Last Update: 03/26/2021
TABLE OF CONTENTS
- Your Relationship with the Trader Interactive Marketplaces
- Information We Collect
- Additional Information We Receive About You
- How We Use, Share, or Disclose Information
- How We Store Information
- How We Secure Information
- Managing Your Personal Information with Us
- Children and Our Services
- Residents of the State of California
- Residents of the European Union
This policy covers the following marketplaces underneath the Trader Interactive umbrella. Some are used to connect buyers and renters with sellers or owners, and others are used exclusively by our sellers and owners to manage their company information, manage their employee access to their online information, and/or to update/change inventory and listings.
YOUR RELATIONSHIP WITH THE TRADER INTERACTIVE MARKETPLACES
- Trader Interactive, LLC (“Trader Interactive”, “we”, or “us”) owns and operates a set of specialty marketplaces that connect buyers, sellers, owners and renters of recreational vehicles, recreational equipment, motorcycles, private aircraft, and commercial equipment and vehicles. The purpose of our marketplaces is to share the information you provide as an interested buyer or renter with those specific third-party sellers or owners you identify.
- Trader Interactive receives no finder’s fee, revenue share, or other monetary compensation for connecting you to the seller or owner of the item you are interested in.
- You don’t have to provide any information about yourself to search the marketplaces, check the prices of different vehicles, explore the inventory a specific seller or owner is offering, or otherwise browse our marketplaces.
- When you use Trader Interactive’s websites, even if you simply search our marketplaces, we receive some personal information from you such as the type of device you’re using and your IP address. We also use tracking data during your active session on our marketplaces so you can move around the site and go back to previously visited information without losing that information.
- You can choose to share additional information with us, including your email address, phone number, mailing address, or phone number. You do this by completing an online interest form so we can connect you with a seller or owner. You will also provide certain personal information when you create a MyTrader account to join our community of recreational vehicle/equipment enthusiasts or save your searches for future use.
- As a seller or owner advertising on our marketplaces or listing inventory for sale or for rent, you are a third-party business customer of Trader Interactive. Your use and participation in our marketplaces, including the information you provide, will be governed by your contract with Trader Interactive as well as by other separate terms, conditions, and agreements as posted at the bottom of each marketplace page. If you are a business customer, you will provide Trader Interactive with detailed information on your business and your inventory. You will designate employees as key contacts (and provide their detailed business contact information) for your Trader Interactive relationship. All information you provide to Trader Interactive should be tied to your business or dealership – please don’t provide any personal contact information or data as part of our business relationship.
- If you buy an ad on our marketplaces to sell or rent a vehicle or equipment, or if you reserve a rental through our marketplace, you will be required to provide certain personal information to Trader Interactive to complete the transaction, as well as to protect both you and potential buyers/renters from fraud. This additional personal information may include payment data (such as credit card information) or detailed information about you including your driver’s license, vehicle information, location or vehicle, or proof of ownership. As disclosed in more detail below, we use third-party processing to manage and protect this sensitive personal information. We do not obtain, store, or tie this additional personal data to your Trader Interactive account or marketplace activity nor does this information get shared in detail with the sellers or owners.
- Trader Interactive is a subsidiary of Open Road Holdings, LLC. We may share your information from our marketplaces with the marketplaces or affinity sites of other direct or indirect subsidiaries of our parent.
- If you have questions about this policy, how we collect or process your personal data, or anything else related to our privacy practices, we want to hear from you. You can contact us at any time at our Contact Us page or by email at [email protected]
This policy applies to information we collect from or about you through our marketplaces and in email between you and a marketplace. Additionally, we may retain records of our communications through other media (such as phone and mail) based on questions or inquiries you provide.
INFORMATION WE COLLECT
Information You Share With Us
We require certain information to provide our services to you, whether you are a buyer, seller, owner, or renter. For example, you must have an account with us in order to list a vehicle for sale. When you choose to share the information below with us, we collect and use this information to operate our marketplaces and to connect you with buyers, sellers, owners, or renters.
