Privacy Notice

NextRoll is a technology company that provides intelligent, data-driven marketing and advertising services and solutions to help big and small companies (“Customers” or “Advertisers”) accelerate their growth. NextRoll’s proprietary data and machine learning (“NextRoll Technology”) powers our Services across all of our business divisions including:

• AdRoll offers a technology platform for companies that sell their products and services directly to consumers (called “Direct to Consumer” or “D2C” companies). The AdRoll platform provides D2C companies with advertising and marketing solutions to enable them to sell more to their existing consumers, and also to identify new consumers to whom they can sell their products and services. AdRoll does this by creating connected, personalized customer journeys, including digital advertising, email marketing and onsite experiences, and helps companies understand the impact of their marketing with advanced measurement and attribution; and
• RollWorks offers an account-based platform for businesses who want to sell their products and services to other businesses (called “B2B” companies). Our RollWorks Services help B2B companies identify their target accounts and key buyers, reach those accounts across multiple channels, and measure program effectiveness in their system-of-record.

The NextRoll website(s) are a collection of sites that we use to describe our Services to potential customers, to provide our Services to our Customers, and to support Customers and partners as they seek to identify, deploy and measure their marketing and advertising efforts with us over time.

For more information on the data collected through our Services, please see our Service Privacy Notice.

Data You Provide To Us

• Contact Information: You may provide us with your name, address, phone number and email when you set up an account with us and you may provide your name, title, company, email, address and/or phone number when you sign up for an event with us online or download content from our site.
• Account Information: If you open an account, we will collect your username and password and other information necessary to open and access your account.
• Customer Service Information: Information you may provide to our customer service including your email address for purposes of responding to your inquiries and survey responses.
• Financial Information: Credit card number or other payment account information. This information is collected directly by our payments processor and not stored at NextRoll.
• Hashed email addresses: We collect hashed versions of the email addresses that consumers have entered on that Advertiser’s site. Hashing is a technology process that pseudonymizes (i.e. digitally scrambles) email addresses. For instance, when joe_the_cat@nextroll.com is run through a typical hashing function, it becomes the following string of digits: 0F0B7B1A1A7E8BDBBC6AA545F8CCD6F83671B32479271BFCB6CC8498912058D5. We take this step to de-identify data and protect email addresses, while being able to use the unique identifier created for the purpose of recognizing you and sending your interest-based ads across different devices (computers, tablets and mobile devices) and browsers (also called “cross-device matching”). We describe cross-device matching in further detail in How We Use the Data We Collect.

Data We Automatically Collect From Your Device

• Device Information: This is technical information about the device you use to access our websites such as your device’s IP address and operating system. Additionally, in the case of mobile devices, your device type, and mobile device’s unique advertising identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifier that may be assigned to the mobile device, such as an Android ID or UDID in older Apple phone models, or a non-cookie unique identifier used by Non-Cookie Technologies.
• Browser Data: This is technical information about the browser you are using that is captured in order to serve you an ad that can be rendered on your device. An example of browser information is the technical information that identifies your browser as, for example, Chrome, Firefox, Safari etc.
• Activity on our Digital Properties: This is data about your browsing activity on our websites, or when you interact with our other tools or dashboards.. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, whether you downloaded a white paper.
• Location Data: This is non-precise information related to your geography derived from your device’s IP address (e.g. laptop, desktop or mobile etc.). This does not reveal your precise geographic coordinates (i.e. your GPS latitude and longitude) – only country, state, city and zip/postal code level location data, and helps us to display ads that are relevant to your general location (for example, showing ads in French if you are located in France).
• Ad Data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.

Data We Collect from Third Party Sources

• Data from Advertising Partners: This is data that allows us to match the NextRoll cookie identifier with identifiers that may already be used by other companies in the digital advertising ecosystem that we work with (“Advertising Partners”), for example, ad exchanges or companies that sell advertising space on publishers’ websites (sometimes referred to as “supply side platforms”). Matching cookie identifiers help us deliver ads to you and recognize you across browsers and devices, and may include pseudonymous advertising identifiers (meaning identifiers that help identify your browser or device, but not you directly) which some third party advertising platforms choose to share with us. We may work with our Advertising Partners to synchronize their unique, pseudonymous identifiers to our own to enable us to more accurately recognize a particular unique browser or device and the advertising interests associated with it (commonly known as “ID Syncing”).
• Contact Data from Third Parties. We obtain and collect contact data from various third party sources, including from public sources and through licenses with data providers. This contact data is B2B information – in other words, it is typically a business email address, business street address, or sometimes, a business telephone number.
• Attribute Data: We may collect additional information about you from other third party sources where they have the rights to share such information and we have the rights to use it, for example, demographic data or title and employer data. We use this data to better understand our Customers and to better market our Services to you.

