactions, changes to our policies and other administrative matters, or your questions and comments; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Improving our products, services and operations; 
 
To support the operation and to maintain proper functioning of the subscription service. 

Geolocation Data (general location and precise GPS location)

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Indirectly/automatically collected from you through use of our services

Providing you with the products, services and support you request; 
 
Processing your transactions and shipping your orders; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Improving our products, services and operations.

Sensory information (such as audio recordings if you call our customer service) 

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Indirectly/automatically collected from you through use of our services

Providing you with the products, services and support you request; 
 
Processing your transactions and shipping your orders; 
 
To create, maintain, customize and secure your account with us;  
 
Communicating with you about your account or transactions, changes to our policies and other administrative matters, or your questions and comments; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Improving our products, services and operations; 
 
For compliance purposes; 
 
To support the operation and to maintain proper functioning of the subscription service. 

Inference data about you 

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Indirectly/automatically collected from you through use of our services

Providing you with the products, services and support you request; 
 
To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; 
 
Improving our products, services and operations; 
 
To support the operation and to maintain proper functioning of the subscription service. 

Other information that identifies or can be reasonably associated with you (such as user-generated content)

You (e.g., forms you complete on our sites or profiles you create in our applications) 
 
Indirectly/automatically collected from you through use of our services 
 
Service providers 
 
Affiliates and partners 
 
Third parties 

To better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials. 

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.  For each of the above categories of personal information, we may share your personal information with the following categories of third parties: service providers, data aggregators, internet cookie data recipients, operating systems and platforms, affiliates,  and parent or subsidiary organizations. 

Rights

If you are a California resident, you may have certain rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 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 share that personal information. 
  • The specific pieces of personal information we collected about you (also called a data portability request). 
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and 
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

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.  

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you. 
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
  3. Debug products to identify and repair errors that impair existing intended functionality. 
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at the email below: 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  To designate and authorized agent to make a request on your behalf, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf.  You may only make a verifiable consumer 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 certify you are the person about whom we collected personal information or authorized representative, which may include your account number, or other pieces of personal information we may already possess, or in certain circumstances, a signed declaration under penalty of perjury that you are the consumer, or someone legally authorized to act on your behalf. 
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.   

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.   

You may have the right to receive information about the financial incentives that we offer to you.  You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights.  Certain information may be exempt from such requests under applicable law.  We need certain types of information so that we can provide the services to you.  If you ask us to delete it, you may no longer be able to access or use the Site. 

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. 

The California Consumer Privacy Act (CCPA) sets forth certain obligations for businesses that “sell” personal information.  Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past 12 months. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt of initial request.  If we require more time, we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Shine the Light

Residents of the State of California also have the right to request from companies conducting business in California a list of all third parties, if any, to which the company has disclosed personal information during the preceding year for direct marketing. We comply with this law by offering California residents the ability to tell us not to share your personal information with third parties for their direct marketing purposes. To make such a request, please email us at: 

You must specify “California Resident” as the subject line, and your full name, email address, and postal address in your message.

Changes to Our Privacy Notice

We reserve the right to amend this Supplemental Privacy Notice at our discretion and at any time.  When we make changes, we will post the updated Supplemental Privacy Notice on the website and update the effective date.  Your continued use of our website following the posting of changes to this Supplemental Privacy Notice constitutes your acceptance of such changes. 

CA Resident Verifiable Consumer Request

Subject: California Resident

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