RecodeX logo

Privacy

Privacy Policy Notice for Website Users

Micro-Processor Services, LLC (“MPSLLC”), doing business as RecodeX  ("Company""We", or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy.  THIS NOTICE DESCRIBES HOW YOUR PERSONAL DATA MAY BE PROCESSED BY US AND WHAT YOUR RIGHTS ARE WITH RESPECT TO YOUR PERSONAL DATA.  PLEASE REVIEW IT CAREFULLY.

This Notice is being provided to you in accordance with the requirements of Florida Law, the EU or UK General Data Protection Regulation (the “GDPR”), CCPR and CPRA (California), and the Global data privacy and protection mandates of other jurisdictions (e.g., Canada’s PIPEDA, Australia’s APP, Brazil’s LGPD, etc.).

This policy describes the types of information we may collect from you or that you may provide when you visit any website operated by Us (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On the Website.

In email, text, and other electronic messages between you and the Website.
Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website.
Through mobile and desktop applications that you access on or through the Website.

It does not apply to information collected by:

Us offline or through any other means, including on any website operated by any third party; or

Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see “Changes to Our Privacy Policy”) and/or may be affected by the location or venue from which you are accessing our website (see specific provisions below on GDPR (EU) Compliance, CCPR and CPRA (California) Compliance, and Global Compliance). Your continued use of this Website after we make changes is deemed to be acceptance of those changes and/or acknowledgement of the specific provisions, so please check the policy periodically for updates.

PERSONS UNDER THE AGE OF 18

We strive to comply with the Children’s Online Privacy Protection Act (COPPA). Our Website is not intended for persons under 18 years of age. We do not aim any of our products or services at children under the age of 18.  No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from persons (“minors”) under 18 years of age. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a minor under 18, please contact us at:

[email protected]

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

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

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, IP address, and similar usage details, as set forth in more detail below.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and web beacons.

Information You Provide to Us. 

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, purchasing our services or products, posting material, or requesting further services.
  • Records and copies of your correspondence (including email addresses) if you contact us.
  • Your responses to surveys that we may ask you to complete.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website. We do not collect this information from you. We may use a third-party payment processing company (“Payment Processor”) to bill you and process your payments for orders made on our Website. The processing of payments will be subject to the terms, conditions and privacy policies of the Payment Processor. For more information, please see our Terms of Use located at https://recodex.co/terms.
  • Your search queries on the Website.

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

Information That We Collect Through Our Current Automatic Data Collection Technologies.

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

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.
  • Improve user experience.

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

  • Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse or opt out of cookie data collection, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies.Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons.Pages of our Website 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 website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Other tracking technologies, such as tags and scripts, may also be used to collect and track information and to improve and analyze our Website.

HOW WE USE YOUR INFORMATION

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

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us by sending an e-mail to [email protected]. For more information, see Choices About How We Use and Disclose Your Information.

DISCLOSURE OF YOUR PERSONAL INFORMATION

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

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

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MPSLLC’s assets, including RecodeX, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MPSLLC or RecodeX about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MPSLLC or RecodeX, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising.You can set your browser to refuse or opt out of all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company.If you do not wish to have your contact information used by us to promote our own or third parties' products or services, you can opt out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to us as a result of a product purchase, warranty registration, product service experience, or other transactions.

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.

ACCESSING AND CORRECTING YOUR INFORMATION

You may send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. 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.

DATA SECURITY

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

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

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

GDPR COMPLIANCE (EU & UK)

What is “Personal Data” and “Processing”?

Notwithstanding the foregoing, under the GCPR, “Personal Data” means any information relating to an identified or identifiable Data Subject; specifically including, but not limited to, name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that Data Subject.  A Data Subject is an identifiable natural person, i.e., one who can be identified, directly or indirectly, in particular, by reference to Personal Data. Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. “Process” and “processed” have a corresponding meaning.

