Privacy Policy

I. PERSONAL DATA COLLECTION

a. Some Personal Data is collected from Users through the Services.

b. Types of Personal Data Collected.
• Among the types of Personal Data collected through the Services, by TCR itself or through third parties, are: Cookies; Usage Data; email address; first name; last name; phone number; and IP address.
• Details of each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or through explanatory messages displayed prior to the data collection.
• Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the Services.
• Unless specified otherwise, all Personal Data requested by the Services is required for a User to use the Services and failure to provide this data may make it impossible for TCR to provide the Services. In cases where the Services indicate that some Personal Data is not required, Users are free not to communicate this data without impact to the availability or the functionality of the Services.
• Users who are uncertain about which Personal Data is required for the Services are welcome to contact TCR.

c. Users are responsible for any third-party Personal Data obtained, published or shared by such Users through the Services and confirm that they have the third party’s consent to provide such data to TCR.

d. In addition to the information contained in this Privacy Policy, TCR may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

II.  USE OF PERSONAL DATA AND PURPOSE OF PROCESSING

a.  TCR processes Personal Data, including sharing it with third parties, where processing is necessary for the purposes of our legitimate commercial interests and performance of the Services as further described in this Section. TCR does not sell Personal Data that we collect.

b. Our legitimate interest in the effective delivery of information and services to you, and the effective and lawful operation of our business includes:

·       Providing the Services to Users

·       Developing and improving our site, and your user experience

·       Performing analytics on the Services

·       Contacting the User

·       Displaying content from external platforms

·       Managing contacts and sending messages

·       Performing platform services and hosting

·       Managing registration and authentication

·       Performing tag management

·       Managing system logs and maintenance

·       Performing internal operations, such as improving the effectiveness of our Services

·       Conducting audits

·       Providing information to our representatives and advisors, such as our attorneys, accountants, and others to help us comply with legal, accounting, or security requirements

·       Transferring information as part of a merger or sale of the business

·       Resolving disputes between Users, customers and TCR

·       Protecting the rights, safety, and information of TCR, our customers and their members, and third parties

·       Complying with our legal obligations, responding to enforcement requests, protecting TCR’s rights and interests (or those of its Users or third parties) and detecting any malicious or fraudulent activity

c. A User’s Personal Data may be used for legal purposes by TCR in court or in the stages leading to possible legal action arising from improper use of the Services. The User acknowledges and agrees that TCR may be required to reveal Personal Data upon request of public authorities.

d. TCR may aggregate, combine, anonymize and/or pseudonymize any data that we collect and process, including Personal Data. This may be done for the purpose of performing the Services, correcting data currently held by TCR, expanding data sets and research.

III. WHO CAN ACCESS PERSONAL DATA COLLECTED

a.   TCR will only disclose Personal Data as set forth in this Privacy Policy, as permitted by law, or with the User’s consent. Where third parties are processing Personal Data on our behalf, they will be required to agree, by contractual means or otherwise, to process the Personal Data in accordance with applicable law and to act only on TCR’s instructions.

b.   In addition to being accessible by TCR, in some cases, Personal Data may be accessible to certain types of persons involved with the operation of the Services (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by TCR.

c.   TCR may disclose Personal Data to the following entities and for the listed purposes:
• Customers and Other Authorized Business Partners. For the purpose of providing the Services, TCR will share Personal Data with a User’s designated organization (i.e., TCR’s customer).
• Employees. Only authorized employees have access to Personal Data.
• Contractors and Service Providers. TCR employs other companies and individuals to perform functions on our behalf. Examples of such functions include fulfillment activities, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing technical support and providing customer service. TCR may share Personal Data with these contractors and service providers as TCR deems necessary for such third parties to perform their functions related to the Services.
• To Comply with Legal Process, Protect Company, or Enforce our Rights. TCR may further disclose Personal Data when it is necessary to: (i) conform to legal requirements or comply with legal processes; (ii) enforce or apply our conditions of use and other agreements; (iii) protect the rights, safety or property of TCR, our affiliates, our customers, service providers, Users or the public, or (iv) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).
• As Part of a Merger or Sale of Business. TCR may disclose or transfer Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

IV.  MODE AND PLACE OF PROCESSING DATA

a.   TCR takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of Personal Data. TCR utilizes industry-accepted reasonable security practices and has implemented reasonable technical and organizational measures to protect the confidentiality, security and integrity of User’s Personal Data. The measures that TCR has implemented take into account the current available security technologies, cost, and risk presented by the type of Personal Data TCR processes. Although TCR uses reasonable security measures to help protect Personal Data against unauthorized disclosure or loss, TCR cannot guarantee the security of Personal Data transmitted to TCR over the Internet. While TCR strives to use commercially acceptable means to protect Personal Data, there is no guarantee that information may not be accessed, disclosed, altered or destroyed.