We use this data to operate our business and provide Services to you as well as to serve ads that aim to be more relevant to you. Specifically, we use this data for:

• Providing our Services and Customer Support: For example, to monitor usage of features, manage campaigns, and log data for audit purposes. We may contact you when you ask us for support or when it appears to us that you might need support, and to maintain records of our communications with you for future reference.
• Invoice you and collect fees for services we have provided.
• Troubleshoot Problems: To monitor and fix our website performance, for example if the site is slow, not loading properly, or to investigate aberrations in performance of our Services.
• Prevent Potential Fraud and Enforce our Terms of Service. To prevent fraud on our sites or through the use of our Services; to enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law; or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
• Customize, Measure and Improve our Websites and Services: To provide customized content and to measure which content is most helpful (or unhelpful) to our Customers, which helps improve our website and our services. For example, if we notice higher visits to certain Help Center articles or receive higher customer support tickets for specific issues, we can improve our support materials or identify areas where we can make our product better for our customers.
• Contact You About Your Account or our Services, Including to Market our Services to You or Provide Updates: We may use your contact information to contact you about your account, for example, in relation to the performance of your campaigns, to follow up on billing issues, or to tell you about new Services we are offering. We may send you product updates, performance information, surveys, or communicate with you in other ways about our services. When we can legally do so, we may augment the information you give us in order to contact you by phone or even snail mail. You can opt-out of receiving emails by unsubscribing through the link at the bottom of our emails or by updating your email preferences here. You can let us know if you don’t want to receive phone calls or other marketing materials from us by contacting support@nextroll.com.
• Interest-Based Advertising: Selecting ads that are more likely to be relevant to you based on data such as your browsing activity, the time of day you visit our Digital Properties and the time you spend on them, and non-precise geographic data inferred about your device/s. For example, we may show you ads for our Services only available in your city, region or country during your lunch or commute hours. For more information about how our Services work, please see our Service Privacy Notice.
• Frequency Capping: Making sure that you don’t see the same ad too many times.
• Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.
• Cross-Device Matching: Identifying different devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices, and so that campaign effectiveness can be measured and analyzed. For example, cross-device matching helps us not show you ads for the shoes you were looking at on your phone but already purchased on your tablet. Instead we’ll try to show you ads for an upcoming triathlon where you can put those shoes to work. It also helps us match devices so we can honor your opt-out choices across all devices we know are connected to the opted-out cookie. You may opt-out of cross-device interest-based targeting by employing the respective opt-out techniques we describe in Your Choices and Opting-Out of Targeted Ads. To learn more about how we use cross-device matching, click here.
• Attribution: Monitoring when, where, and at what price we served certain ads so that we can measure our influence on the marketing result of our campaigns and overall marketing strategy. For example, being able to measure if a certain ad campaign (the ads shown and to whom they were shown) actually led to a potential customer becoming a paying Customer.
• Reporting: Analyzing how our ads are performing and gaining insights into our Customers and prospective customers. Reporting may include ad metrics such as attribution (described above), impressions (ads served), clicks (ads you clicked on), and conversions (for example, if you create an account with us or download a white paper from our site). This helps us identify ads that are useful to our Customers and demonstrate NextRoll’s value, and relatedly, helps us identify an ad that is not performing well (prospective customers aren’t clicking on it), we will be able to see that data and update our ad or ad campaign strategy.
• Conducting Our Corporate Operations. As to data we collect in our corporate capacity – our own B2B lists of Customers and prospective customers – we use that data to conduct our business operations and communications.
• Complying with Legal Process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
• Investigating Wrongdoing and Protecting Ourselves or Third Parties: To enforce our Terms of Service or other policies or investigate any potential violation of our Terms of Service and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).

