FloLogic Product and Mobile App Privacy Policy

Product and Mobile App Privacy Policy

Introduction

FloLogic, Inc., a North Carolina corporation (“Company” or “We”), respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

The types of information (including personal information) we may collect or that you may provide when you download, install, register, access, or use the FloLogic Leak Detection & Auto Water Shutoff System (the “Product”), the FloLogic App and any other available mobile device applications used in connection therewith, whether available through mobile, tablet, browser-based, PC-based, or smart device-based systems and interfaces (together with all related documentation, the “App”), and the software and functionality contained in the Product or any other interface device used in connection therewith (collectively, the “Service”, and together with the Product and the App, the “Covered Products”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect through any of the Covered Products, whether accessed and/or used on or through a mobile device, PC, browser-based interface, or smart-device interface, and in email, text, and other electronic communications sent through or in connection with any of the Covered Products.

This policy DOES NOT apply to information that:

We collect offline or on any other Company apps or websites, including websites you may access through the App. The privacy policy for our website https://www.flologic.com) is located at https://www.flologic.com/website-privacy-policy/.
You provide to or is collected by any third party (see Third-Party Information Collection). A third party will generally have their own privacy policies, which we encourage you to read before providing information to such third party.

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, do not download, install, register with, or use any of the Covered Products. By downloading, installing, registering with, or using any of the Covered Products, you agree to the terms and conditions of this policy and agree to allow us to collect and process information as described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of any of the Covered Products after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates. Each time that you access and use any of the Covered Products you are (a) certifying the accuracy of your representations and warranties made herein and in every document incorporated herein by reference, and (b) acknowledging and agreeing to be bound by the covenants herein and in every document incorporated herein by reference.

If you are a California resident, please see the Section of this policy entitled California Privacy Rights.

Individuals Under the Age of 18

The Covered Products are not intended for individuals under 18 years of age. No one under age 18 may provide any information (personal or otherwise) to, through, or on any of the Covered Products. We do not knowingly collect information (personal or otherwise) from individuals under 18. If you are under 18, do not use or provide any information to, through, or on any of the Covered Products or any of their features, register on the App, make any purchases through the App, use any of the interactive or public comment features of the App (if any), or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from an individual under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights and California Privacy Rights for more information.

Information We Collect and How We Collect It

We collect information from and about users of the Covered Products:

Directly from you when you provide it to us.
Automatically when you use the Covered Products.

Information You Provide to Us

When you download, register with, or use any of the Covered Products, we may ask you provide information:

By which you may be personally identified, such as first name, last name, mailing/property address, email address, telephone number, country, state, and ZIP/postal code, and any other identifier by which you may be contacted online or offline (“personal information”).
That is about you but individually does not identify you.
That is about your home/property, including information regarding your Wi-Fi network.

The information you provide to us includes:

Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use any of the Covered Products and requesting further services. We may also ask you for information when you report a problem with any of the Covered Products.
Records and copies of your correspondence, whether by email, web forms, messages, or phone (including email addresses, phone numbers, the content of such correspondence and recordings of such correspondence), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.
Details of any account you maintain with us, including passwords, user IDs, and log-in information.
Information you provide to us regarding your property insurance policy, including the carrier of such policy, the policy number, and other information related to such insurance policy.

You may also provide information for publication or display (“Posted”) on public areas of the App or websites you access through the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Prior to making any User Contributions, you represent and warrant that you have obtained all permissions (including permissions from third parties) necessary to Post such User Contributions.

We also collect information, including personal information, that you choose to provide to us from time to time.

Information We Collect Through Automatic Data Collection Technologies

When you download, access, and use any of the Covered Products, we may use certain technology to automatically collect:

Information Related to the Covered Products. We may, either now or in the future, collect the following types of information:
- Data from the Product’s sensors and system, including but not limited to alarms, notifications, user preferences, settings, and user actions. The Product’s sensors collect data such as current flow rate, temperature, and pressure rate of your water system. This helps the Product protect your home and detect leaks. Information about leaks, notifications or alarms delivered through the Covered Products, and any actions you take in response to those notifications are also collected. We may share this data with third parties, including third parties that you authorize to receive such data by the terms of this policy or otherwise.
- Other data collected by the Product via third party systems you’ve authorized the Product to communicate with.
- Direct adjustments to the Covered Products, including modifications or settings.
- Technical information from the Covered Products, including, without limitation, model number, serial number, and software version.
- System data obtained by the Covered Products from third party systems, including security alarms, irrigation systems, water heaters, water conditioners and other water related appliances.
App and Mobile Device Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App. We may request, and you may grant, access to certain mobile device functions, such as SMS, and precise location (non-continuous) in connection with your use of the App (see Device Permissions for Information Access).
Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, Wi-Fi network, operating system, browser type, mobile network information, and the device’s telephone number.
Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Location Information. The App may collect real-time information about the location of your device.
Personal Information. The Covered Products may collect information that is personal information.

