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Medici Technologies, LLC
Privacy Policy

Last update: July 1, 2021

Medici Technologies, LLC, Medici Medical Group, and Medici Clinical Management (“MT”, “MMG,” “MCM,” “we,” “us,” and “our”), are committed to protecting your privacy. This Privacy Policy (“Policy”) applies to your use of the online interfaces and properties owned and controlled by Medici Technologies, LLC and the employees, agents, and/or others authorized to act on behalf of MT. These online interfaces and properties shall include https:/www.medi.ci and the interactive messaging and communication capabilities available to MT account holders.

This Privacy Policy (“Policy”) describes how we collect, use, disclose and protect your Personal Information (defined below). It applies to all Personal Information processed by us in connection with or as part of providing our Services or engaging in written or electronic communications with you. However, this Policy does not describe how we collect or use your Protected Health Information (as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)), which is covered by our Notice of HIPAA Privacy Practices (“HIPAA Notice”). For clarity, the HIPAA Notice, not this Privacy Policy, explains our privacy practices with respect to your Protected Health Information.

We may modify this Policy from time to time. We encourage you to read this Policy periodically to ensure you have up-to-date knowledge of our privacy practices. By continuing to access or use the Services after changes to this Policy become effective, you accept the revised Policy. If any changes are unacceptable to you, you may stop using our Services at any time.

Personal Information We Collect

We collect Personal Information when you use our Services, create an account with us or provide Personal Information to us. Personal Information is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual, including, but not limited to, a first and last name, unique identifier, email address, a home, postal or other physical address, and phone number. The types of Personal Information that we may collect about you are:

  1. Information You Provide to Us

    1. We collect the information you give us when you use our Services, when you participate in surveys or promotional activities, give us feedback, or when you otherwise choose to provide your information to us.

    2. When you use our Services, such as speaking with MMG administrative staff we may collect your name, address, email address, phone number, birth date, credit card information, etc., to verify your identity and provide Services to you.

    3. From time to time, we invite users to volunteer to participate in surveys or promotional activities or give us feedback. When a user participates, we request certain Personal Information such as name and email address. We may use this information to follow-up with the participants, or, if applicable, to notify contest winners and award prizes.

  2. Communications from You

    When you use our Services (for example on our website), complete electronic forms, or contact us, by online chat, email, phone, or text, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request.

  3. Information Related to Your Use of the Services

    We may automatically collect information about your use of the Services (we refer to this information as “Usage Data”), including information sent by Your device. For example, we may collect:

    1. Device information, such as your hardware model, IP address (the Internet address of your computer), unique device identifiers, and other information such as your browser type and operating system.

    2. Website usage information regarding customer traffic patterns and website usage. This may include the web page that you were visiting before accessing our website or mobile application, the pages or features of our website or mobile application you browsed to inform us which part of our website, app and Services you visit and how much time you spend there.

    3. Information about your preferences to make your use of the website more productive through the use of cookies.

  4. Information Sent by Your Mobile Devices
    We collect certain information that your mobile devices send when you use our Services, such as the unique identifier, user settings and the operating system of your device, as well as information about your use of our services on your mobile device.

  5. Location Information
    When you use our online Services, we may collect and store information about your general location by converting your IP address into a rough geo-location, so we can, for example, provide you with information about services available in your geographic market. We may also access your mobile device’s GPS coordinates or course location, but only if you have previously agreed that we can collect this information by allowing the sharing of your location information. If you do not want us to have your location information, you may disable the location sharing feature on your device or browser.

  6. Information from Our Clients and Partners
    We may receive your Personal Information from our business clients and partners, such as your employer, in connection with one or more business purposes, including to make our Services available to you.

Cookies and Other Tracking Technologies

  1. Cookies
    A “cookie” is a small data file that certain websites write to your computer or smart device when you visit them. A cookie can’t read data off your hard disk or read cookie files created by other websites. We use session cookies that are deleted when you leave our website and close your browser and persistent cookies that can remain even after you leave. A cookie file can contain information such as a user ID that the website uses to track the pages you’ve visited. The cookies that are configured by our website do not contain directly identifying information, such as your name, or sensitive information, such as your credit card number.

    1. Cookies are used:

      • to make our Services function properly;

      • to provide a secure browsing experience during your use of our Services;

      • to collect passive information about your use of our Services;

      • to support our marketing campaigns, including to measure how you interact with our marketing campaigns;

      • to help us improve our Services; and

      • to remember your preferences for your convenience.

