This PRIVACY NOTICE IS FOR CALIFORNIA RESIDENTS intended to apply solely to
visitors, users, and persons who are residents in the State of California
(“consumers” or “you”).
This notice is an addendum for information contained in the existing
of the Company and its affiliates (collectively, “we,” “us,” or “our”).
We adopt this notice to comply with the California Consumer Privacy Act of
2018 (“CCPA”) and other California privacy laws. Any terms defined in the
CCPA have the same meaning when used in this notice.
Information We Collect –
We collect information that identifies, relates to, describes, references,
is capable of being associated with, or could reasonably be linked, directly
or indirectly, with a particular consumer or device (“personal
We have collected the following Statutory Defined Categories of personal
information from consumers within the last twelve (12) months:
Category: “Identifiers” – which may include: A real name,
alias, postal address, unique personal identifier, online identifier,
Internet Protocol address, email address, or other similar identifiers.
Category: “Customer Records” -which may include: A name,
signature, address, telephone number, education level, employment, driver
license status and medical information Some personal information included in
this category may overlap with other categories.
Category: “Protected Classification Characteristics”– which
may include: Age, marital status, gender, and Veteran or military status.
Category: “Internet or Other Similar Network Activity”–
which may include: Browsing history, search history, information on a
consumer’s interaction with a website, application, or advertisement.
Category: “Geolocation Data” – which may include location
Category: “Professional or Employment-Related Information”–
which may include employment status, ie. Employed, Self-Employed or Retired
The above categories of personal information are obtained from the following
categories of sources:
- Directly from you. For example, from your interaction on this platform and
the information you provide on any forms this platform which you submit.
In some instances we may also automatically collect certain information
from you through the technology on the platform.
- Information you provide in connection with a product/service offered by
our affiliates, partners or vendors.
- Information you provide the platform for communication permissions and
- Indirectly from our clients or their agents. For example, through
information we collect from our clients in the course of providing
marketing or technology services to them.
- Directly or indirectly from our clients or their agents. For example,
through information we collect from our clients in the course of providing
services to them.
- From third-parties that interact with us in connection with the platform
function or services we perform. For example, verification services used
for state and federal permission and consent records.
- Information you provide us through telephone and websites, customer
service correspondence, and general feedback.
- In addition, we may receive information about you from other online or
offline sources, including service providers from whom we validate
consumer selfreported information, and verify information we already have
Use of Personal Information
We may use or disclose the personal information we collect for one or more
of the following business purposes:
- To process an inquiry or request you provide. For example, if you provide
us with your information to share with businesses who will contact you
regarding a product or service you expressed interest in.
- To provide you with personalized email, SMS or tele communications
concerning products or services, information or news, that you may be of
interest to you through targeted offers and ads (with proper consents,
where required by law).
- To carry out our obligations and enforce our rights arising from any
contracts entered into between us and any affiliates, client network,
- To improve our platform and the services offered.
- For testing, research, analysis and technological/product development.
- To help maintain and protect the rights, safety, security, and integrity
of our platforms, products and services, databases and other technology
- To respond to any law enforcement requests and as required by applicable
law, court order, or governmental regulations.
- 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 is among the assets transferred.
- As described to you when collecting your personal information or as
otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the
personal information we collected for any other purpose than described
herein without first providing you notice.
Sharing Personal Information
We may share your personal information with a third party for business
purposes. When we disclose personal information for a business purpose, we
enter a contract that describes the purpose and requires the recipient to
both keep that personal information confidential and not use it for any
purpose except performing the services outlined in the contract.
In the preceding twelve (12) months, we have disclosed the following
categories of personal information (as identified above) for a business
- Category: Identifiers
- Category: Customer Records
- Category: Protected classification characteristics
- Category: Internet or other similar network activity
- Category: Professional or employmentrelated information
We share the above following categories of personal information for a
business purpose to the following third parties:
- Our affiliates.
- Service providers.
- Data aggregators.
- Third parties to whom you or your agents authorize us to disclose your
personal information in connection with the products or services you have
expressed interest in.
Your Rights and Choices
Right to Opt-Out of the Sale of Personal Information-
You have the right to opt-out of any sale of your Personal Information by
us. If you are requesting a product or service, this is an exemption from
this right, and we will process your request. However, you have the right to
cease all further sale of your Personal Information.
