Optimal (“we”, “us”, or “our”) and our subsidiary companies are committed to respecting your privacy rights. Our targeted digital advertising network and digital advertising offerings and ad targeting technology deliver targeted digital advertisements online and on mobile devices for advertisers (our “Services”).
NAI membership & compliance
Our subsidiary UNTU is a member of — and adheres to the Code(s) of Conduct of — the Network Advertising Initiative (NAI), the leading self-regulatory association dedicated to responsible data collection and its use for digital advertising. The NAI is an organization for third-party online advertising technology companies, including networks, exchanges, DMPs, SSPs, RTB platforms, analytics companies, and service providers.
The NAI’s role is to help promote consumer privacy and trust by creating and enforcing high standards for responsible data collection and use practices online and in mobile environments among its members. You can find a description of policies listed here: NAI Self-Regulatory Codes of Conduct. By abiding by the NAI’s Codes of Conduct, we demonstrate our commitment to consumer privacy and digital advertising best practices.
Visit the NAI opt-out tool, which allows you to opt-out of Interest Based Advertising.
Where we collect or receive Personal Information about you directly from you, we will explain the purposes for which we collect and use such Personal Information, the types of third parties to which we disclose that information, and the choices and means, if any, we offer you for limiting the use and disclosure of Personal Information about you. This explanation will be provided as soon as practicable and, in any event, before we disclose your Personal Information or use such information for a purpose materially different than that for which it was originally collected or processed.
Where we collect or receive Personal Information about you from Customers, which occurs when our subsidiaries are acting as providers of Services to Customers, we do so as a processor (under GDPR) and/or service provider (under CCPA) of Personal Information on behalf of Customers. We will use such information in accordance with the notices provided by Customers and in accordance with the choices you made with respect to such Personal Information, as communicated to us by Customers.
Collection of Personal Information
Information You Voluntarily Provide Us: When you visit our Website or use the Services, we may collect certain types of information that you submit voluntarily. You will need a username and password from us in order to access protected areas of the Website and the Services. We require some limited information to create an account for you, including your user name, password, email address, mailing address and telephone number. In addition, if you are accessing the Website or the Services on behalf of a Customer, you may provide certain information, for example, the Customer’s name, email address, and password. We also collect certain information from you in order to process transactions on the Services, including credit card numbers and associated billing information. We refer to this information as “Billing Information.” Our legal basis for processing this information is your consent.
- Name, Email Addresses, etc. This information may include name, email address, mailing address and telephone number, as well as demographic and voting data to supplement this information. Our legal basis for processing this information is our legitimate interests, namely monitoring and improving the Services, and the legitimate interests of Customers (“data controller” under GDPR and/or “business” under CCPA).
- Sensitive Data and Sensitive Health Data. Certain information that we collect from third parties may also be considered “Sensitive Data.” Sensitive Data may include social security numbers and bank or credit card account information. Sensitive Data may also include information about your race or ethnicity, or personal health and medical information such as information on personal health conditions and treatment (“protected health information” or “PHI”), prescriptions for medications and laboratory results (“Sensitive Health Data”).
- Please click on the following link for examples of the categories of Sensitive and Non-Sensitive Health Data that we collect from third parties, including from Customers and other trusted sources, and that we use for the Services, both “standard” or “off-the-shelf” audience segments and custom audience segments used for the same purposes: www.winwithoptimal.com/industries/healthcare
- Please also be aware that, unless appropriately de-identified, PHI collected by us may be protected under the Health Insurance Portability and Accountability Act of 1996, as amended.
- Device-Identified Information (“DII”). DII is technical information that is linked to the browser, device or group of devices you use, but is not intended to be used to directly identify a particular individual. Examples of DII include your device’s Internet Protocol (IP) address, browser type, and operating system. Additionally, in the case of mobile devices, we or our service providers may collect your device’s type and unique advertising identifier (such as the Apple IDFA (or UDID in older Apple phone models) or Android Advertising ID / Google AdID), and any other unique identifier that may be assigned to your device, or a non-cookie unique identifier, so long as the identifier is not linked or intended to be linked to Personal Information when ultimately used for interest-based advertising. This information may also include information reflecting your viewing behavior and other interactions with connected televisions (or “smart TVs”) and unique advertising identifiers associated with your smart TV. Nonetheless, please note that in certain contexts and jurisdictions such as under the CCPA and the GDPR, DII that we do not regard as Personal Information, such as IP addresses, may nevertheless be regarded as personal information.
