California Privacy Policy

California residents have certain additional rights with respect to their personal information under the California Consumer Privacy Act, as amended by the California Privacy Rights Act and implementing regulations (the “CCPA” California Civil Code section 1798.100 et seq.) and the Shine the Light Act (California Civil Code section 1798.83) (“California Rights”). For more information about your California Rights, please contact us in accordance with the “Contact Us” section of this Policy. If there is any discrepancy between this Policy and your California Rights, your rights under the California Privacy Policy shall prevail.

1. YOUR PRIVACY RIGHTS IN CALIFORNIA.

This policy is a supplement to our general privacy policy (“Policy“) for those persons covered by California law. All terms defined in the Policy shall retain the same meaning on this page. As used herein and in any of its supplemental policies, “Personal Information” has the same meaning as in the CCPA.

2. CALIFORNIA CONSUMER PRIVACY ACT.

California residents have the right to know, the categories and specific items of Personal Information we have collected, the purposes for which such information is collected or used, whether such information was sold, shared or disclosed to third parties, and the length of time we intend to retain such information.

California residents also have the right to (1) request deletion of any Personal Information collected; (2) request correction of inaccurate Personal Information; (3) request disclosure of information collected, including specific pieces of Personal Information; and (4) request disclosure of Personal Information sold or shared and to opt out of any such selling or sharing.

We will not discriminate against you if you exercise your rights under the CCPA. Requests regarding your information can be submitted by (1) calling our toll-free number at 1 (888) 331-0559 or (2) contacting us pursuant to the “Contact Us” section of our general Privacy Policy.

In order to verify your request, we will require you to submit personal information (such as an email address or telephone number) that will allow us to confirm that you are the consumer about whom we have collected information, or you are an agent authorized by the consumer to act on their behalf. We will review your request and either provide you with a notice that we have complied with your request or an explanation of why we were not able to comply with your request. You may appeal our determination by following the instructions included in a denial. Your authorized agent may make a request via the methods described above but must have access to your telephone number and/or email address and provide written authorization signed by you.

We are strongly committed to not sharing personal information with third parties. Under this Privacy Policy, we may share your information only under particular situations, as described in this Policy.

3. COLLECTION AND USE, DISCLOSURE AND SALE OF PERSONAL INFORMATION.

In general, in the previous 12 months, we have collected, used and disclosed the following categories of Personal Information: Identifiers, Characteristics of Protected Classifications under California or U.S. law (as described in the Privacy Disclosure Page below), Commercial information, Internet or other electronic network activity, Geolocation Data, Professional or employment-related information, inferences about you, and other categories of Personal Information that relate to, describe or can reasonably be associated with you.

For a list of the specific data we collect and may disclose, the sources from which we collect this personal information, and the personal information we use for business and marketing purposes, please visit our “Privacy Disclosure Page ” below.

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), the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; 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.

We do not knowingly sell or share the personal information of individuals under the age of 16.

4. CCPA OPT-OUT AND LIMITATION ON USE OF SENSITIVE PERSONAL INFORMATION.

We do not sell or share your personal information, including your sensitive personal information. California Civil Code Section 1798.121 permits users who are California residents to limit the use of their Sensitive Personal Information to only that which is necessary for providing products or services to consumers.

5. AUTOMATED DECISION MAKING.

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you if this position changes.

6. SHINE THE LIGHT ACT.

Residents may request certain information about our disclosure of Personal Information to third parties, including our information-sharing practices, including the names and addresses of companies with whom we have shared your personal information, for their direct marketing purposes. To make such a request, please contact us in accordance with the “Contact Us” section of our general privacy policy.

7. ADDITIONAL NOTICES

We may interact with you beyond your activity as a visitor to our Site. In the event that you and the company have a subsequent association, you may have modified and additional rights under California law or as set forth above. The company will notify you and inform you of such change of circumstances before collecting your personal data.

PRIVACY DISCLOSURE

1. CALIFORNIA INFORMATION.
This section explains your rights regarding the Personal Information we collect, as set forth in the CCPA. The following chart summarizes our Personal Information collection, use and sharing practices for the previous 12 months since we last updated this policy on April 1, 2025.

Information Category	Source of Information	Purpose of Collection	Other Parties To Which We Disclose This Information
Identifiers, such as your name, alias, address, e-mail address, user name, IP address, account name, SSN, driver’s license number or other government ID.	From you.	To process your requests for services, to communicate with you, to improve our services, to enforce our agreements, to enforce our terms of use, to register your account, for the administration and protection of our business, and to comply with applicable laws, regulations, and legal and regulatory processes.	Service providers who help provide services on our behalf.
Personal information categories described in the California Customer Records statute: Signature, physical characteristics or description, state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information^{^[1]}.	From you.	To process your requests for products or services, to communicate with you, to improve our services, to enforce our agreements, to enforce our terms of use, to register your account, for the administration and protection of our business, and to comply with applicable laws, regulations, and legal and regulatory processes.	Service providers who help provide services on our behalf.
Protected classification characteristics under California law, such as racial, ethnic, or national origin, religion, gender, or sexual orientation	N/A	N/A	N/A
Commercial information, records of products or services purchased, obtained or considered, or other purchase or consumption histories or trends	From you	To process your requests for products or services, to market to you, to improve our services.	N/A
Information about Internet or electronic network activity, for example, browsing history, search history, information about a consumer’s interaction with a website, application or advertisement.	From you or our service providers.	To improve our services, for the administration and protection of our business, and to comply with applicable law, regulations and legal and regulatory processes.	N/A
Geolocation data such as the time and physical location related to use of an internet website, application, or device.	N/A	N/A	N/A
Sensitive Personal Information including (1) biometric information for the purpose of uniquely identifying a consumer,(2) personal information collected and analyzed concerning a consumer’s health, (3) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation, and (4) other personal information including personal identification numbers (e.g. social security, driver’s license, and passport numbers), account or debit or credit card numbers combined with passwords or codes that enable access to the accounts, exact user geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, mail, email, or text message content (unless intentionally sent to us), and genetic data.	N/A	This is not considered Sensitive Personal Information under the CCPA because, it is not collected for the purpose of inferring your characteristics.	N/A

RETENTION.

We will retain categories of your Personal Information only for as long as necessary. We make this determination based on our relationship with you, applicable laws, and our data retention policies. We will retain each category of your Personal Information for as long as we have a relationship with you (e.g. for as long as you are a customer and for a reasonable period thereafter).

When determining how long to retain each category of Personal Information after we no longer have a relationship with you, we take into account how long our customers usually want to continue hearing from us, our legal obligations and the expectations of regulators, as well as the length of time information is needed for internal audit purposes and to exercise or defend our legal rights.

We also consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We review our retention periods for each category of Personal Information on a regular basis, and all data is retained in compliance with applicable data protection laws.