California Consumer Privacy Rights

California residents have additional rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (CCPA). This section supplements the information contained elsewhere in this privacy policy and applies solely to individuals who reside in California. Any terms defined in the CCPA have the same meaning when used in this notice.

Please note the following rights are not absolute, and we may be entitled to refuse requests, wholly or in part, where exceptions under the CCPA apply.

    1. Right to Know the Personal Information We Collect About You – You have the right know:
      • The categories of Personal Information we have collected about you;
      • The categories of sources from which the Personal Information is collected;
      • Our business or commercial purpose for collecting or selling Personal Information;
      • The categories of third parties with whom we share Personal Information, if any; and
      • The specific pieces of Personal Information we have collected about you.
Please note that we are not required to:
      • Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
      • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
      • Provide the Personal Information to you more than twice in a 12-month period.
Please note that we are required to update the information required to be disclosed under the CCPA at least once every 12 months.
    1. Right to Access the Personal Information We Collect About You –You have the right know:
      • You have the right to access Personal Information that we may collect or retain about you.  If requested, we shall provide you with a copy of your Personal Information which we collected as permitted by the CCPA.
      • You also have the right to receive your Personal Information in a structured and commonly used format so that it can be transferred to another entity (“data portability”).
    2. Right to Opt-Out/Do Not Sell or Share My Personal Information –In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know:
      • The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold or shared; and
      • The categories of Personal Information that we sell or share about you for a business purpose.
      • You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale or sharing of your Personal Information. If you exercise your right to opt-out of the sale or sharing of your Personal Information, we will refrain from selling or sharing your Personal Information, unless you subsequently provide express authorization for the sale of your Personal Information.
      • To opt-out of the sale or sharing of your Personal Information, visit our information removal page and fill out the form here.
Please note that it is our policy not to sell or share any Personal Information for any business purpose.  Therefore, we have not sold to a third party any Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Therefore, in the preceding 12-months, and except as expressly described in this Privacy Policy, we have not disclosed to a third party any Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
    1. Right to Deletion—Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
      • Delete your Personal Information from our records; and
      • Direct any service providers to delete your Personal Information from their records.
      • Please note that we may not delete your Personal Information if it is necessary to:
      • Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
      • Debug to identify and repair errors that impair existing intended functionality;
      • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
      • Comply with the California Electronic Communications Privacy Act;
      • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
      • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
      • Comply with an existing legal obligation; or
      • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
    2. Right to Correct/Right to Rectification – In certain circumstances, you have the right to request correction of any inaccurate Personal Information.  Upon verifying the validity of a valid consumer correction request, we will use commercially reasonable efforts to correct your Personal Information as directed, taking into account the nature of the Personal Information and the purposes of maintaining your Personal Information.
    3. Right to Request That We Do Not Share or Disclose My Sensitive Personal Information– You have the right to limit how your sensitive Personal Information is disclosed or share with third parties, as defined in the CCPA. We do not collect any sensitive Personal Information.
    4. Protection Against Discrimination—You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
      • Deny goods or services to you;
      • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
      • Provide a different level or quality of goods or services to you; or
      • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
To Exercise Your Rights under the CCPA—If you would like to exercise any of your rights as described in this Privacy Policy, please make a “Data Subject Request” by: Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. You will need to provide us with:
  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.