Exclusive Business Class Privacy Policy

One of the most important things for us is to protect your personal data. In this order we collect information rightfully, acting with integrity, confidentiality, and with great certainty.

What is the purpose of the privacy policy we set out below? In fact, the goal is a well-defined one that will accurately describe how our company collects and handles customer’s personal data and at the same time we also talk about any other data customers provide through different platforms when they buy a product or service or subscribe to our Newsline.

The purpose of this statement is to inform you about the procedures we have approached to protect your personal data successfully. This policy refers to our website, text messages, emails, and social account. By using one of our platforms, you hereby agree to our Terms and Conditions. We do not intend to knowingly collect information from children.

Personal Information we collect and use:

“Personal information” is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For purposes of this Policy, there is no meaningful distinction between the terms “personal information” and “personal data.”

We may collect, use and transfer the following types of personal data:

• Identity Data, which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, photographs, national insurance number, job title, vehicle registration number(s), age, and gender;
• Contact Data, which includes billing address, delivery address, personal email, and phone numbers;
• Booking data (such as, for each traveler, the traveler’s name, frequent flyer details, passport number, redress control number, country of citizenship, booking reference number, and itinerary, which may include name of airline or carrier, hotel accommodation and/or vessel, port of destination, port of arrival, date and time of departure and/or check-in, date and time of arrival and/or check-out, meal preferences, luggage information, and layover information);
• Financial Data, which includes bank account and payment card details;
• Transaction Data, which includes details about payments and donations from you and details of products and services you have purchased from us and activities you have participated in;
• Technical Data, which includes the data that can be automatically collected from any device used to access the Site or our Services. Such information may include, but is not limited to: your device internet protocol (IP) address, your login data, browser type and version, time zone offset settings and geolocation, CPU, screen resolution, device memory, system languages, installed fonts, draw canvas logic, browser plug-in types and versions, operating system and platform, full ‘Uniform Resource Locators’, clickstream to, through and from the Site (including date and time) and other technology on the devices you use to access the Site;
• Profile Data, which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, mouse-overs and methods used to browse away from the page);
• Usage Data, which includes information about how you use the Site, products, and services;
• Marketing and Communications Data, which includes your preferences in receiving marketing from us and Our third parties and your communication preferences; and
• Information that can include search history, IP address, screen resolution, browser used, operating system and settings, access times, and referring URL. If you are using a mobile device, we may also collect data that identifies your device, your settings, and your location;
• Customer support information: when you contact our customer support services we will collect any inquires, complaint, or other information that you may submit to our support team.
• Any other information you provide us.

In fact, we do not collect any category of special information.

Only after you guarantee that all the information about your personal data is truthful and that it is your responsibility to provide us, we assume the responsibility to collect, process, and maintain it safely.

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

The provision of the above personal data, where requested, is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations except when we rely on consent as a legitimate basis for processing and or our legitimate interest. Without it, we may not be able to provide you with all the requested services. It is important that all the personal data you give us is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.

In case we have to collect your personal data according to law or under the terms and conditions of a contract with you (customer), and you don’t provide the requested data, we can’t finish the contract that we have or are trying to enter into with you. Therefore, we might need to cancel a service. However, in these types of situations, we will keep you informed.

At this time, the methods we and our third-party service provider use to collect your personal data are:

The personal information you give to us: We collect your personal information directly from you.

For example, you provide us with your personal information when you register or book travel, contact our customer support.

At the same time, we have the passive ability to collect some personal information. How does this happen? When you visit our website, you provide the opportunity to collect certain information about yourself. In addition, when you are using our website, cookies and other similar technologies can help us automatically collect technical data about your equipment, navigation actions, and patterns. See the cookies section of this Privacy Policy for further information on the purposes for which we collect and use this information.

Voice Calls: We may record or monitor calls to and from our Customer Support Team for contractual reasons, quality control purposes, analytics, staff training and/or to protect us in the event of a legal dispute. Any personal data obtained from you during the call will be treated in accordance with this Privacy Policy.

From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), and other third parties, to the extent permitted by applicable law.

Automatic Information: We automatically collect certain information about your computer when you visit our website. For example, we record your IP address, Web browser software (such as Firefox, Safari, or Internet Explorer), and referring website. We also may gather information about your online activity, such as trips or activities viewed and bookings made. We collect this automatic information to customize your user experience and protect against fraud. See also Cookies and other technologies below.

In order to help you find the nearest hotel, train station, airport, or send some important messages to you, our system can use the attributes and settings of your device that allow us to determine physical location.