b.    The processing of Personal Data is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated herein or through the Services.

c.    TCR may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes. Note: Under some legislation, TCR may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any of the other legal bases specified herein. This, however, does not apply whenever the processing of Personal Data is subject to European data protection law;
• provision of data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which TCR is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in TCR; or
• processing is necessary for the purposes of the legitimate interests pursued by TCR or by a third party.

d.    In any case, TCR will gladly help to clarify the specific legal basis that applies to the processing of a User’s Personal Data, and in particular whether the processing of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

e.    The Personal Data is processed at TCR’s operating offices and in any other places where the parties involved in the processing are located.

f.     Depending on the User’s location, data transfers may involve transferring the User’s Personal Data to a country other than their own.

g.    Users are entitled to learn about the legal basis of Personal Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by TCR to safeguard their Personal Data.

V.    RETENTION OF PERSONAL DATA

a.   Personal Data shall be processed and stored for as long as required by the purpose(s) it has been collected for.
• Personal Data collected for purposes related to the performance of a contract between TCR and the User (or User’s employer) shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of TCR’s legitimate business interests shall be retained as long as needed to fulfill such purposes.
• TCR may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn.
• TCR may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

b. Once the applicable retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to correct and the right to data portability cannot be enforced after expiration of the applicable retention period.

VI.  RIGHTS OF USERS

a.   Users may exercise certain rights regarding their Personal Data processed by TCR.

b.   In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Personal Data. Users have the right to object to the processing of their Personal Data if the processing is carried out on a legal basis other than consent.
• Access their Personal Data. Users have the right to learn if their Personal Data is being processed by TCR, obtain disclosures regarding certain aspects of such processing and obtain a copy of the Personal Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.
• Restrict the processing of their Personal Data. Users have the right, under certain circumstances, to restrict the processing of their Personal Data. Where Users have and exercise such right, TCR will not process a User’s Personal Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Personal Data from TCR.
• Receive their Personal Data and have it transferred to another controller. Users have the right to receive their Personal Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Personal Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

c.   Where Personal Data is processed for a public interest, in the exercise of an official authority vested in TCR or for the purposes of the legitimate interests pursued by TCR, Users may object to such processing by providing grounds related to their particular situation to justify the objection.

d.   Should a User’s Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. TCR does not process Personal Data collected for direct marketing purposes.

e.   Any requests to exercise User rights can be directed to TCR through the contact details provided in this Privacy Policy.

VII. COOKIE POLICY

When a User first accesses the Services from certain jurisdictions, the User will receive a message advising the User that cookies are in use. By clicking “accept”, the User agrees to TCR’s use of cookies as described in this Privacy Policy. If the User does not wish to receive cookies, the User may withdraw their consent or set their browser to reject cookies or to alert the User when a cookie is placed on their device. If the User withdraws consent, limits or disables the use of cookies when the User visits or uses the Services, the User may not be unable to use the full functionality of the Services. For more information about our specific use of cookies, please reference our “Cookie Policy,” which is attached as Schedule 1 (Cookie Policy) and incorporated herein by reference. TCR may also permit select third parties to use cookies to collect information about Users’ online activities across other websites or over time in order to assist us with Services analytics.

VIII.       HOW “DO NOT TRACK” REQUESTS ARE HANDLED

The Services do not support “Do Not Track” requests. To determine whether any third-party services used by or linked to the Services honor “Do Not Track” requests, please read the privacy policies for those services.

IX.   THIRD PARTY SERVICES

The Services may contain links to third party websites, applications and services not operated by TCR. These links are provided as a service and do not imply any endorsement by TCR of the activities or content of these websites, applications or services nor any association with their operators. TCR is not responsible for the privacy policies or practices of any third party including websites or services directly linked to or from our Services.

X.    INFORMATION FOR CALIFORNIAN CONSUMERS

The California Consumer Privacy Act of 2018 (“CCPA”) provides several rights to California residents with regards to the collection, disclosure, sale, and deletion of their Personal Data. The Campaign Registry California Privacy Notice set forth in Schedule 2 (California Privacy Notice) describes in more detail TCR’s compliance with CCPA and how residents of California may exercise their CCPA Rights. If a User has questions about exercising their CCPA Rights, please contact us as set out below.

XI.  INFORMATION FOR OTHER U.S. CONSUMERS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. The Services are available in all fifty states.

Schedule 3 describes in detail TCR’s compliance with Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia privacy law.  If a User has questions about exercising their specific state rights, please contact us as set out below.