    2. Types of Cookies on Our Services. We use the following types of cookies on our Services:

      • Strictly Necessary Cookies – These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, Services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.

      • Performance or Analytics Cookies – These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to understand our users better and to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies.

      • Third-Party Cookies – These are cookies that are provided by third-party service providers and belong in one of the cookie categories described above. These third-party providers process your Personal Information on our behalf pursuant to our instructions and obligations consistent with this Policy.

    3. How to Manage Cookies
      Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:

      • First-Party Cookies – If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by changing the settings in your browser. You do not need to have cookies turned on to use and navigate through many parts of our website, although if you block or disable the cookie functions, you may not be able to access all portions or features of the website and the Services. Please follow instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings) to disable first-party cookies. You can find more information about how to change your browser cookie settings here.

      • Third-Party Cookies – Some third-party services providers that we engage (including third-party advertisers) may also place their own cookies on your device. Note that this Policy covers only our use of cookies and does not include use of cookies by such third parties. Modern browsers also allow you to block third-party cookies, please see section above to learn how to do that.

    4. Web Beacons
      Web Beacons, also known as web bugs, pixel tags or clear GIFs, are tiny graphics with a unique identifier that may be included on our website to deliver or communicate with cookies, in order to track and measure the performance of our website and Services, monitor how many web visitors we have, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

    5. Analytics Technologies
      Users of our Services who have JavaScript enabled are tracked using analytics technologies, including Google Analytics. Unless the Analytics feature is blocked, it collects the following types of information from the user: type of user agent (web browser) used, software manufacture and version number; type of operating system; network location and IP address; country, city, state, region, county, or any other geographic data; hostname; bandwidth (internet connection speed); time of visit; pages visited; time spent on each page of the website; referring site statistics; the website (URL) the user came through in order to arrive at our website; search engine query used (example: typing in a phrase into a search engine, and clicking on a link from that search engine). The data collected by the analytics technology is primarily used to optimize the Service experience for our users. We also use this data for our own business purposes, for example, to analyze how many users we have, where visitors come from and understand how they interact with us.

    6. Mobile Applications
      Depending on your permissions, we may receive your Personal Information from your internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Learn more about your choices for mobile devices by visiting Your Ad Choices. To end all targeting on a mobile device immediately, turn on “Limit Ad Tracking” in the device settings. To limit Ad Tracking on an Apple device, please see here. To limit Ad Tracking on an Android device, please see here.

How We Use Your Personal Information

We will only use your Personal Information as described in this Policy or otherwise through your informed consent.

  1. To Provide Our Services to You
    We will use your Personal Information to provide information or perform Services that you request. We may use general location information to improve and personalize our Services to you, such as providing location-relevant information and Services to you. Your information may be available or provided to third-party service providers in order to provide you with the information or to support the Services you request. These third party service providers are contractually obligated to protect your information as disclosed in this Policy.

  2. For the Operation and Administration of Our Business
    We will use your Personal Information for the purposes of furthering our business, including creating, operating, delivering, maintaining, and improving our content, products, and Services. We may monitor how our users use our Services including without limitation time spent using our Services, pages visited and content viewed. Aggregated forms of this data may also be used for research and development purposes in order to offer new features, functionalities, content, products, and services.

  3. For Business Analytics Purposes
    We analyze, and may engage third parties to analyze, your Personal Information and Usage Data to determine the usefulness of our website, mobile app, and other elements of the Services. Analytics help us determine how effective our navigational structure is in helping users reach the information they seek, completing the task they wish to complete, etc., and to tailor features and functionalities to our users’ needs and preferences.

  4. For Our Own Marketing Purposes
    We process your contact information or information about your interactions on our Services to: send you marketing communications and keep you updated about our products and services; provide you with informational content; and deliver targeted marketing to you. We may periodically send you free newsletters and e-mails that directly promote our Services, and that we believe may be of interest to you. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain administrative and transactional communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use, or this Policy, among others.

  5. To Provide Customer Support or Respond to You
    We collect information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes, or issues, so we can address your needs and support your use and enjoyment of the Services.

  6. For Account and Network Security Purposes
    We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your Personal Information, such as your device information, activity information, and other relevant information to proactively manage privacy and security risks. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity to prevent unauthorized users from gaining access to your information.