You can opt-out of this communication at any time by contacting us via phone or email.

We may use your Personal Information for the following purposes:

• To create and maintain the contractual relation established for the provision of the product and/or service requested by you, which includes to complete and fulfill your booking or purchase, including to process your payment, communicate with you regarding your booking or purchase, and provide you with related customer service. Information concerning our provision of the Service and/or to provide you with any clarification or assistance may be sent to you via email, phone, SMS, recorded calls or other similar technologies.
• To authenticate your account credentials and identify you, as necessary to log you in to the Services and ensure the security of your account.
• To communicate with you about your account or use of our Services and/or functionality (e.g.: to send administrative information to you, such as information regarding the Services and changes to our terms, conditions, and policies); respond to your inquiries and fulfill your requests, such as to send you newsletters, or follow up on, your comments and questions; and otherwise provide customer service.
• To record or monitor calls to and from our Customer Support Team for contractual reasons, quality control purposes, analytics, for staff training and/or to protect us in the event of a legal dispute.
• To send you marketing communications, that we believe may be of interest to you, via email, phone, mail, SMS, or other equivalent electronic communication regarding products and services similar to those already purchased by you and offered on our Website.
• to permit you to participate on message boards, chat, profile pages and other services to which you are able to post information and materials (including our Social Media Pages). Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the Website and to the general public.
• To personalize your experience on the Services by presenting products and offers, marketing notifications and advertising tailored to you based on the information on your use of our Website, products and services and other sites collected through cookies (please see the Cookies section of this Privacy Policy for further information).
• To provide services and information to travel partners, such as providing user feedback and usage details.
• For our business purposes, such as data analysis, market research, audits, developing new products, fraud monitoring and prevention, to protect against, investigate, and deter fraudulent, unauthorized, or illegal activity.
• To comply with our policies, procedures and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law.
• As otherwise consented to by you and as required or permitted by applicable law. If you give your consent to any further use of personal information, you can withdraw that consent at any time by contacting us using the details set out below.

Consistent with the above purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email, text message, or mobile push notification to:

• Send you information relating to our products and Services. This may include booking confirmations and updates, technical notices, updates, security alerts, support, and administrative messages.
• Send you marketing communications. In other situations, we may communicate with you about contests, offers, promotions, rewards, upcoming events, and other news about products and Services offered by us, our group companies, our travel partners, and other business partners.

Email Communications. From time to time, we may send you emails containing information about your apparent travel-related or activity interests. We do this to make it easy for you to take advantage of travel-related or other opportunities on our website.

If you no longer want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in such emails to opt out of future marketing email communications. If you have an account, you may also opt out of marketing emails in your account settings. Please note that even if you opt out of receiving marketing communications from one or all of our Services, we will still send you service-related communications, such as confirmations of any future bookings you make.

Push Notifications (on Mobile Devices). You can use the settings on your mobile device to enable or turn off mobile push notifications from us.

SMS Message Service. With your consent, where required, we may contact you at the mobile phone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, and text messages in connection with the above purposes.

By signing in to the SMS message service, you consent to receive recurring autodialed marketing texts from or on behalf of our Company at the mobile number you’ve provided to opt-in. You understand that consent is not a condition of purchase. Message & data rates may apply.

After you opt-in to receive messages online, in-person, or SMS, you can cancel the SMS service at any time by just replying “STOP” to the SMS message. After this, you will no longer receive SMS messages from us. Unsubscribing from our SMS service will not preclude us from sending you service-related SMS in connection with an existing booking, including us contacting you with an automated pre-recorded call containing critically important travel information (e.g., Major Schedule Change Notifications via call and/or SMS message). If you want to join again, just sign up as you did the first time, and we will start sending SMS messages to you again.

If at any time you forget what keywords are supported, just reply “HELP” to the SMS message. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe.

As always, message and data rates may apply for any messages sent to you from us and to us from you. Message frequency depends on the user’s interaction. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

You represent that you are the account holder for the mobile telephone number(s) that you provide. You are responsible for notifying us immediately if you change your mobile telephone number. You may notify us of a number change by contacting us via email at info@exclusivebusinessclass.com.

You agree to indemnify us in full for all claims, expenses, and damages related to or caused in whole or in part by your failure to notify us if you change your telephone number, including, but not limited to, all claims, expenses, and damages related to or arising under the Telephone Consumer Protection Act.

