Privacy Notice – Purpose Group

1. PURPOSE OF THIS PRIVACY NOTICE

This Privacy Notice (“Privacy Notice”) sets out how Purpose Group (“we”, “us” or “our”) processes your personal information in connection with our business, including the provision of our website at https://ohgpurposegroup.com (“Site”) and the services we offer (“Services”).

In particular, this Privacy Notice explains our approach to any personal information that we might collect from you (i) when you use our Site or Services (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal information we collect, why we collected it and your rights in respect of our processing of your personal information).

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Cookie Notice and Terms of Use.

If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please see the section 21 of this Privacy Notice called “California Consumer Privacy Statement” by clicking here.

To the extent certain US states provide residents with specific rights regarding their personal information, please see the section 22 entitled “US State Privacy Rights” for more information by clicking here.

2. SCOPE OF THIS PRIVACY NOTICE

This Privacy Notice only applies to the use of your personal information obtained by us, whether from you directly or from a third party. It does not apply to personal information collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control).

3. CHANGES TO THIS PRIVACY NOTICE

We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal information, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal information. If we update this Privacy Notice, we will update the effective date at the top of the page.

4. ABOUT US

The Purpose Group LLC

200 Varick Street, 4th Floor, New York, NY 10014

5. HOW TO CONTACT US

If you have any questions about this Privacy Notice or want to exercise your rights as set out in this Privacy Notice, you can contact us by post at the address above or by email using the address below:

Email	Send us an email at: [email protected]
Post	Write to us at: 200 Varick Street, 4th Floor, New York, NY 10014

6. TYPE OF INFORMATION WE COLLECT/PROCESS

When we talk about personal information we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or by other factors that are specific to them, such as their physical appearance. Categories of personal information we may collect and process about you include:

Identity Data	First name; last name.
Contact Data	Delivery address; billing address; email address; telephone number; social media handle.
Applicant Data	Date of birth; gender; country; nationality; CVs, work experience; dietary requirements; any other information that you may provide in advance of/during your supply of services to us.
Image Data	Photos; video recordings.
Financial Data	Bank account details; partial payment card details.
Transaction Data	Details about payments made between you and us; details of services purchased from us.
Profile Data	Interests and preferences; contact preferences; whether you have participated in any promotions or competitions; feedback and survey responses; the content of any messaging you send using any Contact Form or Chat function on the Site.
Behavioral Data	Data relating to your browsing activity, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any services you viewed through the Site.
Health Data	Data relating to health and health interests
Technical Data	IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
Marketing and Communications Data	Marketing preferences; service communication preferences.
Publicly Available Data	Information about articles (or similar) that you may have published; Information about your interests or affiliations or publicly stated positions on political matters, corporate matters and similar.

For more information about the information we collect please refer to the ‘How we use Personal Information’ section.

7. HOW WE COLLECT PERSONAL INFORMATION

We may collect and receive your personal information using different methods:

Information you provide to us	You may give us your information directly, for example, when you obtain services via our Site or other sites that we operate on behalf of our clients, contact us with questions, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.
Information we collect automatically, including using cookies and other similar technologies	When you access and use our Site, we may collect certain Behavioral Data and Technical Data automatically, including through our use of cookies and other similar technologies (see the ‘Website insight and analysis’ section).
Information received from third parties	We may receive information about you from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide our Site and our Services.
Publicly available information	From time to time, we may collect information about you (Identity Data, Contact Data, or Publicly Available Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

8. WHO WE COLLECT PERSONAL INFORMATION ABOUT

We collect and process personal information from the following people:

Site visitors	We will collect and process your personal information in connection with your interaction with us and our Site, or other sites that we operate on behalf of our clients.
People who contact us with questions	If you contact us with a question through our Site, or other sites that we operate, submit a complaint or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal information in connection with your interaction with us and our Site.
Client personnel	We may collect and process your personal information in connection with the supply of services to you and/or your organization.
Talent	If you supply services and/or content to us and/or work with us to provide services to our clients (including featuring in content we produce), we may collect or process your personal information, such as your Identity Data, Contact Data, Financial Data, CVs in connection with such supply of services and/or content to us and our clients.
Partner/supplier personnel	If you (or your organization) supply products or services to us or otherwise partner with us, we may collect and process your personal information in connection with our receipt of those products and services and/or partnership. This may include personal information included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data.
Visitors to our offices	If you attend one of our physical offices or other locations, we may process personal information that you volunteer in connection with your visit and any inquiries you make. For example, you may volunteer personal information when signing in as a guest, or when you register for and access our guest Wi-Fi network at our premises. Security camera footage may also be collected for security purposes.
Job applicants	If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal information in connection with your application.
Members of the public	We may process your data in connection with the provision of the Services to our clients.

9. HOW WE USE PERSONAL INFORMATION

A: OPERATION OF SITE, PROVISION OF SERVICES AND MARKETING

I. Operation of the Site

If you browse our Site

When you browse our Site, or other sites we operate, we may process Technical Data, including through our use of essential cookies and other similar technologies, to provide our Site to you.

If you link to social media sites and interact with our social media pages

If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site), we and the relevant social media platform may receive personal information relating to such interaction and may share your personal information in connection with this purpose. Where that data is collected through your use of our Site, the data may include certain Behavioral Data and Technical Data. For more information about how we use this information, please see the ‘Website insight and analysis’ section.

The relevant social media platform may also be a controller in respect of the personal information that is collected via your use of our social media pages and may use that information for additional purposes. For details of how the relevant social media platform uses your personal information, please see the privacy notice of the relevant social media platform.

Website insight and analysis

We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site. The data that is collected includes Behavioral Data and Technical Data, and certain Profile Data.

We and our third-party partners use this data to analyze how you use our Site and our Services and the effectiveness of our Site and Services, including:

to analyse how you use, and the effectiveness of, our Site and Services;
to improve our Site and Services;
to count users who have visited our Site and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site and Services;
to measure the effectiveness of our content;
to learn what parts of our Site are most attractive to our users, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see;
to help us understand the type of marketing content that is most likely to appeal to our visitors and customers.

II. Provision of our Services

Content creation.

As part of our content creation services to clients, we manage and maintain websites for our clients which collect information including Identity Data, Contact Data and Health Data. We collect this data on our client’s behalf and in order to provide our Services.

Client data insight and analysis.

We may, acting on our own behalf and on behalf of our clients, collect data about you in connection with the provision of our Services to carry out insight and analysis on an anonymized and/or aggregate basis so that we can improve our services and help our client to better understand their own customers’ interests and improve their products/ services. The data that is collected includes Behavioral Data and Technical Data, and certain Profile Data.

Client administration.

We may collect personal information about our client and potential client contacts to enable us to respond to client requests, to administer client accounts with us, to conduct credit checks (if permitted by applicable law), and to verify and carry out financial transactions for payments made to us. The data that is processed includes Identity Data and Contact Data, and certain Transaction Data.

III. Marketing and Media Questions

Marketing.

We may use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organization you represent) marketing communications by email or via phone. Our marketing will include press releases and information about us.

Media and informational inquiries.

We may collect information (including Identity Data, Contact Data and Publicly Available Data) about client contacts or industry contacts for interview requests, for media questions, or other requests for information. We may also provide individuals with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Where an individual signs up to receive such information, Contact Data may be requested in each case, together with details of other information that is relevant to these inquiries. This information is used in order to enable us to respond to individual requests or media requests.

B: BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL

Receipt of services.

If we have engaged an organization to provide us or our clients with services (for example, IT support or financial advice), we will collect and process your information (including Contact and Identity Data) if you are a contact within the relevant organization in order to manage our relationship or our clients with the organization, to receive services from the organization and, where relevant, to provide our services to others including our clients.