Unless specified otherwise, all information and permissions requested by the Covered Products are required for the Covered Products to property function. In instances where the Covered Products expressly state that certain information or permissions are not required, you are free to refuse disclosure of such information or granting of such permissions, as applicable, without affecting the functioning of the Covered Products. Inquiries regarding the information and permissions that are required to be provided in order for the Covered Products to properly function may be directed to [email protected].

If you do not want us to collect this information do not access or use any of the Covered Products and delete the App from your devices.

We also may use certain technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

Some web browsers may transmit “do-not-track” (“DNT”) signals to mobile applications with which the user communicates. We currently do not change our tracking practices in response to DNT settings in your web browser.

Our third-party partners, such as web analytics companies and third party ad networks, may collect information about you and your online activities over time and across the App. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.

We and our third-party providers may use cookies, pixels, tags, and other similar tracking mechanisms to automatically collect information about browsing activity, type of device and similar information within the Covered Products and to target advertising and content across the Covered Products and third-party sites and services. We use this information to, for example, analyze and understand how users access, use and interact with others through the Covered Products, as well to identify and resolve bugs and errors in the Covered Products and to assess, secure, protect, optimize and improve the performance of the Covered Products.

The technologies we use for automatic information collection may include:

Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts and features of the Covered Products.
Web Beacons. Pages of the App and our emails 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 or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use any of the Covered Products or their content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

Advertisers, ad networks, and ad servers.
Analytics companies.
Your mobile device manufacturer.
Your mobile service provider.
Your property insurance carrier.

These third parties may use tracking technologies to collect information about you when you use the Covered Products. 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, apps, and other online services websites. 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 Your Choices About Our Collection, Use, and Disclosure of Your Information.

We may collect information about you through affiliates, business partners, authorized representatives, advertising networks, data analytics providers, social networks, Internet service providers, operating systems and platforms, government entities, public databases, data brokers, and vendors and service providers who provide services on our behalf.

Device Permissions for Information Access

Depending on your specific device, the Covered Products may request certain permissions that allow them to access your device information as described below. By default, these permissions must be granted by you before the respective information can be accessed. Once the permission has been given, it can be revoked by you at any time. In order to revoke these permissions, you may refer to the device settings or contact the Company as provided for herein. The exact procedure for controlling permissions may be dependent on your device and software. Please note that the revoking of such permissions might impact the proper functioning of the Covered Products. If you grant any of the permissions listed below, the respective information may be processed (i.e. accessed to, modified or removed) by us and the Covered Products.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, Wi-Fi network, or the status of any ongoing calls.

Precise location permission (non-continuous)

Used for accessing your precise device location. The Covered Products may collect, use, and share your location information in order to provide location-based services. Your geographic location is determined in a manner that isn’t continuous. This means that it is impossible for the Covered Products to derive your exact position on a continuous basis.

SMS permission

Used for accessing features related to your messaging including the sending, receiving and reading of SMS.

Phone address book

The Company allows users to add additional users to control the Product. For convenience, you can select these users from your device’s contact address book. When a user indicates they wish to add an additional user to control the Product by providing such additional user’s email address, an invitation email is generated and automatically sent to the additional user.

How We Use Your Information

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

Provide you with the Covered Products and their contents, and any other information, products, or services that you request from us.
Fulfill any other purpose for which you provide it.
Give you notices about your account.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when updates to the Covered Products are available, and of changes to any products or services we offer or provide though the Covered Products.
Provide, develop evaluate, and improve the Covered Products.
Help us make sales, marketing, and business decisions and carry out research.
Help us run our day-to-day operations and otherwise enable you to use the Covered Products and their features and functionality.
Communicate with you.
Carry out marketing and promotional activities.