Guest Searching to Basic Request and Account Information: You don’t have to create an account to use some of our marketplace features, such as searching for vehicles or equipment, looking at seller or owner inventory, or checking out the prices of vehicles listed for sale. If you choose to receive our newsletters, create an account on our marketplaces, participate in sweepstakes/give-aways, or engage in other marketplace activities, you must provide us with some personal data so we can enroll you in those services or set up your account. Each contact form, interest form, account set-up, or reservation request identifies the required personal data fields to be completed prior to submitting it to us. Additional fields may be shown but are not required to complete your submission.
When you register for a newsletter, enter a sweepstakes, or set up an account, we may ask for your email address and/or your first name and last name. We will also ask you to create a password when you create your account with us. If you ask to be connected to a seller or owner, we ask you to provide, in addition to the above, additional contact information such as your phone number.
Public Information – Customer Reviews: Some of our marketplaces include the ability for buyers to provide reviews or comments on sellers of vehicles or equipment. Your comments and reviews are posted publicly on our marketplace. Prior to posting your review or comments, we will assess your posting to ensure it meets our content standards and is not inappropriate, offensive, or discriminatory. Please note that any personal data you post may be visible to everyone on the website.
If you would like to have your posted customer review removed from a marketplace, please send us a request through our Contact Us page. Please provide sufficient information to help us to identify the Customer Review that you wish to have removed. We may contact you if we require additional evidence to verify that you are the author of the review. Please note, even if we delete your Customer Review from the marketplace, copies of your review may remain viewable in cached and archived pages, or might have been copied or saved by other users.
Social Media Accounts: You may choose to follow Trader Interactive or our marketplaces via provided links to Facebook, Twitter, Snapchat, Pinterest, or Instagram. We will have visibility into the connection information you share via these social media platforms. You may also choose to use your Facebook or Google accounts to sign-in and create a MyTrader user account. According to your privacy settings on those platforms, these social or sign-in connections with our marketplaces may automatically provide us with access to certain personal data they have stored about you (such as content you have viewed or enjoyed, information about the advertisements you have been shown or clicked on, etc.).
Payment Information: Trader Interactive does not process payments for any parties on our marketplaces. When you are ready to pay for a listing to sell a vehicle, to reserve a rental, or other payment transactions allowed via our marketplaces, your payment will be completed by a third-party payment processing company, Clear Commerce or Stripe. Clear Commerce or Stripe will accept and store your payment information, process your payment transaction, and provide confirmation back to you, the owner, and us as applicable that your payment has completed successfully. Please refer to their respective privacy policies available at the bottom of their website when you provide your payment information.
Other Data You May Share with Our Company: In addition to your interaction with our marketplaces, you may share information about yourself and your interests through:
- Information you provide when you apply for a job through our website. This includes any email address you provide to receive a reminder to apply for a position via “Remind me to apply later”.
- Information that you provide by completing and submitting “help” inquiries. This includes requesting specific services or support that may be tied to an account or other relationship you have with our marketplaces.
- Records and copies of your correspondence (including email addresses), if you contact us, including through the “Contact” or “Send Us Feedback” page of our marketplaces.
- Information you share in the free-from text box on our email inquiry form that could include additional personal data we did not specifically request from you. Other information you provide in that text box that could be used to associate you to an existing account or other relationship with our company or marketplaces.
How You Control Information You Provide to Us:
As noted above, you control how and what you share with our marketplaces. Below are actions you can take:
- Only share your personal information when you want to be connected to a seller, and be contacted on a vehicle or piece of equipment. You can search and look without providing any information or identifying yourself.
- If you have a MyTrader account, you can update and change the information associated with your account via our marketplaces. The account information clearly shows what information is required to maintain your account. It is your choice to enter additional information on optional fields.
- MyTrader account holders may also send us an email at [email protected] to request access to correct or delete any personal information that you have provided to us. Some of your personal information cannot be deleted by us except by also deleting your user account. We may not accommodate a request to change information if we cannot verify the personal information relates to you, if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
ADDITIONAL INFORMATION WE RECEIVE ABOUT YOU
We receive certain information when you use our services or other marketplaces or mobile applications that include our content, and from third parties including advertisers. We use such data, described in detail below, to operate our marketplaces.
Location Information: We require information about current location, which we get from signals such as your IP address or device settings, to determine content and services available to you through our marketplaces. We use an outside vendor company to resolve your IP address during a browsing session to a location. We do not retain your IP address as part of your activity or account.