Recruitment.

If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual. We use such information for the following purposes: a) to assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelancer positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application; b) to take any steps necessary to enter into any contract of employment (or otherwise) with the individual; c) to comply with any regulatory or legal obligations in relation to any such application; and d) to review our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation.

Visiting our premises.

If an individual visits any of our premises we may collect information including Identity or Contact Data as part of our sign in process. We may also capture their image on our surveillance camera.

If an individual registers as a guest user for free Wi-Fi access at any of our premises, we may collect information including Identity and Contact Data as part of the registration process. We may also process Behavioral and Technical Data in connection with any use of this free Wi-Fi service for monitoring and record-keeping purposes, including to identify the source of service requests, optimize and maintain performance of the Wi-Fi service, and investigate and prevent system abuse.

Business administration, finance, and legal compliance.

We may use an individual’s information (including Identity Data, Contact Data, Financial Data, Transaction Data, Publicly Available Data) for the following business administration and legal compliance purposes:

To facilitate the operation or effective management of our group of businesses;
For financial, accounting and tax purposes;
To comply with our legal obligations;
To enforce or protect our legal rights;
To deal with complaints;
To protect the rights of third parties (including where health or security of an individual is endangered (e.g. a fire);
In connection with a business transition or sale such as a merger, re-organization, acquisition by another company, or sale of all or a portion of our assets;

10. IF YOU FAIL TO PROVIDE YOUR INFORMATION

Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the information we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

We only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations.

We are part of the Omnicom Group of marketing and advertising firms and (subject to the above) may share personal information within Omnicom Group companies, Omnicom Networks, or with our partner agencies. For more information about the Omnicom Group, please see here: Advertising and Marketing Agencies | Omnicom Group.

Further (again subject to the above) we may share your personal information with third parties, as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties.

Our clients	We may share personal information with our clients for the purposes of providing them with Services.
Third-party IT suppliers	We may share personal information with third parties who support us in providing our Site and help provide, run, and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centers around the world, and personal information may be stored in any one of them.
Payment providers and banks	We may share personal information with third parties who assist us with our invoicing and/or making/receiving payments.
Third-party email marketing and CRM specialists	We may share personal information with specialist suppliers who assist us in managing our marketing database and sending out email marketing communications.
Recruitment agencies and related organizations	We may share personal information with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies for recruitment purpose.
Auditors, lawyers, accountants and other professional advisers	We may share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies	We may share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties	Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfill requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

12. ONWARD TRANSFERS

Transfers by us – where we disclose personal information

As we are a company located in the United States, you acknowledge and agree that any data that is provided directly to us may be stored in this country. We may also transmit your personal information to other third parties outside of this country as listed above in ‘SHARING YOUR PERSONAL INFORMATION’ and more specifically to the offices of other global Omnicom Group entities, networks, or partners agencies.

13. OBTAINING YOUR CONSENT

Where our use of your personal information requires your consent, you can provide such consent:

at any time by providing your personal information to us; or
by providing your consent to us by e-mail, post or phone using the contact details set out in this Privacy Notice.

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

14. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal information under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal information on our behalf) are obliged to respect the confidentiality of the personal information of all users of our Site and those who purchase our Services.

15. ACCESS

To the extent required by applicable law, we will provide you with reasonable access to the personal information maintained about you and a reasonable opportunity to correct, amend or delete the information where it is inaccurate or has been processed erroneously, as appropriate. We may limit or deny access to personal information where permitted by law (such as where the burden or expense of providing access would be disproportionate or where the rights of third parties would be violated).

You may exercise these rights verbally or in writing by using our contact information provided in the section entitled ‘How to contact us’ above. We will endeavor to promptly respond to your requests and will respect time frames set by local legislation where applicable.

Please note that in order for you to assert these rights we may need to verify your identity to confirm your right to access your personal information. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal information from you than we currently have.