- Geo-location data. This is non-precise information related to your geographical location derived from your device’s IP address (e.g. laptop, desktop or mobile etc.). This information does not reveal your precise geographic coordinates (i.e. GPS latitude and longitude). Examples include your zip code or the approximate geographic area provided by your Internet service provider (ISP) or location positioning information provided by the location services and GPS features of your mobile device or website when location services are enabled on your device. This information helps us and our service providers to serve ads that are relevant to your general location (for example, showing ads in French if you are located in France). We may also infer the geo-location of your device based on data collected through, for example, a WiFi identifier that the device is connected to.
- Offline Data for Audience Matching. As described below in additional detail in “Audience Matching Services (on-boarding),” we may collect customer relationship data (such as email addresses or “hashed” versions of email addresses) from Customers or from other third parties in order to provide audience matching services as part of the Services, sometimes referred to as “on-boarding.”
Use of Information We Collect
We use the information we collect to respond to requests, resolve problems, maintain Customers’ accounts and provide the Services to Customers including to measure or understand the effectiveness of the Services, provide our Website to you, improve our offerings and to create new services, and market our products or services and those of our affiliates, partners and third parties to you.
We may also use the Personal Information that we collect to send you certain Services and administrative notices, which are not subject to opt out.
We use Billing Information that we collect only for purposes of authentication and to process transactions on the Service.
We may also use the information we collect to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.
Interest-Based Advertising. The Services help Customers deliver advertisements to people who are most likely to find them interesting by showing them advertisements that are relevant to their specific interests. This is called “interest-based advertising.” We deliver many of these interest-based ads on websites and mobile applications which rely on advertising revenue to support the content they provide. In doing so, we may utilize the information segments referred to in “Information We Collect from Third Parties” (including Sensitive Health Data), as well as Personal Information and non-Personal Information derived from your browsing habits on the Internet, to target specific ads to you.
The Services use that data to help Customers provide ads and send advertisements to you that aim to be more relevant to you. This allows Customers who use the Services to provide more effective advertising that reaches a more precise pool of prospective buyers.
We may also serve ads to you based on inferences made regarding health conditions that may be of interest to you. When doing so, we may make these inferences using models based on a sample set of other users’ anonymized and aggregated health records, which we then compare with information in its databases to create datasets it can use to make certain predictions or inferences regarding characteristics that may apply to you, including the existence of certain medical conditions.
You can control how you share your Personal Information with us, including electing to opt-out of interest-based advertising altogether. Please visit our page to opt-out.
Aggregated / Anonymous information. We may use information that is in aggregate / anonymous form to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. This includes reporting information to Customers of the Services in order to allow them to effectively evaluate the value of the Services to their needs. These uses also include marketing and improving the Services. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Services and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Services. Information that is in “aggregate / anonymous” form refers to non-identified information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person), and does not include information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person directly or indirectly.
Audience Matching Services (or “on-boarding”). We use Personal Information we collect in order to provide audience matching services as part of our Services, sometimes referred to as “on-boarding.” Audience matching is a particular type of interest-based advertising where we share de-identified offline information (e.g. “hashed” versions of email addresses) with an ad partner or incorporate a pixel or mobile ad identifier from an advertising partner into the Services, and the ad partner “matches” common factors between our information and the ad partner’s information or other datasets to cookies, mobile ad identifiers or other online identifiers. We use this information only as a processor for the purpose of providing Services to that particular Customer. We do not share this information with other Customers.
Cross-device Linking. We use Personal Information we collect in order to identify different devices and browsers that are likely to be associated with you so that ads can be targeted, limited and/or and sequenced across those devices, and so that the Services can be better measured and analyzed. For example, cross-device linking helps us not show you ads for the same topic or product or service that you were looking at on your phone but already acted upon via your tablet. Cross-device linking also improves our ability to match devices in order to receive and honor your opt-out choices across all devices. You may opt-out of cross-device interest-based targeting by employing the respective opt-out techniques we describe in “Your Choices and Opting-Out of Interest-Based Advertising and Analytics.”
(Disclosing Personal Information to Third Parties)
We will offer you the opportunity to choose whether your Personal Information is to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by you.
Aggregated / Anonymous information. In addition, we may use information that is in aggregate / anonymous form to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. This includes reporting information to Customers of the Services in order to give Customers information in order to evaluate the value of the Services to their needs, as well as to market and improve the Service. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Services and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Services.