XII.         USERS BASED IN THE EUROPEAN UNION OR THE UNITED KINGDOM

For purposes of the EU’s General Data Protection Regulation (“GDPR”), and the UK GDPR, TCR is a data processor, with an office at 1775 Tysons Blvd 5th Floor, McLean, Virginia 22102, USA.

TCR is headquartered in the United States. By using any of the Services from outside the United States, Users acknowledge that their Personal Data will be accessed by TCR or transferred to TCR in the United States and to those entities listed in Section III of this Privacy Policy who are located around the world; and that User Personal Data will be transferred to, and stored and processed in, the United States or elsewhere in the world where TCR servers are located.

XIII.      RECOURSE, ENFORCEMENT, AND LIABILITY

In compliance with the EU-U.S. DPF Principles, including the UK Extension of the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, TCR commits to resolve complaints about your privacy and TCR’s collection or use of Personal Data transferred to the United States pursuant to this Policy.

European Union, Swiss, and United Kingdom individuals with DPF inquiries or complaints should first contact TCR’s Data Protection & Privacy Department by emailing privacy@campaignregistry.com or by calling +1- 839-900-1504.

TCR has further committed to refer unresolved privacy complaints under the DPF Principles to an independent recourse mechanism, American Arbitration Association, operated by ICDR-AAA If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit URL for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not otherwise resolved by other redress mechanisms. For more information about binding arbitration, visit http://www.dataprivacyframework.gov/framework-article/G%E2%80%93Arbitration-Procedures.  The Federal Trade Commission has jurisdiction over TCR’s compliance with the DPF.

XIV.       MINORS AND CHILDRENS’ PRIVACY

TCR does not knowingly collect Personal Data from children under the age of 18. If TCR learns that Personal Data of persons younger than 18 years-of-age has been collected through the Services, TCR will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted or otherwise communicated Personal Data to TCR without your consent, then you may alert us at privacy@campaignregistry.com so that we may take appropriate action to remove the minor’s Personal Data from our systems.

XV.  DEFINITIONS

a.   “Data Processor”: The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller, as described in this privacy policy.

b. “Data Subject”: The natural person to whom the Personal Data refers.

c. “European Union” or “EU”: Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

d. “Usage Data”: Information collected automatically through the Services (or third-party services utilized for the Services), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Services) and the details about the path followed within the Services with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

e. “User”: The individual using the Services who, unless otherwise specified, coincides with the Data Subject.

XVI.       MISCELLANEOUS

a.   This privacy statement has been prepared based on provisions of multiple legislation, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

b.   More details concerning the collection or processing of Personal Data may be requested from TCR at any time. Please see our contact information for inquiries.

c.   Changes to this Privacy Policy
• TCR reserves the right to make changes to this Privacy Policy at any time by notifying its Users through the Services and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to TCR. Users are strongly recommended to check the Services often, referring to the date at the top of this Privacy Policy for the last modification date.
• Should changes to this Privacy Policy affect processing activities performed on the basis of the User’s consent, TCR shall collect new consent from the User, where required.

d.   Contact Information for TCR/Data Controller

The Campaign Registry Inc., 1775 Tysons Blvd 5th Floor, McLean, Virginia 22102

TCR contact email: privacy@campaignregistry.com

SCHEDULE 1

COOKIE POLICY OF www.campaignregistry.com

Effective Date: January 8, 2021, Last updated February 18, 2025

This Cookie Policy applies to The Campaign Registry, Inc. (“TCR”, “we”, “our” or “us”).  Like most businesses, we employ “cookies” or similar technologies. This Cookie Policy tells you about the use of cookies and similar technologies on our websites, online portals and applications which link to this Cookie Policy (collectively, the “Services”).

a.   When you first access our Services from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By clicking “accept”, you signify that you understand and agree to the use of these technologies, as described in this Cookie Policy.

b.   You do not have to accept cookies and consent can be withdrawn at any time (see “How to Control Cookies”, below). You can change your browser settings to refuse or restrict cookies, and you may delete them after they have been placed on your device at any time. If you do not accept or delete our cookies, some parts of the Services that you access may take more time to work, or may not function properly.

What Are Cookies?

Cookies are small files containing a string of characters which we may store on your computer or mobile device when you visit or use one of our Services.  When you visit or use the Services again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.

Cookies set by a website owner (in this case, TCR) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the Services (i.e., advertising, social media functions and analytics).

Cookies which expire and are automatically erased when you close your browser window are called “session cookies”. We use session cookies to grant our users access to content and to enable actions such as remembering applications. Cookies which have an expiration date in the distant future and remain in your browser until they expire, or you manually delete them are called “persistent cookies”. We may use persistent cookies to better understand usage patterns so we can improve the Services for our users. For example, we may use a persistent cookie to associate you with your user account or to remember your choices on the Services.