To Opt Out of Cookies. You have the ability to adjust your browser settings to manage how we or other websites track your browsing activity. More information can be found at StaySafeOnline.org. Additionally, you can manage the advertising presented to you while browsing any website through the Ad Choices link at the bottom of each page in our marketplaces.
Cookies are not required for many parts of our marketplaces, such as searching. Although most web browsers automatically accept cookies, many browsers’ settings can be set to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some of our services may not function properly if you disable cookies.
Log Data: We receive information when you view content on or otherwise interact with our marketplaces, which we refer to as “Log Data,” even if you have not created an account. For example, when you visit our marketplaces, sign into your account, or interact with our email or contact forms, we may receive information about you. This Log Data includes information about your computer and internet connection, as well as details of your visit to our marketplaces. Specifically, this includes traffic data, logs, and other communication data and the resources that you accessed and used – some data may only be used during your active session (and then forgotten) while other data may persist such as your preferences or remembering you when you return. We may also collect IP address, browser type, operating system, the referring web page, pages visited, location (based on IP address), device information (including device and application IDs), search terms, and cookie information.
We use Log Data to operate our services and ensure their secure, reliable, and robust performance. For example, we use Log Data to protect the security of accounts and to determine what content is popular on our marketplaces. We also use this data to improve the content we show you, including ads. We use the information you provide to us and data we receive, including Log Data and data from third parties, to make inferences like what topics you may be interested in which helps us better design our services for you and personalize the content we show you, including ads.
Other Third Parties and Affiliates: We may receive information about you from third parties who are not our advertisers or ad vendors, such as vendors and service providers who help us evaluate the safety and quality of content on our platform or our corporate affiliates.
Personalizing Across Your Devices: When you log into our marketplaces on a browser or via our mobile application on a device, we will associate that browser or device with your account for purposes such as authentication, security, and personalization. We may also associate the activity you did on one and share it with the other. We do this to operate and personalize our marketplaces and make them more relevant to you.
HOW WE USE, SHARE, OR DISCLOSE INFORMATION
The nature of our marketplaces requires that we share your personal information directly with the seller or owner you have identified in your interest/contact form to make these connections. You play a large part in what personal data we share and with whom we share it. However, in limited circumstances we may also disclose your personal data for additional purposes. We make such disclosures either (a) at your direction or with your consent, (b) subject to your right to opt-out, (c) as necessary to operate our services, or (d) as required by law.
Sharing You Control: We share or disclose your personal data with your consent or at your direction to connect you with the designated seller or owner that has the vehicle or equipment you are interested in.
While we don’t process your payments, we facilitate the connection to our third party payment processing providers, Clear Commerce and Stripe, to accept your payment data, store that data as needed, process your payment transaction, and manage any post-transaction activities. Clear Commerce and Stripe may send us information when the charge was accepted or that is has failed or was otherwise fraudulent, or that there is a dispute on a charge made on our behalf. We may share additional data with Clear Commerce or Stripe to investigate and resolve activities resulting from the payment process.
- Comply with a law, regulation, legal process, or governmental request;
- Protect the safety of any person;
- Protect the safety or integrity of our platform, including to help prevent spam, abuse, or malicious actors on our services, or to explain why we have removed content or accounts from our services;
- Address fraud, security, or technical issues; or
- Protect our rights or property or the rights or property of those who use our services.
Non-Personal Information: We collect, share and/or disclose non-personal data, such as anonymized or “de-identified” information and aggregated information about our customers and marketplace users such as the total number of times people engaged our marketplaces this month, the states those visits came from, or information related to advertising clicks or other metrics. This information does not identify any individual, without exception. All such non-personally identifiable information collected by us through our marketplaces, and all aggregated/compilations of non-personally identifiable information that we create, are the exclusive property of Trader Interactive. We may use any such non-personally identifiable or aggregated information for any purpose, including monitoring user traffic patterns, analyzing and quantifying user preferences, improving the design and content of our Services, and enabling us to personalize your user experience, and we may share it with customers, advertisers, service providers, and other third parties.