16. OPT OUT AND UNWANTED COMMUNICATIONS

To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the ‘How to contact us’ section.

17. ENFORCEMENT RIGHTS AND MECHANISMS

We will ensure that this Policy is observed and duly implemented. If at any time you believe that your personal information has been processed in violation of this Policy, or if you have any inquiries or complaints about the use or limitation of use of your personal information, you may send a request to us at the contact information in the section entitled ‘How to contact us’ above.

18. THIRD PARTY LINKS AND SERVICES

This Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal information with such third party.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

19. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We retain personal information only for as long as is necessary for the purposes described in this Privacy Notice, after which it is deleted from our systems.

If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate we may keep your personal information for a short period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list so that we know not to send you further marketing communications in the future.

20. INFORMATION OF MINORS

Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect information of minors. However, due to the nature of our organization and the Services we provide, we may from time to time collect and process information relating to minors. If we do collect information of minors, we will comply with all applicable laws and regulations relating to the processing of information of minors.

21. CALIFORNIA CONSUMER PRIVACY STATEMENT

This California Consumer Privacy Statement (“Statement”) supplements the Purpose Group Privacy Notice. It applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to Purpose Group personnel. Sections 2-5 of this Statement do not apply to job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Sensory Information: audio, electronic, visual, and similar information
Employment Information: professional or employment-related information
Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our online Privacy Notice and for the following business purposes specified in the CCPA:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Debugging to identify and repair errors that impair existing intended functionality
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Managing career opportunities with Purpose Group.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

Directly from you, such as when you contact us with a question
From your devices, such as when you visit our Site
Vendors who provide services on our behalf
Social networks
Government entities

Sale of Personal Information

We do not and will not sell your personal information.

Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information	Category of Third Party
Identifiers	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Additional	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Protected Classifications	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Commercial	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Online Activity	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Employment Information	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Education Information	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Inferences	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: Government entities.

California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access or deletion request (or to submit a request as an authorized agent on behalf of a consumer), email us at the address provided in the section entitled ‘How to contact us’ above. For questions or concerns about our privacy policies and practices, please contact us as described in the section entitled ‘How to contact us’ above.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: your email address, the name of the Purpose Group representative with whom you typically interact, and the date of your last interaction with a Purpose Group representative. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

22. U.S. STATE PRIVACY RIGHTS

The Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and similar laws in other U.S. states (“State Privacy Laws”) provide consumers in those states with specific rights regarding their personal information. To the extent that you are a resident of one of these states, this notice describes your rights under the State Privacy Laws and explains how you may exercise these rights.

The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in this notice above.

Right to Know. You have the right to know whether we process your personal information and to access such personal information.

Right to Data Portability. You have the right to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. You may request such personal information up to twice annually, subject to certain exceptions.

Right to Delete. You have the right to delete personal information that you have provided by or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in the State Privacy Laws. Additionally, if you request deletion of your personal information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal information for any purpose except for those allowed under the State Privacy Laws.

Right to Opt-Out. You have the right to opt out of the processing of your personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

If you wish to opt out of the processing of your personal information for any of the above purposes, please email [email protected].

Right to Correct. You have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process it.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, 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.

How to Exercise Your Rights; Verifying Your Identity. To exercise any of your privacy rights, or if you have any questions about your privacy rights, you may contact us by emailing us at [email protected].

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that your request is not fraudulent. We may contact you for additional information as reasonably necessary to authenticate your request, but if we are ultimately unable to authenticate your request using reasonably commercial efforts, then we may not be able to comply with it.

Only you may make a verifiable request related to your personal information. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.
Response Time; Your Right to Appeal. We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. You will have the right to appeal within a reasonable period of time after you have received our decision. Within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.

If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information that we have collected (or may collect) from you to data brokers or other third parties. You can exercise this right by emailing us at [email protected] with the subject line “Nevada Do Not Sell Request.”

Last Updated: May 2024