The Cookies We Use

Cookies make the use of our Services easier by, among other things, saving your preferences. We may also use cookies to deliver content tailored to your interests. Our cookies may enable us to relate your use of our Services to Personal Data that you previously submitted. The information that we collect with cookies allows us to statistically analyze usage of our Services, and to improve and customize our content and other offerings.

The specific types of first party and third party cookies placed by our Services and the purposes they perform are described as follows:

Google Analytics (Google LLC)

●      Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the data collected to track and examine the use of the Services, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

●      Place of processing: United States –Privacy Policy – Opt Out.

How to Control Cookies

When you first access our Services from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By clicking “accept”, you signify that you understand and agree to the use of these technologies, as described in this Cookie Policy.

You do not have to accept cookies and consent can be withdrawn at any time, although you may not be able to use certain features of the Services if you do not accept or you withdraw consent. You can do this by clicking opting out as provided above (where available) or by activating the settings on your browser that allows you to refuse all or some cookies.

Please follow the links below to obtain helpful information for the most popular browsers:

●      Microsoft Internet Explorer:

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

●      Microsoft Edge:

https://support.microsoft.com/en-gb/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d

●      Google Chrome:

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

●      Mozilla Firefox:

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

●      Apple Safari: 

https://support.apple.com/kb/index?page=search&type=suggested&locale=en_US&q=cookies+safari&src=globalnav_support 

In addition, you can exercise advertising cookie choices by visiting:

●      http://www.aboutads.info/choices/;

●      http://www.networkadvertising.org/choices/; or

●      http://youronlinechoices.com/.

Web Beacons

As well as cookies, we use other technologies to recognize and track visitors to our Services. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie.

Web beacons allows us, for example, to monitor how Users move from one page within our Services to another, to track access to our communications, to understand whether Users have come to our Services from an online advertisement displayed on a third-party website, to measure how ads have been viewed and to improve site performance. 

Additional Information

Notwithstanding the above, you may also consider following the instructions provided by Your Online Choices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services to manage your preferences for advertising-related cookies. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. Users can make use of these resources in addition to the information provided in this Cookie Policy to manage cookie preferences.

Miscellaneous

Any changes we make to our Cookie Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Cookie Policy.

If you have questions or concerns about TCR’s Cookie Policy, please contact info@campaignregistry.com.

SCHEDULE 2

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information The Campaign Registry has collected about them, and whether The Campaign Registry disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Data Collection” and “Use Of Personal Data And Purpose Of Processing” above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, The Campaign Registry does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age, as the term “sell” is commonly understood.

Additional Privacy Rights for California Residents

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

●      The categories of Personal Information that we have collected.

●      The categories of sources from which we collected Personal Information.

●      The business or commercial purpose for collecting and/or selling Personal Information.

●      The categories of third parties with which we share Personal Information.

●      The categories of Personal Information that we sold or disclosed for a business purpose.

●      The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

Access. You can request a copy of the Personal Information that we have collected about you.

Appeal. You can appeal our denial of any request validly submitted.

Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.

Deletion. You can ask us to delete the Personal Information that we have collected from you.

Opt-out.

●      Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.

●      Opt-out of profiling/automated decision making. You can opt-out of automated processing or profiling performed on personal information to evaluate, analyze, or predict personal aspects related to a person’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

●      Opt-out of other sales of personal data. You can opt-out of other sales of your Personal Information.

Limit processing of Sensitive Personal Information. You have the right to limit certain uses or disclosures of sensitive personal information; however, we do not collect, use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

SCHEDULE 3

PRIVACY RIGHTS OF OTHER U.S. RESIDENTS.

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. The Services are available in all fifty states.

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide their state residents with rights to:

·  Confirm whether we process their personal information.

·  Access and delete certain personal information.

·  Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).

·  Data portability.

·  Opt-out of personal data processing for: (i) targeted advertising (excluding Iowa); (2) sales; or (3) profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

·  Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please contact us, or have your authorized representative contact us, as set forth in “Contact Us” below. In the event you have an authorized representative submit a request to delete, request to correct or request to know on your behalf, you will have to provide written authorization demonstrating this grant of authority, which can include a Power of Attorney. Authorized representatives may not submit any other types of requests on your behalf.

For purposes of requests to delete, correct and to know, we will verify your identity based on information we have collected about you, including your name, address, and phone number, but will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the Personal Information. If we are unable to verify your identity, we may deny your request.

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 request.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada Residents who wish to exercise this sale opt-out rights may contact us as set forth in “Contact Us” below. However, please know we do not currently sell data triggering that statute’s opt-out requirements.