For all questions about the SMS message service, you can contact us at:
Telephone: +1 888-341-5254
Email: customercare@exclusivebusinessclass.com

In case of need to transmit your data to third parties, we will take into account the following:

• only with your consent;
• if this operation is strictly necessary to provide our services;
• in case it is necessary to send to a lawyer the information, to start the procedure for resolving the litigation;
• in case it is necessary to protect the integrity and transparency of our company;

Also, there is a possibility to share information about your personal data with our business partners. Some of these business partners may use your personal information for fraud detection found, for an email address, to detect, prevent, or otherwise address fraud, security, or technical issues. We may also share your information by asking our partner to create an application, questionnaire e.t.c, for the purpose to know the degree of your satisfaction with our services. Some of these business partners may use your personal information for online behavioral advertising purposes, or to offer you services or products that we believe you may be interested in. We may also share your information as otherwise described to you at the time of collection. We may also share anonymous aggregated usage information with partners.

Our servers and data centers are located in many countries and by giving us your personal information, you agree that it can be shared with other countries that may have different and/or less strict confidentiality rules. As a result, your personal information may be subject to requests for access from Governments, Courts, or Law Enforcement Agencies from these countries in accordance with the laws of these countries. According to the legislation in force in such countries, we will provide the necessary security measures to ensure the protection of your personal information.

We have adopted the appropriate security measures to avoid accidental loss, use or access to your personal data in an unauthorized manner, alteration or disclosure. In addition, we restrict access to your personal data only to those employees, agents, contractors, and other third parties who need to know the business. They will process your personal data only in accordance with our instructions and are subject to confidentiality.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting via email at info@exclusivebusinessclass.com.

To establish the necessary retention period for personal data, we examine the amount, nature, and vulnerability of the personal data, the motives for which we process your personal information, even if we can fulfill those motives through other methods and the appropriate legal, government tax, accounting or other requirements.

A cookie (also called an Internet/Web cookie) is a type of message that is given to a web browser by a web server. The main goal of a cookie is to determine users and possibly prepare customized Web pages, as well as to save site login information for you.

If our client is on his first visit to our site, we will send him cookies. You ask, “What for?”. The answer is very simple. We collect information about our clients’ preferences around the browser or search methods that they usually use.

We and certain third-party partners use cookies on our websites, our mobile applications and within emails or other communications, we send to you.

To the extent, the cookies we use for these purposes lead to the processing of your personal information, details about how we use that personal information and your rights over that personal information are discussed in this Privacy Policy

Types of Cookies used on our Website.

Generally speaking, we use the following type of cookies:

• First-party cookies: these are sent to your device from a website or domain managed by us and from which the service you requested is provided.
• Third-party cookies: these are sent to your device from a website or domain other than the one being visited by you and that is not managed by us, but by a separate entity that processes data obtained through cookies.
• Session cookies: these are designed to receive and store data on your device while you access the Website until you close your web browser.
• Persistent cookies: these types of cookies remain stored on your device and can be accessed and processed after you exit the Website as well as when you navigate on it for a pre-determined period of time. Persistent cookies help us recognize you as an existing user of our Website, so it’s easier and convenient to return to our Website or interact with our Services without signing in again.
• Technical Cookies: these Cookies are strictly necessary for the operation of our Website and are essential for browsing and allowing the use of various features. Without them, you cannot use the search function or book other available services on our Website.
• Personalization Cookies: these are used to make navigating our Website easier, as well as to remember your selections and offer more personalized services.
• Analytical Cookies: these Cookies gather information about your use of our Website, the pages you visit and any errors that may occur during navigation in order to make our Services more useful and relevant to you.
• Advertising and re-marketing Cookies: these Cookies are used to gather information so that ads are more interesting to you, as well as to display other advertising campaigns along with advertisements on the Website.
• Social Media Cookies: these cookies are used to allow you to share or like our pages and content through third-party social media websites.

By sending cookies to your browser, it allows us to regularly adjust the quality and convenience of our site according to the preferences of each client.

You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our Website, some Services and functionalities may not work.

In general, the browser can offer the ability to control cookies. Control modes are different from browser to browser. If you use multiple browsers to access our services, you need to set the cookie disabling options for each browser, computer, or device you use. If your browser blocks cookies, your preferences may be deactivation are not effective. If you block or delete cookies or opt-out of online behavioral advertising, not all the trackings we’ve described in this policy will stop. Some features that our site operates may not be accessible because you are blocking the cookies on the device or browser that you use.

In order to provide better services, we can use Google Analytics to collect demographic and interest data about you.