We may disclose data about you:

• With our Service Providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
• With our Subsidiaries and Affiliates: But they will only process your data for the purposes already explained in this Website Privacy Notice. Our subsidiaries are NextRoll Limited (Ireland), AdRoll Limited (UK), and NextRoll Pty Limited (Australia).
• With our Advertising Partners: We also share data with our Advertising Partners, including hashed email addresses (or other pseudonymous identifiers associated with those hashes), device information, browser data, activity on our Digital Properties, location data and our CRM Data. This enables them and us to better personalize ads to you.
• In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of NextRoll, our Customers or any other third party.
• In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).

NextRoll may aggregate and de-identify data it collects so that it can either no longer be directly associated with a natural person or cannot be associated with a natural person at all. It may then use such data for its business purposes including the provision interest-based advertising and reporting in the course of its Services.

We may also share aggregated and de-identified data with our subsidiaries and affiliates and third parties, including with our Advertising Partners. For example, we may conduct industry wide surveys to publish benchmark reports, or to include statistics when collaborating with researchers or other companies on industry white papers.

Our websites use cookies, tracking pixels and related technologies to operate and personalize our sites. For example, to provide personalized content on our site, enable customer service chat functionality, for analytics purposes, and to target ads to you about our products and services on other websites.

We also use cookies, tracking pixels and related technologies to provide our services for our Customers. Cookies are small data files that are served by our platform and stored on your device. You can refuse consent to, or opt-out of, NextRoll cookies at any time, as explained in Your Choices and Opting-out of Interest-Based Advertising and Analytics below. For more information regarding data associated with cookies, please refer to Data Retention.

Tracking cookies enable us to identify your device when you move between different Digital Properties, so that we can serve targeted advertising to you.

• Specifically, the NextRoll cookie we serve through the NextRoll platform for this purpose is named “__adroll” and “__adroll_fpc”.

Our Advertising Partners may also drop cookies for the purposes described in What Data We Collect. Generally, the type of cookies dropped will vary depending on the Advertising Partner. We provide a list of our Advertising Pixel Partners here.

Additionally, we use non-tracking cookies (not unique) to store user decisions in terms of your ad consent and opt-out choices:

• We may drop an __adroll cookie with value opt-out if you opt-out as described below.
• We may drop a __consent cookie that stores the consent choices you have made regarding data processing and advertising by NextRoll.

In respect of website visitors with IP addresses not from a European Territory, NextRoll and some of our Advertising Partners may use technologies other than cookie technology to recognize your computer, device or browser for the purpose of interest-based advertising, analyzing engagement with ads or content, measuring the effectiveness of a particular ad campaign or marketing effort, to monitor against fraud or misuse of our Services, or in other ways described in this Website Privacy Notice in How We Use the Data We Collect. This use of non-cookie technology may be used in addition to cookies, or separately, to collect and record data about your web browsing activities on browsers, search engines or other platforms that may not utilize NextRoll Technology. You may opt-out of tracking via non-cookie technologies by employing the respective opt-out techniques described in Your Choices and Opting- Out of Interest-Based Advertising and Analytics Ads.

We recognize how important your online privacy is to you, so we offer the following options for controlling the interest-based ads you receive and how we use your data.

Opting-out of this type of advertising will not prevent you from seeing ads, rather, those ads will likely be less relevant. This is because they will not be tailored to your specific interests but will instead be based on the context of the Digital Property in which they are displayed or the ads you see may be randomly generated.

Here’s how you can control how we use your data:

• Web browser: You can opt-out of receiving interest-based ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by clicking here. Please note that this “opt-out” function is browser-specific and relies on an “opt-out cookie”. This means if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again.
• Cross Device Opt-Out: In some cases we may link multiple browsers or devices to you. If you opt-out on a browser or device and we have more linked to you, we will extend your opt-out decision to the other linked browsers and devices. Since we only link users across browsers and devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
• Mobile Device Opt-Out: To opt-out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:
  • iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting; and
  • For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Select Ads > Enable “Opt out of interest-based advertising”.
• Industry Opt-Out Tools and Self-Regulation:
  • NextRoll is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. You may use the NAI opt-out tool here, which will allow you to opt-out of seeing personalized ads from us and from other NAI approved member companies. In addition, the NAI opt-out tool allows you to separately opt-out of “audience matched” advertising through the NAI’s “Audience Matched Advertising Opt-Out” tool. Audience matching is a particular type of interest-based advertising where de-identified data (e.g. hashed emails) is tied to “offline” activity or information (generally, information that is or can be associated with a consumer’s email address) and matches that de-identified data to cookies, mobile ad IDs, or other online identifiers. We describe this hashing activity in detail in What Data We Collect. Because this “audience matched” information is derived from an email address or information that can be tied to an email address, it is possible to opt-out with an email address. However, when you opt-out in this way, you will need to submit all of the email addresses that you use for the opt-out to work.
  • We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt-out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
  • We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt-out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.
  • Finally, we also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt-out via their ”Your Online Choices” website here.
• Reminder to Users Residing in a European Territory: If you are located in a European Territory you will also have additional data protection rights. These are described Information for European Territory Residents: Our Legal Basis and Your Rights.