The usage information we collect helps us to improve the Covered Products and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.
Monitor the use and effectiveness of the Covered Products.
Store information about your preferences, allowing us to customize the Covered Products according to your individual interests.
Recognize you when you use the Covered Products.

We may also use your information to contact you about the Company’s own and third-parties’ goods and services that may be of interest to you. If you do not want the Company to use your information in this way, please contact the Company at [email protected].

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may also use the information we collect about you or that you provide to us, including any personal information, to comply with certain user data sharing agreements between certain insurance carriers and the Company. Such insurance carriers may use such information, including information related to access and/or use of the Covered Products for, among other things, the purpose of underwriting property insurance policies and monitoring compliance with the terms and conditions of such property insurance policies. To facilitate the use of information as provided for in this paragraph, users may be prompted to enter certain information regarding their insurance carrier(s) through the App, and through any other means as may be established by the Company from time to time.

Disclosure of Your Information

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

In addition, we may disclose personal information that we collect or you provide:

To our subsidiaries and affiliates.
To contractors, vendors, service providers, and other third parties we use to support our business.
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 FloLogic Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by FloLogic Inc. about the users of the Covered Products is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To third parties, such as home insurance or home warranty providers, for purposes of monitoring the status of the Covered Products and your usage of the Covered Products.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us, including the Product Terms of Service and End User License Agreement found at https://www.flologic.com/product-terms-of-service-and-eula/ and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FloLogic, Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also disclose the information we collect about you or that you provide to us, including any personal information, to certain insurance carriers pursuant to the terms and subject to the conditions of certain user data sharing agreements between such insurance carriers and the Company. Such insurance carriers may use such information, including information related to access and/or use of the Covered Products for, among other things, the purpose of underwriting property insurance policies and monitoring compliance with the terms and conditions of such property insurance policies. To facilitate the disclosure of information as provided for in this paragraph, users may be prompted to enter certain information regarding their insurance carrier(s) through the App, and through any other means as may be established by the Company from time to time.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

Tracking Technologies. 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 or block the use of other tracking technologies, some parts or features of the Covered Products may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the Covered Products to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts or features of the Covered Products may become inaccessible or not function properly.
Promotion by 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 with your request to [email protected].
Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email with your request to [email protected].
Disclosure of Your Information for Third-Party Advertising and Marketing. 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 sending us an email with your request to [email protected].

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.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights and California Privacy Rights for more information.

Accessing and Correcting Your Information

The Company would like to make sure you are fully aware of all of your data protection rights. Every user of the Covered Products is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request that the Company complete information you believe is incomplete.
The right to erasure – You have the right to request that the Company erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that the Company restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to the Company’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact the Company at [email protected].

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
Data portability.
Opt-out of personal data processing for:
- targeted advertising (excluding Iowa);
- sales; or
- profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please contact the Company at [email protected].

Nevada provides its 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 [email protected].

Data Security and Processing

We have implemented a variety of measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use industry standard security measures for protecting information, data collected, and data storage.

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 the Covered Products, 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 and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through any of the Covered Products. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Information collected in connection with your use of the Covered Products is processed using computers or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Company, information collected in connection with your use of the Covered Products may be accessible to persons involved with the operation of the Covered Products (administration, sales, marketing, legal, system administration, etc.) or external third parties appointed, if necessary, as information processors by the Company. An updated list of these parties may be requested from the Company at any time by sending a request to [email protected].

Retention and Disposal of Information

We retain your information as long as we determine it is required for the operation of our business and to meet legal, regulatory, and other requirements. We take reasonable steps to ensure that information is disposed of securely when we no longer require such data.

Cross-Border Transfers of Personal Data

Your information, including your personal information, may be collected, processed and stored by the Company or its service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using any of the Covered Products in the European Union or other regions with laws governing data collection and use that may differ from United States law, you consent to the transfer of your personal data to the United States and other countries where the Company operates.

Changes to Our Privacy Policy

We may update this policy from time to time. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on our website home page.

The date this 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 this policy to check for any changes.

How to Contact the Appropriate Authority (GDPR Compliance Only)

Should you wish to report a complaint under the General Data Protection Regulation (GDPR) or if you feel that we have not addressed your concerns regarding our compliance with the GDPR in a satisfactory manner, you may contact the Information Commissioner’s Office via the email address, phone number, or mailing address provided on the following website: https://ico.org.uk/.

Contact Information

To ask questions or comment about this policy and the Company’s privacy practices, contact the Company at [email protected].