Opting Out of Marketing Communications
Your Choices and Opting-Out of Interest-Based Advertising and Analytics
You can control how you share your Personal Information with us, including electing to opt-out of interest-based advertising. Please visit www.winwithoptimal.com/opt-out to opt-out. An opt-out allows you to direct us not to engage in a particular type of Personal Information collection or use. There are many different ways that we collect Personal Information, different purposes for that collection, and different industry-specific tools for opting-out. We describe below your different options for controlling how we use your Personal Information:
- Web browser: You can opt-out of receiving interest-based ads served by or on behalf of the Services by clicking on the blue icon that typically appears in the corner of digital ads and following the instructions provided or by visiting our opt-out page: www.winwithoptimal.com/opt-out. Please note that this opt-out function is browser-specific and relies on an opt-out cookie. This means that if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again.
- Cross Device Opt-Out: As described above in “Use of Information We Collect,” we may link multiple browsers or devices to the cookie ID, hashed email address or other unique identifiers associated with you. If you opt-out on a browser or device and the Services have additional devices or browsers linked to you, we will extend your opt-out decision to any other linked browsers and devices. Since we only link users across browsers and devices in certain conditions, there may be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
- Mobile Device Opt-Out: To opt-out of receiving interest-based ads that are based on your behavior across different mobile applications, see instructions for iOS and Android devices:
- iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting; and
- For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Select Ads > Enable “Opt-out of interest-based advertising.”
- Smart TV Opt-Out: To opt-out of receiving interest-based ads that are based on your viewing behavior and other interactions with connected televisions (or “smart TVs”), see instructions in your television’s privacy controls, and can also refer to the NAI’s connected TV opt-out instructions.
- Industry Opt-Out Tools and Self-Regulation:
- We recommend using NAI’s opt-out tool which will allow you to opt-out of seeing interest-based ads from us and other advertisers. In addition, NAI’s opt-out tool allows you to separately opt-out of “audience matched” advertising through NAI’s opt-out tool. You can also use the email opt-out tool provided by LiveRamp to opt-out your email address from LiveRamp’s database. Note that this “audience matched” information is derived from an email address or information that can be tied to an email address, it is possible to opt-out with an email address. However, please be aware that if you opt-out this way, you will need to submit all email addresses that you use for the opt-out to be fully effective.
- We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt-out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners, via the DAA website.
- Additional Rights of Individuals Residing in the EEA, Switzerland and California: If you are a resident of the EEA or California, you also have additional data protection rights specific to residents of the EEA, Switzerland or California. These are described in “Accessing and Controlling Your Information” (for EEA and Switzerland residents) and “Supplemental Privacy Notice for California Residents” (for California residents).
Accountability for onward transfer
We use model contractual clauses and other mechanisms approved by the European Union and Switzerland, respectively, for transfers of Personal Information from the European Economic Area (“EEA”) and Switzerland.
Data integrity and purpose limitation
We endeavor to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. We will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by us for as long as we retain possession of such information. Our personnel have a responsibility to assist us in maintaining accurate, complete and current Personal Information. When providing Services, we endeavor only to process Personal Information that is relevant to the Services, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified.
Accessing and controlling your information
EU data protection laws make a distinction between organizations that process Personal Information for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant controller, since the controller has primary responsibility for your Personal Information.
For Audience Members: When providing Services, we have no direct relationship with Audience Members, and any such individuals who seek access, or who seek to correct, amend, delete, or restrict processing of their Personal Information should direct their inquiries to the relevant Customer which has transferred such Personal Information to us for processing. We will assist Customers in fulfilling their obligations under applicable law to respond to such requests by individuals regarding their Personal Information.
Please note that while any deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
In general, we retain information we collect from you based on the specific types of information described below, at the end of which periods we will either delete or anonymize the information. Please note, however: Notwithstanding the below-described data retention periods, in some cases we store your information for longer periods in backup archives and/or as necessary to comply with our legal obligations and accounting requirements (but only so long as to satisfy such obligations and requirements), provided that in all such cases we will securely store the information and isolate it from any further processing until deletion is possible. Specifically:
- Customer-Provided Information: For any information that a Customer instructs us to collect or otherwise provides to us in order for us to perform the Services, we retain this information until the Customer asks us to delete this data or for one (1) year following completion of the Services, whichever is earlier.