You can also request that we stop email marketing to you. You can use the unsubscribe link in our marketing emails or contact support@nextroll.com.

We retain data for as long as necessary to perform our Services and for the purposes described in this Website Privacy Notice. For example, we may retain:

• billing information as necessary to meet audit requirements;
• login information to confirm when Terms of Service were accepted; and
• information as long as necessary to meet legal requirements, resolve disputes or enforce agreements.

We retain cookie data such as device and browser information, ad data, and data collected on our Digital Properties as follows:

• Mobile Identifiers and Cookie Identifiers: Cookie identifiers we collect expire (and are then deleted) 13 months from the last time your device accessed a Digital Property using our technology. If you visit another Digital Property that uses NextRoll Technology inside that 13-month expiry period, then the expiry period will be reset and measured from that date instead. The expiration period for mobile identifiers is controlled by the end-user on their own device.
• Personal Data Associated with Mobile and Cookie Identifiers Related to Browsing History: We delete personal data associated with mobile and cookie identifiers after 12 months. For example, data such as an Advertiser’s website you visited or ads that you may have clicked.
• Personal Data Associated with Advertising Bidding Requests: Data logged in order to process an advertising bid request we have received from an Advertising Partner (such as cookie identifier, IP address, the domain url requesting to display the ad, and browser information) are deleted after 14 days. Data we have logged regarding bids we have placed to display an advertisement (including cookie identifiers, mobile identifiers, the advertisable bid on, and the advertisable won or displayed to the end-user) are deleted after 30 days.
• Personal Data Associated with the Display of an Advertisable: Data logged for the display of an advertisable (including cookie identifiers, the advertisable won or displayed to the end user and data indicating whether an end user clicked on the particular advertisable displayed) are deleted after 12 months.

We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.

We may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. In general, these countries will be the countries in which we or our service providers operate.

Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Website Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.

For example, when we transfer your information from a European Territory (as defined below) to our parent company in the United States, we do so under the European Commission’s Standard Contractual Clauses. When we transfer your data outside of a European Territory to Advertising Partners (or vice versa), we do so under lawful data export mechanisms which may include Standard Contractual Clauses, EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and Binding Corporate Rules.

Our Legal Basis: We provide the representations and information in this section in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). If you are a visitor from the European Territories, our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it. “European Territories” mean the European Economic Area and Switzerland. For the purpose of this Website Privacy Notice, the term “European Territories” shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit.

Specifically:

• We will normally collect personal data from you where the processing is in our legitimate interests. For example, to administer our platforms and provide our Services and fulfil our contractual obligations as a service provider.
• In some cases we may collect, and process personal data based on consent. For example, when you visit one of our Digital Properties, you will be asked to consent to NextRoll dropping a cookie.

If you have questions or need further information concerning the legal basis on which we collect and use your personal data, please Contact Us.

European Residents Privacy Rights: If you are a resident of a European Territory, you have the following enhanced rights under EU data protection law:

• If you wish to access, correct, update or request deletion of your personal information, please complete the information on this webpage to obtain a verifiable request.
• If you wish to object to us processing your personal data or would like to otherwise restrict the processing of your personal data, we will honor that request. Please visit the Your Choices and Opting-Out of Interest-Based Advertising and Analytics portion of this Privacy Notice to select the best opt-out method for you.
• Similarly, if we process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. You can also refuse consent for NextRoll or our Advertising Partners to drop cookies by clicking here or by refusing consent for NextRoll when you see a “consent banner” displayed on our websites which lists NextRoll (formerly AdRoll and Semantic Sugar) as a vendor.
• You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Territories are available here. However, if you have any questions about our collection and use of your personal data, we encourage you to contact us first at support@nextroll.com. If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer at dpo@nextroll.com.

