Depending on your U.S. state of residence, you have may have additional privacy rights with respect to your personal information. These rights may be accorded to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act; the Iowa Data Protection Act; the Nebraska Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Tennessee Information Protection Act (effective July 1, 2025); the Minnesota Consumer Data Privacy Act (effective July 31, 2025); the Maryland Online Data Privacy Act (effective October 1, 2025); the Indiana Consumer Data Protection Act (effective January 1, 2026); the Kentucky Consumer Data Protection Act (effective January 1, 2026); and the Rhode Island Data Transparency and Privacy Protection Act (effective January 1, 2026) (collectively, as may be amended from time to time, “State Data Privacy Laws”). If you reside in one of these States (each a “Covered State”), you are a “Covered Resident”.
This section contains disclosures required by State Data Privacy Laws, is only relevant to Covered Residents and applies only to the collection or other use of “personal information” that is subject to State Data Privacy Laws.
Information We Collect. In the past 12 months, we may have collected the following categories of personal information about Covered State consumers:
- Identifiers
- This includes information containing a real name, alias, e-mail address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers.
- Other personal information categories, as listed in the applicable Covered State’s statute
- This includes a signature, physical characteristics or description, telephone number, education, employment, or employment history.
- Protected classification characteristics under the laws of the Covered States or federal law
- This includes information pertaining to age (40 years or older), race, citizenship, marital status, sex, veteran, or military status.
- Commercial information
- This includes account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information
- Examples of biometric information include fingerprints, faceprints, voiceprints, and iris or retina scans.
- Internet or other similar network activity
- Examples of this information include browsing history, search history, information on a consumer’s interaction with a website (cookies), application, or advertisement.
- Professional or employment-related information
- Examples of this information include current or past job history or performance evaluations.
- Non-public education information
- Such information includes education records directly related to a student maintained by an educational institution or party acting on its behalf.
We do not knowingly collect or solicit personal information from anyone under the age of 18.
Categories of Sources. We collect personal information from the following categories of sources:
- Directly from you, such as through your communications and correspondence, as well as customers’ transactions with us and others;
- Indirectly from you and from other sources or service providers, including, but not limited to: administrators, banks, auditors, law firms, employment agencies; and
- Government entities.
Use of Personal Information. We may use and disclose the personal information we collect for one or more of the following business and commercial purposes:
- Providing you with information about our products and services;
- Providing performance and other updates;
- One or more of the following business purposes:
- Providing products and performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
- Vendor and employment management and to accomplish our business purposes and objectives;
- Legal compliance; and
- Internal operations.
For example, we use personal information to fulfill your transactions; respond to your communications; conduct risk and security control and monitoring; detect and prevent fraud; perform accounting, audit and other internal functions; comply with law, legal process and internal policies; maintain records; facilitate corporate transactions; and exercise rights and defend legal claims.
Disclosing Personal Information. We may provide personal information to:
- Service providers, including but not limited to: administrators, banks, auditors, law firms, employment agencies;
- Business partners and affiliates; and
- Legal or government regulatory authorities as required by applicable law.
In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.
Rights of Covered Residents. State Data Privacy Laws provide a Covered State consumer the following rights, subject to certain exceptions and limitations:
- The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information. These access and data portability rights do not apply to (i) personal information collected about employees, job applicants, contractors or similar individuals and used only within the context of such a relationship (“employment-related personal information”) or (ii) personal information reflecting a written or verbal business-to-business communication (“B2B personal information”);
- For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
- The right to request that we delete the personal information (other than employment-related personal information or B2B personal information) we have collected from you or maintain about you;
- The right to opt out of our sale(s) (if any) of your personal information; and
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by State Data Privacy Laws.
Exercising Your Rights. To exercise your State Data Privacy Laws rights described above, please submit a verifiable consumer request to us at the phone number or email address provided below. We will respond to your request within forty-five (45) days of our receipt of such request. 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. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. Please describe your request with sufficient detail for us to properly understand, evaluate, and respond to it. You may appeal our denial of any request within forty-five (45) days of your receipt of our written denial therefor. To exercise your right to appeal, you must contact us at the phone number or email address provided below.
Requests from Authorized Agents. If you would like an authorized agent to submit a request under State Data Privacy Laws on your behalf or if you are an authorized agent of a consumer and registered with the Secretary of State to conduct business in one or more Covered States, please send us an e-mail at email address for instructions and details on proof required for use of an authorized agent, including a copy of the written permission signed by the consumer for the agent to act on the consumer’s behalf in this manner.
Right of Non-Discrimination. You have the right not to receive discriminatory treatment by us for exercising any of your rights under State Data Privacy Laws.
Reasonable Access for Consumers with Disabilities. Persons with disabilities may contact us about obtaining this Privacy Notice in alternative format by contacting us via phone or e-mail, as described below.
You may submit requests relating to your exercise of rights under State Data Privacy Laws to us: via e-email address.
CONSENT TO PROCESSING IN THE UNITED STATES
Our Services are operated in the United States. By providing any information to Company, all users, including, without limitation, users in the member states of the European Union, Canada, the United Kingdom or elsewhere outside of the United States, fully understand and consent to this Privacy Policy. That means by using our Website, App and/or participating in any of our Services and/or providing us with your information, you consent to the collection, transfer, storage, use and processing of your personal information to and in the United States in accordance with this Privacy Policy. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from United States law, please note that you are transferring your personal information to the United States. The laws of some countries may not provide the same levels of protection of personal information as your home country, particularly if you are resident in the European Union. We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Policy, and that all information you provide to us is stored on our secure servers or those of our service providers.
YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR INFORMATION WITH US, OR MAKE USE OF THIS WEBSITE.
TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.
Notice to Residence of the European Union, European Economic Area and United Kingdom
European Economic Area and United Kingdom data protection law requires a “lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Area and the United Kingdom, respectively. Our lawful bases for collecting such information about you are permitted under Article 6, Section 1 of the EU general data protection regulation 2016/679 (as amended from time to time, and as adopted by the United Kingdom, the “GDPR”) and are summarized below.
- Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your Personal Information when you contact us through the Service or enter into a contract with us.
- Contract: We may need your Personal Information to comply with our contractual obligation to you to deliver the Service, such as fulfilling any future transactional services.
- Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Service or through our contract with you.
- Legitimate Interests: This is a technical term that means we have a good and fair reason to use your Personal Information and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that do not materially impact your rights, freedom, or interests.
For example, we (i) use identity, device, and location information to prevent abuse of the Service by users and to keep the Service secure, and (ii) analyze how users interact with our Service so we can understand better what elements do or do not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Service, and to ensure the safety and security of the Service, which allows us to improve and develop the quality of the online experience we offer all our users.
In accordance with the GDPR, as a resident of the European Union, European Economic Area, or the United Kingdom, you may have the following rights with respect to your Personal Information:
- If the processing of Personal Information is based on your consent, the right to withdraw consent at any time for the processing of such Personal Information. This will not affect the lawfulness of any processing carried out before the consent was withdrawn;
- The right to request access to and rectification of your Personal Information;
- The right to object to or request restriction of the processing of your Personal Information;
- The right to request erasure of your Personal Information; and
- The right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us based on your consent or a contract and that is processed by automated means, and to have such Personal Information transmitted to another company where technically feasible (i.e., data portability).
To make a request pursuant to your GDPR rights, you can contact us by email at [email address].
If you are not satisfied with our response to any appliable request made pursuant to your rights under the GDPR, you have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority. If you are located in the United Kingdom, this is the Information Commissioner’s Office (ICO). If you are located in the European Economic Area, you can contact the Commission Nationale Informatique & Libertés (CNIL).