- Mobile Identifiers and Cookie Identifiers: Cookies we set expire (and are then deleted) 13 months from the time your device last accessed the relevant website page where the cookie was set. The expiration period for mobile identifiers is controlled by you on your own device.
- Other Information Associated with Mobile and Cookie Identifiers Related to Browsing History: We delete information associated with mobile and cookie identifiers after 12 months.
- Information Associated with the Display of Ads: Data logged for the display of an advertisement (including cookie identifiers, the advertisement displayed to you and data indicating whether you clicked on a particular advertisement) are deleted after 12 months.
Recourse, enforcement and liability
We encourage you to raise questions about our processing or disclosure of your Personal Information by contacting us, as set forth in the “Contact Us” section below.
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Taking into account the risks involved in the processing and the nature of the information we process, we maintain appropriate administrative, technical and physical safeguards to protect information in our possession against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. This includes, for example, firewalls, password protection, encryption and other access and authentication controls.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your information has been compromised, please contact us as set forth in the “Contact Us” section below.
The Services have security incident response programs designed to promptly respond to and escalate any potential privacy or security incident. If we learn of a security incident, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
Children’s online privacy protection act compliance
In compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our Website and the Services are not directed to people under 13 years of age.
If, for whatever reason, you have any questions, comments, complaints or compliments about the privacy of the Services or this Website, please contact our email support. Please also use these email addresses if you believe you have received a marketing communication from us or one of our Services that you feel makes use of your information in an unauthorized or unwelcome way. Please contact us using the information below:
55 Peters Canyon Road
Irvine, CA 92606
Supplemental Privacy Notice for California Residents
Sensitive Data and Sensitive Health Data
Certain information that we collect from third parties may also be considered “Sensitive Data.” Sensitive Data may include social security numbers and bank or credit card account information. Sensitive Data may also include information about your race or ethnicity, or personal health and medical information such as information on personal health conditions and treatment (“protected health information” or “PHI”), prescriptions for medications and laboratory results (“Sensitive Health Data”).
Please click on the following link for examples of the categories of Sensitive Health Data that we collect from third parties, including from our Customers and other trusted sources, and that we use for the Services, both “standard” or “off-the-shelf” audience segments and custom audience segments used for the same purposes: www.winwithoptimal.com/industries/healthcare
Please be aware that, unless appropriately de-identified, PHI collected by us may be protected under the Health Insurance Portability and Accountability Act of 1996, as amended.
Information We Collect
Our Website and the Services collect Personal Information. In particular, our Website and the Services have collected the following categories of Personal Information from consumers within the last twelve (12) months:
|Category||Examples||Collected on the Website?||Collected by the Service?|
|A. Identifiers||A real name, Internet Protocol address, email address, or other similar identifiers.||YES||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.||NO||NO|
|C: Protected classification characteristics under California or federal law.||Examples: 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||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO||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||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||YES|
|G. Geolocation data.||Physical location or movements.||YES||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO||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||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||YES|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, including:
- 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.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from Customers or their agents. For example, from documents that our clients provide to us related to the Services for which they engage us.
- Indirectly from Customers or their agents through their use of the Services. For example, data about Audience Members we collect from our Customers through their use of the Services.
- Directly and indirectly from activity on our Website and the Services. For example, from submissions through our Website’s portals or website usage details collected automatically.
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 for which the information is provided.
- To provide you with information, products or services that you request from us.
- 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.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our Website and the Services and present their contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect 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 when collecting your Personal Information or as otherwise set forth in the CCPA.
- 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.
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
We 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.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
- Category A – Identifiers
- Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Category F – Internet or other similar network activity.
- Category K – Inferences drawn from other Personal Information.
We do not sell, rent or otherwise disclose Personal Information collected by our Website and/or the Services to third parties in the ordinary course of business. However, certain third party agents and other third parties performing services for us may have access to Personal Information in order to do their jobs.
We disclose Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
Your Rights and Choices
The 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 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 verify your 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 sell or disclose your Personal Information for a business purpose, we will provide two separate lists disclosing:
- Sales, identifying the Personal Information categories that each category of recipient purchased; and
- 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 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 free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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.
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 by filling out this form.
Exercising Access, Data Portability, and Deletion Rights
Only you or a person registered with the California Secretary of State that 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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. In order for us to be able to verify your request, the request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- 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. Making a verifiable consumer request does not require you to create an account with us. 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 Format
We will endeavor to respond to a verifiable consumer request within 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 usable 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.
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.
55 Peters Canyon Road
Irvine, CA 92606