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the “CCPA”) provide you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold; the right to request that we delete personal information that we have collected from you; the right to update or correct your information; the right to opt-out of the sale or sharing of your personal information; the right to limit our use of your sensitive personal information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions.

Any capitalized terms in this California Privacy Rights Section that are not otherwise defined have the same meaning as they do in the CCPA. This California Privacy Rights Section also serves as our “Notice at Collection” under California law. All terms defined in this Section shall only have such defined meanings with respect to this Section.

Collection of Personal Information

If you access or use any of the Covered Products, we may collect 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 (“personal information”). We may have collected the following categories of personal information over the past 12 months:

Identifiers, such as name, email address, physical address, and Internet Protocol address.
Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as name, address, and telephone number.
Characteristics of protected classifications under California or federal law, such as age, race, and gender.
Internet or other electronic network activity information, such as cookies.
Inferences drawn from any of the information identified above.

We collect the personal information listed above from the following sources:

From you directly, when you provide it to us.
From other sources in the course of our business.
Automatically from the Covered Products.

Disclosure of Personal Information

In the last 12 months, we may have disclosed for our business purposes the following categories of personal information subject to the CCPA:

Identifiers, such as name, email address, physical address, and Internet Protocol address.
Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as name, address, and telephone number.
Characteristics of protected classifications under California or federal law, such as age, race, and gender.
Internet or other electronic network activity information, such as cookies.
Information related to use of the Covered Products.
Sensitive personal information, such as information about racial or ethnic origin.
Inferences drawn from any of the information identified above.

We may have disclosed or shared any of the information listed above with:

Third-party service providers supporting our operations.
Analytics providers, to help analyze the data that we collect.
Other third parties for a legal purpose (such as in response to a court order or to defend against a legal claim).
Other third parties when necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party.

Purposes for Collection and Disclosure

We may collect personal data for one or more of the following business purposes:

To provide, maintain and improve the Covered Products; to monitor and analyze trends, usage and activity related to the Covered Products.
To detect, investigate and prevent fraudulent transactions and other illegal activities as well as protect the rights and property of the Company and others.
Warranty support for the Covered Products.
Service and functionality support for the Covered Products.
Product registration.
To complete product order requests.
To respond to product inquiries.
To respond to requests about product information or where and how to have the Covered Products installed.
To respond to complaints about the Covered Products
Legal defenses.
Sales related purposes.
Purposes otherwise described in this policy.
To comply with certain user data sharing agreements between certain insurance carriers and the Company. Such insurance carriers may use such information, including information related to access and/or use of the Covered Products for, among other things, the purpose of underwriting property insurance policies and monitoring compliance with the terms and conditions of such property insurance policies.

Your Rights

If we maintain personal information about you that is subject to CCPA, you may exercise certain rights in connection with this data if you are a California resident.

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve 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.
The categories of personal information that we have disclosed for a business or commercial purpose.
Our business or commercial purposes for collecting, selling, or sharing personal information.
The categories of third parties with whom we share or disclose that personal information.
The specific pieces of personal information we collected about you (i.e., a data portability request).

Right to Delete

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers/contractors to delete) your personal information from our records, unless an exception applies.

Right to Correct

California residents have the right to correct or amend the personal information we have on file. You may correct or amend by logging into your account or by contacting us at [email protected].

Right to Opt-Out of Sale or Sharing

The CCPA provides California residents with the right to opt-out of the “sale” or “sharing” of their personal information. In the last 12 months, we have not sold or shared any categories of personal information subject to the CCPA. We also do not have actual knowledge that we sell or share the personal information of California residents under the age of 16.

Right to Limit the Use of Your Sensitive Personal Information

The CCPA provides California residents with the right to limit the use of their “sensitive personal information” to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations.

We do not use your sensitive personal information for any purposes outside of those permitted by § 7027(m).

Right to Non-discrimination

The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights

If you are a California resident and wish to exercise any of the above rights, you may submit a request to us by email at [email protected].

When you submit a request, we will confirm your identity by asking you to provide information associated with what we have on file for you, including your name, email address, and other identifying information. We may ask you for additional information to verify your identity or to comply with your request.

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

Data Retention

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

Shine the Light Law

In addition to the CCPA, California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information for these purposes.

Contact for More Information

If you wish to contact us regarding this California Privacy Rights Section, you may do so by email at [email protected].