In case you are using our services in the territory of Europe, we have set out below a description of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate and what is your data subjects’ rights under EEA legislation.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1. To register you as a new customer.
   Type of data:
   
   1. Identity
   2. Contact
   3. Performance of a contract with you.
   Lawful basis for processing including the basis of legitimate interest:
2. To process and deliver your order including:
   1. Manage payments, fees, and charges.
   2. Collect and recover money owed to us.
   Type of data:
   1. Identity
   2. Contact
   3. Financial
   4. Transaction
   5. Marketing and Communications
   Lawful basis for processing including the basis of legitimate interest:
   1. Performance of a contract with you.
   2. Necessary for our legitimate interests (to recover debts due to us).
3. To manage our relationship with you which will include:
   1. Notifying you about changes to our terms or privacy policy.
   2. Asking you to leave a review or take a survey.
   Type of data:
   1. Identity
   2. Contact
   3. Profile
   4. Marketing and Communications
   Lawful basis for processing including the basis of legitimate interest:
   1. Performance of a contract with you.
   2. Necessary to comply with a legal obligation.
   3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
4. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). Type of data:
   1. Identity
   2. Contact
   3. Technical
   Lawful basis for processing including the basis of legitimate interest:
   1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise).
   2. Necessary to comply with a legal obligation.
5. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. Type of data:
   1. Identity
   2. Contact
   3. Profile
   4. Usage
   5. Marketing and Communications
   6. Technical
   7. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy).
   Lawful basis for processing including the basis of legitimate interest:
6. To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences. Type of data:
   1. Technical
   2. Usage
   3. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy).
   Lawful basis for processing including the basis of legitimate interest:
1. To make suggestions and recommendations to you about goods or services that may be of interest to you.
2. Type of data:
3. Identity
4. Contact
5. Technical
6. Usage
7. Profile
8. Marketing and Communications
9. Necessary for our legitimate interests (to develop our products/services and grow our business).
Lawful basis for processing including the basis of legitimate interest:

1. You can ask for access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Deletion of your personal data. This gives you the right to solicit us to delete or remove personal data from our system. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below). Note, in some cases when the legislation prohibits us to comply with your request, we will not delete or erase the data, anyway, you will be notified of that.
3. You can ask for the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
4. The right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
5. Restriction of processing of your personal data. In the following cases:
   1. Establish the data’s accuracy.
   2. Suspicions of illegal use of data.
   3. Hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
   4. Objections to our use of your data, at the same time we will verify whether we have superior legitimate motives of data usage.
   5. Transfer of your personal data to you or to a third party.

Withdraw consent at any time where we are relying on consent to process your personal data.

In order to use any of the above-mentioned rights, you should contact us, and provide information to identify yourself, so we can be sure you are the entitled person to make the mentioned requests.

This Privacy Notice for California Residents supplements the information contained in our privacy policy above applies solely to the personal data of users who reside in the State of California (“consumers” or “you”). We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

INFORMATION WE COLLECT

Our Website collects 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 information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	[YES]
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	[YES]
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	[NO]
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	[YES]
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	[NO]
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	[YES]
G. Geolocation data.	Physical location or movements.	[YES]
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	[NO]
I. Professional or employment-related information.	Current or past job history or performance evaluations.	[NO]
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	[NO]
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	[NO]
L. Equipment information.	Information about your internet connection, the equipment you use to access our Website, and usage details.	[YES]

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Our Website obtains the categories of personal information listed above from the following categories of sources:

1. Directly from you. For example, from forms you complete or products and services you purchase.
2. Indirectly from you. For example, from observing your actions on our Website.
3. From third-party business partners such as social media sites, ad networks, and analytics providers.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment.
• To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• 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 materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Our Website may disclose your personal information to a third party for a business purpose. 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 contract.

We share your personal information with the following categories of third parties:

• Service providers.
• Data aggregators.

Disclosures of Personal Information for a Business Purpose

We engage certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Data aggregators.

In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices:

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

If we sold or disclosed your personal information for a business purpose, two separate lists disclose:

• sales, identifying the personal information categories that each category of recipient purchased;
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

1. provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
2. describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.RESPONSE TIMING AND FORMATWe endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

DO NOT SELL MY PERSONAL INFORMATION

Our Company does not sell your personal information to third parties.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny your 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 with 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

The below companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes.

Please keep in mind that the privacy policy of our company can support changes over time. It also needs to be mentioned that our company is not entitled and will never restrict your rights to the protection of personal data.
As a method of precaution, all the changes that will take place on our site will be announced in advance and we will post the date of the last update. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us.