Privacy Policy

9.1. Subject to applicable Data Privacy Law, you may have certain rights to know, access, update, port your personal data, correct inaccuracies, delete, and / or restrict processing of your personal information in our custody and control.

9.2. For security purposes, we will verify your identity when you request to exercise your data privacy rights. For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity, we will respond to your request as appropriate. You right over your personal information depends on the Data Privacy Law applicable where you reside.

9.3.  California Privacy Rights

9.3.1.  California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Services. This notice supplements the information in the Privacy Notice. Certain terms used below The have the meanings given to them in the CCPA and CPRA.  The CCPA and CPRA shall be collectively referred to herein as the “CPRA”.

9.3.2. Additional Disclosure: Do-Not- Track Disclosure

• “Do Not Track”(“DNT”) is the concept that has been promoted by regulatory authorities for the internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. Currently, various web browsers (Chrome, Firefox, Safari, Internet Explorer, Microsoft Edge) offer a DNT option that sends a signal to websites visited by the browser user about the user’s DNT preference. We do not recognize or respond to browser initiated Do Not Track (DNT) signals as a DNT standard has not been adopted to this day. Our third-party partners, such as web analytics companies and third-party ad networks, may collect information about you and your online activities over time and across our Services and our Site. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.

9.3.3.  Your Rights

• As a California Consumer, you have the following rights, these rights are not absolute and may be subject to exceptions and verification.  We may be required or permitted by law to decline any request.  Only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to accessing or deleting your personal information.
• Right to Delete
  • You can make a request to delete any personal and sensitive personal information we collected from you. Upon receiving a verified request, we will notify you once your information has been deleted. We will also communicate your deletion request to the third parties who process your personal information on our behalf and direct them to delete your information.
• Right to Ops-Out of Sale
  • California Consumers have the right to opt out of “sales” of their personal information. The CCPA’s broad definition of “sale” may include using services to deliver targeted advertising on other sites or applications. This means that if you make a request to opt out of our “sales” of personal information, it will likely have a direct impact on the types of advertisements you see online. We will honor requests to opt out of “sales” of your personal information. If you would like to opt out, you may do so as outlined on the following page: Do Not Sell or Share my Personal Information.
• Right to Limit the Use or Disclosure of Sensitive Personal Information.
  • You have the right to limit the use of your sensitive personal information to only those purposes that are necessary for us to provide Services to you.  If you would like to opt out, you may do so as outlined on the following page: limit the use of your sensitive personal information. We will notify you if at any point we intend to use your sensitive personal information for any additional purposes.
• Right to Non-Discrimination
  • We value giving consumers control over their privacy and personal information.  If you choose to exercise any of your rights under the CCPA, we will not differentiate our services as a result of your decision.  We also do not offer any financial incentives to opt-in to sell your personal information.
• Right to Correct
  • You have the right to request the correction, updating and completion of any Personal and Sensitive Personal Information we maintain about you.

9.4.  Colorado, Connecticut, Florida, Montana, Oregon, Texas, Utah, Virgina

9.4.1.  Your Data Subject Rights

• • The Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, Utah Consumer Privacy Act and similar laws in other U.S. states ("Data Privacy Laws") provide their consumers with specific rights regarding their personal information. To the extent that you are a resident of one of these states, this section describes your rights under the Data Privacy Laws and explains how you may exercise these rights.
  • The categories of personal information we process, our purposes for processing, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are detailed in Section 4. To the extent that our personal information processing activities are addressed by a separate privacy notice, please consult the terms of that privacy notice for detailed information about our data practices, including the categories of personal information that we collect and disclose.

9.4.2.  Right to Know

• • You have the right to know whether we process your personal information.

9.4.3.  Right to Access

• • You can make a request to access the categories or specific pieces of personal and sensitive personal information we collected, used, or shared about you.  Along with your verified request, we will give you any categories of sources from which the personal or sensitive personal information is collected; the purpose for collecting, selling, or sharing; and any categories of third parties with whom we share such personal information.

9.4.4. Right to Data Portability

• • You have the right to access and 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.

9.4.5.  Right to Delete

• • You have the right to delete personal information that you have provided or that we have obtained about you. Please note that we may deny such a request if the requested deletion falls under an exception to this right set forth in Data Privacy Laws. If the personal data is no longer needed for any purposes that justify its retention and we are no required by law to retain it, we will do what we can to delete. We may need certain types of data so that we can provide our Services to you.  If you ask us to delete it, you may no longer be able to access or use our Services.

9.4.6.  Right to Opt-Out of Selling or Sharing

• • You have the right to opt out of the processing of the 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 (provision or denial of housing, insurance, employment opportunities, or access to essential goods or services; decisions that have a foreseeable risk of unfair or unlawful treatment, financial or physical injury or other substantial injury). As of the latest date of the Privacy Notice:
    • We DO NOT process personal information for the purposes of targeted advertising;
    • We DO NOT sell your personal information in exchange for monetary or other valuable consideration;
    • We DO NOT engage in profiling decision based on your personal information that produce legal or similarly significant effects concerning you.