Other Uses: Trader Interactive also uses information collected about you, as well as non-personal data, to provide and improve our services and products, including to:
- provide and deliver our products and services, assist with processing transactions and send related information such as confirmations and invoices;
- send you technical notices, updates, security alerts and support and administrative messages;
- communicate with you about products, services, offers, promotions, rewards and events offered by Trader Interactive and others, and provide news and information we think will be of interest to you;
- monitor and analyze trends, usage and activities in connection with our products and services;
- revise, modify, and update existing services and products and develop new services and products;
- personalize the services and products and present you with advertising, content or features that we believe will be of interest or useful to you; and
- carry out any other appropriate purpose described to you at the time immediately before the information was collected.
HOW WE STORE INFORMATION
Storage of Information and Data: Trader Interactive is located in the United States, and all information that we receive or collect is stored in the United States. This means your personal information may be subject to the laws of general application in the U.S.
HOW WE SECURE INFORMATION
Security of Information and Data: Trader Interactive employs technological and organizational measures to ensure that your personal data is protected against unauthorized or unlawful access, use or disclosure.
MANAGING YOUR PERSONAL INFORMATION WITH US
You control the personal data you share with us and that we forward onto the respective seller or owner with your consent or at your direction. You may use a contact form to have us connect you with a specific seller who has the vehicle or equipment you are looking for. You may submit a rental reservation request for an owner’s specific recreational vehicle for your next vacation. While it is more likely you will communicate directly with the seller or owner, you can ask us to provide access to or to correct the data you have provided.
If you have created a MyTrader, TraderTraxx, or other marketplace account, you can update the account information or delete your account. Where applicable, we also provide you tools to restrict or withdraw consent for contacting you or the use of data you have provided to us. We make the data you shared available in our marketplaces portable and provide easy ways for you to contact us.
Accessing or Rectifying Your Personal Data:You can request access to your personal information with us in writing by contacting us at [email protected] We will respond within 30 days. We will provide you access to your personal information unless we are prohibited to do so, for example, if providing you access violates the privacy of another person. If we cannot give you access to your personal information, we will provide justification.
If you have submitted a contact or interest form that we shared with the designated seller or owner, you can obtain a copy of what we sent by filling out this Web Form directly. We may include, as part of your contact or interest form submission, other information that is inferred from your visit or passively obtained via third-parties about you and your activity. This additional information is only included along with the contact information you provided to businesses that sell vehicles.
If you have created an account on Trader Interactive marketplaces, we provide you with tools and account settings to access, correct, delete, or modify the personal data you provided to us and associated with your account.
Retention and Deletion: We keep Log Data for a maximum of 18 months. If you follow the instructions here, your account will be deactivated and then deleted. When deactivated, your MyTrader account will no longer be viewable on our marketplaces. For up to 30 days after deactivation, it is still possible to restore your account if it was accidentally or wrongfully deactivated. The account and all data in the account will be deleted if you take no action within 30 days after it was deactivated.
Object, Restrict, or Withdraw Consent: When you are logged into your MyTrader account, you can manage your settings and other account features here at any time.
Portability: Trader Interactive can provide you a means to request a download of the information you have shared through our marketplaces for you to transfer it as you choose by following the steps here.
If you live in the United States, Canada, and Mexico, the data privacy officer for your personal data can be contacted at:
Trader Interactive, LLC
Attn: Privacy Requests
999 Waterside Drive, Suite 1900
Norfolk, VA 23510-3318
If you live outside the United States, Canada, and Mexico please reference the Residents of the European Union section below
CHILDREN AND OUR SERVICES
Our marketplaces assume all users expressing interest in purchasing or renting vehicles from our sellers and owners are of majority age, can sign a contract, have a payment form issued in their name, and have a valid driver’s license. Our services are not directed to children, and you may not use our services if you are under the age of 18. You must also be old enough to consent to the processing of your personal data in your country or state of residence.
RESIDENTS OF THE STATE OF CALIFORNIA
If you are a resident of the State of California, you may have additional privacy rights under the California Consumer Privacy Act. Learn more about these privacy rights by visiting our Privacy Notice for California Residents.
