We are required by the California Privacy Rights Act (“CPRA”) to provide to California residents an explanation of how we collect, use and disclose their personal information, and of the rights we offer to California residents with respect to that personal information. For purposes of this section, “personal information” has the meaning given in the CPRA.

The following sections describe our practices with respect to personal information subject to the CPRA:

• For the categories of personal information we have collected in the past 12 month, see the Personal Information We Collect section above. 
• For the categories of sources from which personal information is collected, see the Personal Information We Collect section above.
• For the specific business and commercial purposes for collecting and using personal information, see the How We Use Your Personal Information section above.
• For the categories of third parties to whom information is disclosed, see the How We Disclose Your Personal Information section above.
• For the criteria used to determine the period of time personal information will be retained, see the Retention section above.
• We do not sell personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CPRA. A “sale” is broadly defined under the CPRA to include a disclosure for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: contact identifiers, characteristics or demographics, commercial or transactions data, profile data, device identifiers, device data, internet activity data, non-precise location data, and inferences drawn from any of the above. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details on your rights regarding sales and shares, see the Right to Opt-Out of Sales and Sharing section below. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.

Some of the personal information we collect may be considered sensitive personal information under CPRA. For example, account credentials. We collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.

Rights to Know, Correct, and Delete.

The CPRA grants California residents the following rights. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. 

• Right to Know. You have the right to know the following: what personal information we have collected about you, including the categories of personal information, the categories of sources from which personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of personal information that we sold, shared, or disclosed for a business purpose, the categories of third parties to whom we disclosed personal information, and the specific pieces of personal information we have collected about you.
• Correction. You have the right to correct inaccurate personal information we have collected from you.
• Deletion. You have the right to delete the personal information that we have collected from you.

You are entitled to exercise the rights described herein free from discrimination.

To exercise any of these rights, please follow the instructions for data subject requests in the Your Privacy Choices section above. If you have an account with us, we may require you to use the account to submit the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your rights. As part of this process, we may ask for your email or other forms of identification. If we are unable to verify your identity, we may deny your request in accordance with the CPRA.

Right to Opt-Out of Sales and Sharing. 

To the extent we “sell” or “share” your personal information as those terms are defined under the CPRA, you have the right to opt-out of the sale or sharing of your personal information. To exercise this right, please follow the instructions for opting out of sales, shares, and targeted advertising in the Your Privacy Choices section above. 

Authorized Agent

Consistent with California law, you may designate an authorized agent to make a request on your behalf. Except for requests made by opt-out preference signal, we will require written and signed proof of the agent’s permission to do so and may verify your identity directly with you. Requests must be submitted through the designated methods listed above.

Shine the Light. California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any). You can submit such a request by contacting us as set out in Contact Us section with “Shine the Light” in the subject line. The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.