  7. To Maintain Legal and Regulatory Compliance
    Our Services are subject to certain laws and regulations which may require us to process your Personal Information. For example, we process your Personal Information to comply with privacy laws, comply with employment laws, or as necessary to manage risk as required under applicable law.

Information Sharing and Disclosure

Your Personal Information is not shared with third parties without your permission, except as described below.

  1. Information Shared with Our Employees, Services Providers
    We may engage employees and third-party services providers to work with us to administer and provide the Services or to promote our Services. These employees and third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.

  2. Information Shared with Our Business Clients
    We may share your Personal Information with our business clients for Services provision and business operations purposes. Our business clients purchase our Services for their employees, staff, students, dependents, and other specified persons. We may share your Personal Information with our business clients for purposes related to performing our contractual obligations towards these clients, including to make our Services available to you as sponsored by your employer.

  3. Information Disclosed in Connection with Business Transactions
    If we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. Any information you submit or that is collected after a transfer, however, will be subject to a new privacy policy adopted by the successor entity.

  4. Information Disclosed for Our Protection and the Protection of Others
    We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information about you to government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims and legal process (including subpoenas); (ii) to protect the property, rights and safety of a third party, our users, or the public in general; (iii) to protect our property, rights and safety; (iv) to stop any activity that we consider fraudulent, illegal, unethical or legally actionable; and (v) as required by applicable local, state or federal laws.

Data Security

We safeguard the security of the information you provide to us with physical, electronic, and administrative procedures. For certain features of our Services we use industry-standard SSL-encryption to enhance the security of data transmissions. While we strive to protect your information, we cannot guarantee the security of the Internet, and cannot ensure the security of the information that is transmitted through the Internet.

Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “How to Contact Us” section. If your payment information, username, or password is lost, stolen, or used without permission, please promptly update your account or notify us and we will assist you in updating your account details.

Some portions of the Services (for example our presence on social media) allow users to submit comments, reviews, ratings and other information that may be displayed on the Services and viewed by others. We recommend that you do not post on or through the Services any information that you do not want to make available to other users or the public generally. You assume all responsibility for any loss of privacy or other harm resulting from information you post publicly.

Notices and Disclosures for Residents in Specific Jurisdictions

If you are a resident of a particular jurisdiction, there may be more specific disclosures or you may have certain rights or obligations specific to your region.

  1. California
    As a resident of California, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”) as amended as well as additional California state laws.  For more specific information about our information and your rights as a California resident, please see our Privacy Notice and Disclosure for California Residents below.

  2. Nevada
    Under Nevada law, Nevada residents may opt out of certain “sales” of their data by website operators. Currently, we do not sell any data as defined by Nevada law to trigger any opt out rights. Should that change, we shall revise the policy to inform you of a method to opt out of such sales. Meanwhile, please direct any questions to [email protected].

  3. European Union
    As described in the “International Transfers” section below, Medici neither offers goods and services nor monitors the behavior of residents located in the European Union. Therefore, data protection laws applicable to such activities (e.g., the General Data Protection Regulations (“GPDR”) do not apply extraterritorially to Medici’s activities.

Children and Privacy

We are committed to protecting the privacy of children in connection with the use of our Services. This Section explains our online information collection, disclosure, and parental consent practices with respect to information collection from children under the age of 13 (“child” or “children”) in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”).

Our Services include online services that may be used to facilitate health care for a child. A parent or guardian can communicate with our team on behalf of a dependent child and attest that they have legal authority to do so. Children under the age of 18 are not eligible to register directly for an account. If your child directly uses their account, either with or without your permission, we may collect information directly from the child. If you prefer for your child to not directly interact with us online, please do not provide account credentials to your child. Please note certain state patient privacy laws may permit a child to directly obtain certain types of health care services independent of their parent or guardian.

Registration: Children cannot directly register for our Services. During the user registration process, the parent or guardian can create a children’s account by providing certain information about the child, including name, and birth date.

This Policy contains details about the information we collect, which extend to information we collect about children. The information we collect will also be used for the purposes described in this Policy.

In addition to your right to revoke your consent for the collection of your child’s personal information, you may request to review the personal information we have collected from your child as well as request for us to delete personal information we have collected from your child, subject to our data retention requirements. Please submit your request or any questions to [email protected].

Links to Third Party Sites

We may contain links to other sites that are owned or operated by third parties. We are not responsible for the content, privacy or security practices of any third parties. To protect your information, we encourage you to learn about the privacy policies of those third parties.