Per California CCPA Section 1798.140(t): A business does not sell personal
information when: A consumer uses or directs the business to intentionally
disclose personal information or uses the business to intentionally interact
with a third party, provided the third party does not also sell the personal
information, unless that disclosure would be consistent with the provisions
of this title.
In the preceding twelve (12) months, we have shared your information with
providers of the services or products you have requested. We have also
shared your information with third parties as described above.
To Opt-Out of the sale of Personal Information, please see Section: Exercise
Your Rights below.
Right to Know About Personal Information-
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 12
months. Personal Information does not include: (i) Publicly available
information from government records; (ii) De-identified or aggregated
consumer information; (iii) Information excluded from the CCPAs scope, like
health or medical information covered by the Health Insurance Portability
and Accountability Act of 1996 (HIPAA); (iv) Personal Information covered by
certain sector-specific privacy laws, including the Fair Credit Reporting
Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial
Information Privacy Act (FIPA), or the Drivers Privacy Protection Act of
You may submit a verifiable consumer request to obtain the specific Personal
Information we have collected about you at the link or email address
provided in Section: Exercising Your Rights, below.
Once we receive and confirm your verifiable consumer request, we will
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about
- Our business or commercial purpose for collecting that personal
- The categories of third parties with whom we share that personal
- The specific pieces of personal information we collected about you (also
called a data portability request).
- If we disclosed your personal information for a business purpose, two
separate lists disclosing the following will be provided:
- Information you provided that was shared with third parties for the
purposes set forth above and resulted in payment to us which will
identify the personal information categories that the third party
- Disclosures for a business purpose, identifying the personal
information categories that each category of recipient obtained.
- Information you provided that was shared with third parties for the
Right to Delete Personal Information
You have the right to request that we correct and/or delete any of your
personal information you provided to this platform and retained, subject to
certain exceptions. Upon receipt and confirmation of your verifiable
consumer request, we will delete (and direct our service providers to
delete) your personal information from our records, unless an exception
We may retain your information despite your deletion request if retaining
the information is necessary for us or our vendors/ service providers to
perform any of the following:
- Process your request for which you provided your personal information
- Detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible for such
- Debug products to identify and repair errors that impair existing intended
functionality of this platform/service.
- Internal uses that are reasonably aligned with consumer expectations based
on your engagement with the platform/services..
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are
compatible with the context in which you provided it.
Exercise Your Rights-
Only you or a person registered with the California Secretary of State that
you authorize to act on your behalf, may make a verifiable consumer request
related to your personal information or on behalf of your minor child.
You may only make a verifiable consumer request for access or data
portability twice within a 12-month period. The verifiable consumer request
- Provide sufficient information that allows us to reasonably verify you are
the person (or authorized agent) who provided personal information on the
- Describe your request with satisfactory detail that allows us to
accurately understand, evaluate, and provide a response.
The above details are important. We will be unable to process/respond to
your request or provide you with personal information if we cannot
conclusively verify your identity or any authority to make the request
and/or confirm the personal information relates to you.
We will only use the personal information provided in a verifiable consumer
request to actually verify the requestor’s identity or authority in order to
process such request.
Response Timing and Format-
We will respond to a verifiable consumer request within 45 days of its
receipt as required. If more time is required (up to 90 days), we will
inform you of the reason and extension period in writing. We will deliver a
written response by mail or electronically, at your request. The information
provided will cover a 12-month period preceding the verifiable consumer
request’s receipt. The response we provide may also explain the reasons we
cannot process a request, if applicable. For requests made, we will select a
format to provide your personal information that is readily useable.
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
We will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
- Deny these services.
- Charge you different prices or rates for goods or services, including
through granting discounts or other benefits, or imposing penalties.
- Suggest that you may receive a different price or rate for goods or
services or a different level or quality of services. Please note: We do
not charge consumers for use of these services.
- Provide you a different level or quality of services.
Changes to Our Privacy Notice-
We reserve the right to amend this privacy notice at our discretion and at
any time. When we make changes to this privacy notice, we will notify you by
email or through a notice on this platform.
If you have any questions or comments regarding this notice, please contact
us at: or write to us with your specific instructions
at: – Attention: Consumer Services,
18766 John J Williams Hwy #242, Rehoboth Beach, DE 19971