The GDPR prohibits the processing of “special categories” of Personal Data unless certain exceptions apply, because this type of data could create more significant risks to a Data Subject's fundamental rights and freedoms. For example, an unauthorized disclosure of “special categories” of Personal Data may put Data Subjects at risk of unlawful discrimination. For this purpose, processing of “special categories” of Personal Data includes processing of: (i) Personal Data that reveals; (A) racial or ethnic origin, (B) political opinions, (C) religious or philosophical beliefs, or (D) trade union membership; or (ii) (A) genetic data, (B) biometric data for the purpose of uniquely identifying a natural person, (C) data concerning health; or (D) data concerning a natural personal's sex life or sexual orientation.

How and When Do We Collect Your Personal Data?

We may lawfully collect your Personal Data in a number of ways for legitimate purposes, for example: (i) from the information you provide to us when you visit our website https://www.recodex.co or otherwise interact with us before ordering, for example when you express your interest in our products or services; (ii) when you communicate with us via our website, for example in order to make inquiries or raise concerns; and (iii) in various other ways as you interact with us on our website, for the various purposes set out below.

The Types of Personal Data We Process

We may process (i.e., collect and keep) the following types of Personal Data about you: (i) your name and your contact information, i.e., local and permanent address, email address and telephone number; (ii) your date of birth, gender and gender identity, and Social Security (or other identification number) [which generally you do not need to provide]; (iii) your country of domicile and your nationality; (iv) information about your academic and your extracurricular interests and activities; and (v) certain other information you may be asked to provide in connection with any online forms available on our website.

 If you are asked to create an account on our website for any reason, we may ask you to provide your: name, e-mail address,  telephone number, organization name, address, not-for-profit status, and credit card information. The legal basis for processing your personal information is that it is necessary in order for you to enter into a contract to provide the stated products or services to you.

We also may collect background information about you when you use our website, including your IP address, date and time of connection, and the webpages you visit. We also employ cookies on our website. For information about how we use cookies on our websites, please see https://www.recodex.co/privacy

How We Use Your Personal Data

The lawful and legitimate purpose for which we may use Personal Data (including “special categories” of Personal Data) we collect while you visit our website is that it is necessary for the performance of a contract with you, including to: (i) respond to your request for information about RecodeX; (ii) send our newsletters or other information; (iii) enable your attendance at a RecodeX events; and (iv) enable you to purchase products or services from our website or at company events.

The lawful and legitimate purposes for which we may use other Personal Data (including “special categories” of Personal Data) we collect while you visit our website (e.g., the background information such as IP address, date and time, and the webpages you visit) is that it is in our legitimate interests to provide and monitor the usefulness of our website and to ensure it is kept secure.

Why We Process Your Personal Data

As set out above, we may process your Personal Data because it is necessary for the performance of a contract with you (e.g., if you create an account or are purchasing something on our website), or in     order to take certain actions at your request (e.g., to send you a brochure). The legal basis for processing your personal information is that it is necessary in order for you to enter into a contract to provide the stated products or services to you.

Where we have determined that the legal basis for processing your Personal Data is that it is necessary for the purposes of our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms. You may ask us to explain our determination at any time by contacting us, as explained below.

How We Share Your Personal Data

For the purposes referred to in this Notice, and relying on the bases for processing as set out above, we may share your Personal Data with certain third parties in accordance with applicable law and with our officers,  employees, agents, independent contractors,  consultants, and trainees where there is a legitimate reason for their receiving the information, including: (i) third parties who work with us to provide services; (ii) third parties who are contracted to provide IT services for us; (iii) organizations operating anti-plagiarism software on our behalf; (iv) internal and external auditors, attorneys, and other professional service providers; (v) government officials and agencies where we have a statutory and  legal obligation to provide information; (vi) police and other law enforcement agencies; (vii) third parties conducting surveys, and (viii) third parties who collect standard internet log information and details of your visitor behavior patterns so that we can monitor, for example, the number of visitors to each page on our website.