9.4.7.  Right to Correct

• • You have the right to correct inaccuracies in the personal information we collect from you, taking into account the nature of the personal information and the purposes for which we process it.

9.4.8.  Right to Nondiscrimination

• • We value giving consumers control over their privacy and personal information.  If you choose to exercise any of your data privacy rights, we will not differentiate our services as a result of your decision.  We also do not offer any financial incentives to opt-in to sell your personal information.

9.4.9.  Your Right to Appeal

• • For Colorado, Connecticut, Florida, Montana, Oregon, Texas and Virginia residents, if we decline to take action or do not respond regarding a request that you have submitted pursuant to one of the privacy rights set forth in this section, you have the right to appeal our refusal to take action within a thirty (30) calendar days after you receive our decision. 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 the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general’s office to submit a complaint.

9.5.  GDPR Privacy Rights

• If you are a resident of one of many European countries, including the United Kingdom and Switzerland, an important European privacy law (or an equivalent counterpart to it) the General Data Privacy Regulation (the “GDPR”) provides you with certain rights, and places certain obligations on companies regarding how your “personal data” (as the GDPR uses that term) is used.  We describe those rights and obligations below, and how and in what circumstances we honor them. We set out our compliance with the GDPR and, to the extent applicable, those other laws, in this section.

9.6.  Legal Basis

9.6.1. The GDPR requires us to tell you about the legal ground we’re relying on to process any personal data about you. The legal grounds for us processing your personal data for the purposes set out in Section above will typically be because:

• • You provided your (legally sufficient) consent;
  • It is necessary for our contractual relationship, e.g., in order to provide you services or features you’ve requested and we’ve promised;
  • The processing is necessary for us to comply with our legal or regulatory obligations – for instance, to communicate with you about or to help honor your legal rights; and/or
  • The processing is in our legitimate interest.   For instance, we may process and share business data collected from our website for our own internal marketing purposes, or other information for purposes of security, data hygiene or validation, in a manner that constitutes a “legitimate interest”.

9.7.  Your Data Subject Rights

9.7.1. Right to Rectify, Delete, Restrict or Object to the Processing

• • Your rights to deletion or revocation of consent (sometimes referred to as a right to be forgotten, to restrict processing, or to otherwise object to processing).  You have the right to request that we delete your personal data (or where applicable, withdraw your prior consent to our processing of your data). You may also request that we correct or rectify your personal data if it is inaccurate, incomplete or false.
  • If you request that we delete your personal data, or withdraw your consent, we will customarily retain a copy of your data sufficient to suppress it from our active databases in the future:  but if that is not what you wish, you may indicate that to us (in which case your information may be added to our database later, because we will not have “suppressed” it).
  • Moreover, when we delete your personal data, we may retain it (to the extent legally permissible) for certain important (but narrow) internal purposes such as legal, compliance, accounting or auditing purposes, and in some cases, for security purposes.

9.7.2.  Personalized Online Advertising Opt-Out

• • You may object to profiling by online advertising platforms with whom we sometimes partner to help generate (and measure or analyze) “personalized” online advertising.  These platforms are generally separate third party “controllers” of your data.

9.7.3. Your Right to Access

• • In some jurisdictions, you may have the right to request access to a copy of your personal data.  When you request access to your personal data, we are required — for privacy and other important compliance reasons — to verify your identity in a legally sufficient manner: if we cannot do so, we will not be able to satisfy your access request.

• • Please note that as part of the verification process, we may not be able to sufficiently “verify” your identity in a manner sufficient to safeguard against the potential adverse privacy effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another). Because such improper disclosure would likely adversely affect the privacy rights and freedoms of a relevant data subject/consumer, we limit certain personal data we make available.

9.7.4. Questions or Concerns

• • If you have a complaint or concern or question about how we handle your personal data, please contact us as at the above contact addresses, and we will seek to address any concerns you may have. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant Data Protection Authority.

9.8.  Exercising Your Rights

• This provides for instructions on how you can exercise your rights under the applicable Data Privacy Law.

9.9. How to Exercise Your Rights

• To submit a request to access, rectify, delete, port your personal data you can submit a request to us either:
  • By email at  or by calling us at 855-836-4759
  • Note in the body of the email the specific right you want to exercise. In the subject line, include “<Your State/Country> Consumer Request”.
  • To protect the privacy and security of your personal information, we will attempt to verify your identity before acting on your request. Your request must include details sufficient for us to properly understand, evaluate, and respond to the request.
• Please also note that as part of the verification process, we’re required to consider:
  • the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with and:
  • the potential adverse effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another) because such improper disclosure would likely adversely affect the privacy rights and freedoms of the relevant data subject/consumer, we limit certain personal data we make available.