RESIDENTS OF THE EUROPEAN UNION
Currently the Trader Interactive marketplaces are not open for use by residents of the European Union and we block IP addresses that trace back to locations within the European Union or European Economic Area. If you are a resident of the EU and have accessed our marketplace from inside the United States, you may search our marketplaces, create an account (tied to a non-European Union identity), or make connections with sellers and renters on our marketplace. However, your transaction to book a rental reservation or interaction may be denied or blocked if you provide personal information that identifies you as a resident of the European Union.
March 26, 2021
TABLE OF CONTENTS
- Information We Collect
- How We Obtain Information We Collect
- Use of Personal Information
- Sharing Personal Information
- Your Rights and Choices
- Access to Specific Information and Data Portability Rights
- Deletion Request Rights
- Exercising Access, Data Portability, and Deletion Rights
- Response Timing and Format
- Changes to Our Privacy Notice
- Contact Information
INFORMATION WE COLLECTWe 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 or household (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|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 (physical illness, mental illness or disabilities). 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).||YES|
|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.||YES|
|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.||Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as:
- 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
- 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.
HOW WE OBTAIN INFORMATION WE COLLECTWe obtain the categories of personal information listed above from the following categories of sources:
- Directly from consumers. For example, from email provided on our marketplaces for consumers to obtain our newsletters, enter sweepstakes or giveaways, to be connected with a seller or owner, or other participation in our marketplace communities.
- Directly from seller and owners. For example, information that sellers and owners provide to list vehicles or equipment for sale or rent on our marketplaces.
- Indirectly from consumers. For example, through referral links from partner sites, searches or vehicle or equipment listing views collected from consumers in the course of connecting them with a seller or owner.
- From third-parties that interact with us in connection with our marketplaces. For example, we engage a vendor that resolves your Internet Protocol address to a geographic location.
USE OF PERSONAL INFORMATIONWe may use or disclose the personal information we collect for one or more of the following business or commercial purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you share your personal information to inquire about a listed vehicle, we will share that personal information with that seller to connect you with them;
- To provide you with information, products, or services that you request from us, such as newsletters or to search our marketplaces for vehicles or equipment available from listing sellers or owners;
- To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you;
- As a seller, owner, or if you have posted a private listing to sell a vehicle or equipment, we collect personal information from you to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing for advertising your listing;
- To improve our website and present its contents to you;
- For testing, research, analysis, and development of our marketplaces and existing and new products;
- As necessary or appropriate to protect our rights and property, and the rights, property, or safety of us, our clients or others;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- As described to you in a notice presented at the moment when we collect your personal information or as otherwise set forth in the CCPA; or
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
SHARING PERSONAL INFORMATIONWe may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into 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. In the preceding twelve (12) months, we have 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. We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers; and
- Third parties to whom you have authorized us to disclose your personal information via requests to connect you with a seller or owner through a contact or inquiry form.
YOUR RIGHTS AND CHOICESThe CCPA provides 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 RIGHTSYou have the right to request that we disclose certain information to you about our collection and use of your personal information during the twelve (12) month period preceding your request. Once we receive and confirm your request, we will disclose to you the information we are obligated to provide under the CCPA, which may include:
- The categories of personal information we have collected about you;
- The categories of sources from which we have collected your personal information;
- Our business or commercial purpose for collecting your personal information;
- The categories of third parties with whom we share your personal information;
- The specific pieces of personal information we have collected about you (also called a data portability request); or
- The categories of personal information we have disclosed for a business purpose, and the categories of third parties to whom we have disclosed such personal information.
DELETION REQUEST RIGHTSYou have the right to request that we delete some or all of your personal information that we have 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 whom we have furnished that information to also delete) your personal information from our (and their) records, unless an exception applies. With respect to the exceptions, we may deny your deletion request if retaining the information is necessary for us or our service providers 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 right of free speech, 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 your expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of your information that are compatible with the context in which you provided it to us.
EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTSTo exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
RESPONSE TIMING AND FORMATWe endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period. If you have an account with us, we will deliver our response to your request 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 our receipt of your verifiable consumer request. 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 your request is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we will explain to you how we made that decision and provide you with a cost estimate before completing your request.
NON-DISCRIMINATIONWe will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not, as a result of or due to you exercising any of your CCPA rights:
- 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.