 We do not sell, trade, or otherwise transfer your Personal Data to outside parties, except as explained herein. This does not include trusted third parties who assist us as noted above in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We also may release your Personal Data when we believe release is appropriate to comply with the law, enforce our website policies, or protect ours or others' rights, property, or safety. However, notwithstanding the foregoing, non-personally identifiable website visitor information (i.e., information that has been “pseudonymized” as described in the GDPR) may be provided to other parties for marketing, advertising, or other uses without restriction.

Retention of Your Personal Data

RecodeX will process (collect, store and use) the information you provide in a manner compatible with Florida law, the GDPR (EU & UK), California law (CCPA and CPRA), and the relevant Global retention regulations of other jurisdictions (e.g., Canada’s PIPEDA, Brazil’s LGPD, etc.). We will strive to keep your information accurate and up to date and not keep it for longer than is necessary.  Your Personal Data will be stored in accordance with our retention policy, which is governed in part by Florida law.  

Please be informed that: 1) The period for which your personal data will be stored will be from now until no longer needed for compliance with U.S. and Florida laws; 2) You can withdraw your consent, if granted, at any time and even only orally, but this will not affect the lawfulness of processing your personal data based on your consent before withdrawal; 3) and you have legal rights and remedies against any breach of your personal privacy according to articles 77 to 84 of the GDPR (EU).

Your Rights with Respect to Your Personal Data

Under the GDPR, you have a number of rights with respect to your Personal Data. You have the right, in certain circumstances, to request: (i) access to your Personal Data, (ii) rectification of mistakes or errors and/or erasure of your Personal Data, (iii) that we restrict processing, and, (iv) data portability.

In certain circumstances, you also may have the right to object to processing of your Personal Data. 

If requested, and you provided your explicit consent for the processing of your Personal Data (or where a parent or legal guardian provided consent on your behalf because you were under the age of 18 at the time consent was required), you (or your parent or legal guardian, as applicable) have the right (in certain circumstances) to withdraw that consent at any time. However, withdrawal of consent will not affect the lawfulness of the processing before your consent was withdrawn.

If you would like more information about, or if you would like to exercise any of these individual rights, please contact our Data Protection Officer (contact information is below).

CALIFORNIA PRIVACY RIGHTS

California's "shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

For additional information about our compliance with the California CPPA and CPRA, please see below.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Questions/Concerns/Complaints

If you have questions, concerns or complaints about how we are using your Personal Data, we may be able to resolve your complaints, and we request that you contact the Data Protection Officer (contact information is below). You also have the right to lodge a complaint with the applicable Supervisory Authority if you believe that we have not complied with the by requirements of U.S. and Florida law, the GDPR, California law, or the mandates of any other jurisdiction pertinent to your Personal Data.

Relevant RecodeX Contacts

RecodeX may be a “controller” and also may be a “processor” (as those terms are used in the GDPR) of your Personal Data for the purposes of the GDPR. If you have any questions or concerns as to how your Personal Data is collected and/or processed by RecodeX, you can contact: RecodeX Data Protection Officer at: [email protected]

CCPA Privacy Policy & Notice

This CCPA Privacy Notice (“Notice”) supplements the information contained in RecodeX’s (“we”, “us,” or “our”) above mentioned Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers,” “you,” or “your”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably 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.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:

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), clinical trial data, or other qualifying research data;

Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

The personal information that we collect, use or disclose about you will depend on our relationship or interaction with you. During the past twelve months, we have collected the following categories of personal information:

Category

Examples

Collected

Category:
A. Identifiers.
Examples: 
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol 
address, email address, account name, Social Security number, or other similar identifiers. 
Collected:
YES
Category:
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: 
A name, signature, Social Security number, physical characteristics or description, address, telephone
number, education, employment, employment history, or any other financial information.
Some personal information included in this category may overlap with other categories.
Collected:
YES
Category:
C. Protected classification characteristics under California or federal law.
Examples: 
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital
status, medical condition, physical or mental disability, sex (including gender, gender identity, gender
expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic information).
Collected:
YES
Category:
D. Commercial information.
Examples: 
Records of personal property, products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
Collected:
NO
Category:
E. Biometric information.
Examples: 
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a
template or other identifier or identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or
exercise data.
Collected:
NO
Category:
F. Internet or other similar network activity.
Examples: 
Browsing history, search history, information on a consumer’s interaction with a website, application,
or advertisement.
Collected:
YES
Category:
G. Geolocation data.
Examples: 
Physical location or movements.
Collected:
NO
Category:
H. Sensory data.
Examples: 
Audio, electronic, visual, thermal, olfactory, or similar information.
Collected:
NO
Category:
I. Professional or employment-related information.
Examples: 
Current or past job history or performance evaluations.
Collected:
YES
Category:
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: 
Education records directly related to a student maintained by an educational institution or party
acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification
codes, student financial information, or student disciplinary records.
Collected:
NO
Category:
K. Inferences drawn from other personal information.
Examples: 
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions,
behavior, attitudes, intelligence, abilities, and aptitudes.
Collected:
YES

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our website.
  • We may also collect information about you from third parties.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information.
  • To provide, support, personalize, and develop our website, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your website and mobile application experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, mobile application, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our website, mobile application, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our website, mobile application, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users/consumers is among the assets transferred.

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

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

In the preceding twelve (12) months, we have not sold or shared (for the purposes of cross-context behavioral advertising) any of your personal information.

Personal Information Category

Category of Third-Party Recipients

Business Purpose Disclosures

Sales (or Sharing for Cross-Context Behavioral Advertising)

Personal Information Category:
A. Identifiers.
Business Purpose Disclosures:
Service providers; Business partners; Analytics providers; and Other parties
you may authorize
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
B: California Customer Records personal information categories.
Business Purpose Disclosures:
Service providers; Business partners; Analytics providers; and Other parties
you may authorize
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
C: Protected classification characteristics under California or federal law.
Business Purpose Disclosures:
Service providers; Business partners; Analytics providers; and Other parties you may authorize
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
D: Commercial information.
Business Purpose Disclosures:
Service providers; Business partners; Analytics providers; and Other parties you may authorize
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
E: Biometric information.
Business Purpose Disclosures:
None
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
F: Internet or other similar network activity.
Business Purpose Disclosures:
Service providers; Business partners; Analytics providers; and Other parties you may authorize
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
G: Geolocation data.
Business Purpose Disclosures:
None
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
H: Sensory data.
Business Purpose Disclosures:
None
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
I: Professional or employment-related information.
Business Purpose Disclosures:
Service providers; Business partners; Analytics providers; and Other parties you may authorize
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
J: Non-public education information.
Business Purpose Disclosures:
None
Sales (or Sharing for Cross-Context Behavioral Advertising):
None
Personal Information Category:
K: Inferences drawn from other personal information.
Business Purpose Disclosures:
Service providers; Business partners; Analytics providers; and Other parties you may authorize
Sales (or Sharing for Cross-Context Behavioral Advertising):
None

Reselling Personal Information

The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. We have not engaged in the sale of personal information in the preceding twelve (12) months. We reserve the right to sell personal information to third-parties that may resell that information. In the event we decide to sell your personal information to third parties, you will be notified before we do so and have an opportunity to opt-out.

Your Rights and Choices

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

Right to Know and Data Portability

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 twelve (12) months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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.
  • 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.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information 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.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by emailing us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a twelve (12)-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include:
    • Verifying your name and email address.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  We will only use personal information provided in the request to verify the requestor’s identity or authority to make it. For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten (10)-day timeframe, please contact [email protected].

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), 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.

Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically via email unless otherwise agreed.

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.

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.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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

Other California Privacy Rights

California’s “Shine the Light” law (California Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated version on the website and update the Notice’s “Last Updated” date at the top of the Notice. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have questions about this Notice, please contact us at:

Email: [email protected]

To ask questions or to comment about the foregoing privacy policies and our privacy practices, contact us at: [email protected]

linkedin facebook pinterest youtube rss twitter instagram facebook-blank rss-blank linkedin-blank pinterest youtube twitter instagram