Our Social Media Usage

We have accounts on social media platforms through which we may post information or conduct promotional activities. If you use social media to follow us or interact with us, we may collect Personal Information you choose to share with us. Please understand your use of the social media services may result in the collection or sharing of information about you by those social media services. We have no control over, and decline all responsibility for, the use of your personal data by these third parties. Your use of social media, including your interactions with us on social media, are at your discretion. We encourage you to review the privacy policies and settings on the social media services with which you interact to make sure you understand how your information may be collected, used, and shared by those social media services.

International Transfer

Your information is stored on controlled servers with limited access and may be stored and processed in the United States where our service providers are located. We offer our Services only to individuals located in the United States, and we do not advertise our Services outside the United States, nor do we monitor the behavior of individuals located outside of the United States. If you are located outside the United States and choose to provide your Personal Information to us, please note that we may transfer your Personal Information to the United States or another country where our service providers are located, and such countries may not provide the same data protection. Those who choose to access and use the Services from outside the United States do so on their own initiative, at their own risk, with this understanding.

Privacy Notice and Disclosure for California Residents

Effective:  January 1, 2020

This Privacy Notice for California Residents supplements the information contained in the Privacy Policy of Medici Technologies, LLC, as well as the privacy policies of any of its affiliates or subsidiaries, as applicable (hereinafter “Medici”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended. Unless otherwise defined, any terms defined in the CCPA have the same meaning when used in this notice.

What Information Do We Collect? 

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).  Personal information does not include: (a) information that is publicly available from government records; (b) de-identified or aggregated consumer information; or (c) information excluded from the CCPA’s scope, such as (i) 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; or (ii) personal information covered by sector-specific privacy laws including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“CalFIPA”), or the Driver’s Privacy Protection Act of 1994.

The following table and associated statement includes disclosures of the personal information we collect from consumers and the purposes for which it is collected and used, as well as lists of categories of consumers’ personal information we have collected about consumers in the past 12 months, the categories of sources from which it was collected and categories of third parties with whom we shared the personal information.  These disclosures are made pursuant to the CCPA and supplement any other disclosures or notices found in our general privacy policy, cookie policy, or other statements contemporaneously or previously given or made available to you.

Categories of Personal Information Collected

  1. Personal identifiers including name, alias, signature, address, phone number, email address, social security number, device identifier, date of birth/age, driver’s license or other state ID card number or passport number

    1. Sources of Collection

      Individual customers.

      Third parties involved in transactions with our customers.

      Insurance claims and other matters.

      Other individuals or third parties who communicate with us.

      Advertising companies and content publishers that present you with our ads

    2. Business/Purposes for Collection

      To provide products and  services to our customers

      To communicate with individuals who interact with us and our partners

      To provide registration for client or firm events

      To provide Internet of Things (“IoT”) device functionality and data services to our customers

      To provide technical support to our customers

      To make informed business decisions for marketing campaigns, product development, and new features

      To verify customer requests and comply with applicable laws and regulations.

    3. Categories of Third Parties Receiving Personal Information

      Third parties involved in transactions or litigation with our clients

      Marketing service providers

      Third parties involved in providing data and software services associated with our IoT products and services

      Third parties involved in verifying customer requests or other compliance activities

  2. Financial information including bank account numbers or other financial information

    1. Sources of Collection

      Individual clients

    2. Business/Purposes for Collection

      To collect payment for our services

      To facilitate payments and transactions

    3. Categories of Third Parties Receiving Personal Information

      Debt servicing and collection agencies

      Third party payment processors

  3. Internet and other network activity information including online identifiers such as an Internet Protocol (“IP”) address or device identifiers, browsing history, search history, user mobile device type, browsing platform, Wi-Fi connectivity and signal strength, and information about individual interactions with our website, electronic communications, or advertisements 

    1. Sources of Collection

      Website visitors

      Devices and platforms used to access our website

      Medici StreamLabs IoT devices

    2. Business/Purposes for Collection

      To provide information about our services online

      To determine how many unique visitors our website receives, locate the approximate geographic regions of our website visitors, and identify returning visitors

      To deliver marketing communications and advertising
      To identify the devices used to access digital content

      To provide technical support for Medici IoT products

      To improve Medici IoT product performance

    3. Categories of Third Parties Receiving Personal Information

      Website analytics providers

      Marketing service providers

      Technology support providers

      Advertising partners

      Advisors and consultants

In the past twelve (12) months, Medici has disclosed personal information to service providers for business or commercial purposes. The categories of personal information we have disclosed to service providers for business or commercial purposes include:

  • Internet and other network activity information

  • Personal identifiers, such as name, title, biographical information (from other sources in the course of our business), social media identifiers, physical address, IP address, email address, or other, similar identifiers.