This section supplements the information contained in this Website Privacy Notice and applies solely to visitors, users, and others who are residents of the State of California, as defined in Section 17014 of Title 18 of the California Code of Regulations. This section is effective as of January 1, 2020, to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

Any terms defined in the CCPA have the same meaning when used in this section.

For the purposes of this section “Services” shall mean performing advertising and marketing services for NextRoll’s purposes as well as maintaining or servicing NextRoll Customer accounts, providing Customer service, processing or fulfilling orders and transactions, verifying customer information and processing payments.

Information We Collect and the Purposes for Which this Information is Used

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). This collection of information is listed in What Data We Collect.

We set out below the CCPA categories of personal information we have collected from consumers within the last twelve (12) months who are NextRoll Customers and/or visitors of the NextRoll’s Digital Properties. Personal information in certain categories may overlap with other categories.

For clarity, under CCPA personal information does not include:

• Publicly available information from government records;
• De-identified or aggregated consumer information; and
• Information excluded from the CCPA’s scope such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Purposes for Which Personal Information is Collected

The data we collect pursuant to this Website Privacy Notice is for the business purpose of performing advertising and marketing services for our own purposes as well as maintaining or servicing our Customer accounts, providing Customer service, processing or fulfilling orders and transactions, verifying customer information and processing payments (“Services”). However, as part of performing these Services, we also use data collected (as identified above) for the following additional business purposes:

• • Auditing Interactions with Consumers: count ad impressions and verify the quality of ad impressions served to unique visitors identified by cookie id or other unique identifier;
  • Debugging and Repair: the identification and repair of impairments to intended and existing functionalities in our Services and NextRoll Technology, perform debugging and related activities to repair errors that impair the functionality of our Services;
  • Security: detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities;
  • Internal Research and Development: conduct internal research for technological development of our Services and demonstration of the performance of these Services; and
  • Quality and Safety Maintenance and Verification: Verify the quality or safety of our Services and improve, upgrade or enhance our Services and NextRoll Technology.

For more information on how we use this data, please refer to How We Use the Data We Collect.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose (as set out above) or sell your personal information, subject to your right to opt-out of those sales (See Personal Information Sales Opt-In Rights).

The Data Sharing section sets out the personal information that we share with third parties.

Disclosures of Personal Information for a Business Purpose

NextRoll’s performance of its Services do not amount to a sale of personal information. Instead, NextRoll discloses personal data for business purposes.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for our business purposes:

• Category A: Identifiers;
• Category B: California Customer Records personal information categories; and
• Category D: Commercial information;

We disclose your personal information for a business purpose to the categories of third parties set out in Data Sharing.

Sales of Personal Information

We do not consider that the performance of our Services constitutes a ‘sale of personal information’ under the CCPA. Instead, in the course of performing our Services, we disclose personal information for business purposes.

However, we aim to provide consumers with control over the collection and use of their personal information. Consistent with this goal, we will honor requests from consumers to “opt-out” of the collection and disclosure of their personal information. Your Rights and Choices section below provides instructions on how to opt-out of our collection and disclosure of personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes the rights of California residents under CCPA and provides information on how to exercise those rights.

Right to Know and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of 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 (otherwise known as a data portability request); and
• Two separate lists where we have sold or disclosed your personal information for a business purpose:
  • 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

Right to Delete

You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Data Portability and Right to Deletion), we will delete (and direct our services 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:

• 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 relations with you or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• 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;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; and
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Right to Know, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit verifiable consumer request to us by either.

• Calling us at 1-844-740-7126; or
• Visiting this webpage.

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 a verifiable request for access of 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: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

As mentioned above in Sales of Personal Information, we have elected to honor sale opt-out rights. Please see Personal Information Sales Opt-Out and Opt-In Rights.

Personal Information Sales Opt-Out Rights

To exercise the right to opt-out of interest-based advertising, you (or your authorized representative) may submit a request to us by visiting the Do Not Sell My Personal Information webpage.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

We may update or modify this Website Privacy Notice at our discretion and at any time. When we make changes to this Website Privacy Notice, we will post the updated notice online and update the notice’s effective date. Please review this Website Privacy Notice periodically.

If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.