This information is collected and used for the purposes disclosed in this PrivacyNotice and the General Privacy Policy.

Aside from disclosures to service providers, the CCPA also requires that Medici disclose “sales” of personal information to third parties. The CCPA further requires businesses that “sell” personal information (as the term “sell” is defined under the CCPA) to provide an opt-out from such sales.  Some people have taken the position that when a website or app uses third-party cookies and similar technology for its own analytics or advertising purposes, the website/app is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app.  Some take this position even when the website/app pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party.

Medici does not believe that any of its activities with service providers constitute “sales” under the CCPA and currently available guidance.  However, if you take the position that any of the relationships described above involve a “sale” within the meaning of the CCPA, then you may consider Medici to have “sold” what the CCPA calls “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on www.rwc.com or affiliate sites), and “commercial information” (like the fact that a browser visited a page directed to people who are considering purchasing from us) to those service providers. As we await clarity , we continue to offer opportunities to limit and/or opt out of the collection and/or use of data via certain third-party cookies and similar technology for analytics and advertising purposes, as described in the paragraph below.

To learn more about interest-based advertising, including how to opt out from the targeting of interest-based ads by some of our current ad service partners, visit aboutads.info/choices  or youronlinechoices.eu from each of your browsers on each of your devices.  You can opt out of Google Analytics and customize the Google Display Network ads by visiting the Google Ads Settings page and installing the Google Analytics Opt-out Browser Add-on from each browser on each device.  If you replace, change or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again.  We do not monitor or follow “Do Not Track” (DNT) signals because there is no standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this Privacy Policy.  Please visit your mobile device manufacturer’s website, or the website for its operating system, for instructions on any additional privacy controls in your mobile operating system, such as privacy settings for device identifiers and geolocation.

You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent.  Some browsers offer similar settings for HTML5 local storage, and Flash storage can be managed as described here.

  1. California Right to Know

    California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purpose for collecting their personal information, and the categories of third parties with whom we shared their personal information. You may submit a request to know by following the process outlined in Section C below.

  2. California Right to Delete

    California residents have the right to request deletion of the personal information we have collected from them, subject to certain exceptions set forth within the CCPA.  You may submit a request to delete by following the process outlined in Section C below.

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

    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.

    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

    Debug products to identify and repair errors that impair existing intended functionality.

    Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

    Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

    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.

    Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

    Comply with a legal obligation.

    Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    Except to the extent we may deny your request above, we shall otherwise make reasonably best efforts to retrieve and delete any personal information associated with or linked to you.  We shall also reach out to any third party vendors with whom we may have shared your personal information to request deletion and confirmation of the same.

  3. Submitting a Request

    You can submit a request exercising your right to know or to delete by emailing us at [email protected].  You will need to provide us with personal information to verify your identity and residency. The personal information that we use to verify your identity and residency will not be used for any other purposes. We do not discriminate against California residents who exercise their privacy rights under CCPA.

    Once we properly verify your request, we will send you an acknowledgement letter via email or mail describing our verification process. We will respond to your request within 45 days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

    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 via email or mail why we made that decision and provide you with a cost estimate before completing your request.

    Please note that, in responding to your request, we are not permitted to disclose or provide you with your Social Security Number, Driver’s License Number, or other government issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.

    Submitting Requests via an Authorized Agent

    Only you, a person registered with the California Secretary of State, or a person you authorize 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. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465.  If a power of attorney that meets those provisions is not submitted, you will be required to verify your identity directly by submitting a verified consumer request according to the procedures outlined above.  If anyone purporting to be an authorized agent for a consumer contacts us, we will require proof that the authorized agent has been authorized to act on the consumer’s behalf.

  4. Your Right to Non-Discrimination for the Exercise of a Privacy Right

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

    Deny you 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 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 provided 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.

  5. Changes to this Policy

    We may update and make changes to this Policy to reflect any changes to our information practices.  If we make any material changes, we will notify you in accordance with applicable law. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review our website for the latest information on our privacy practices.


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