Duluth Trading Co.
PRIVACY POLICY

Last Modified: March 2020

INTRODUCTION

At Duluth Holdings Inc. d/b/a Duluth Trading Co. (“DTC,” “we,” “our,” or “us”) we take a “No Bull” approach to your privacy. We believe that managing your privacy is important, and we want you to be informed. Please take a few minutes to review this privacy policy (this “Policy”) to understand how we use, disclose, and otherwise interact with information we collect from you. We respect your privacy and are committed to managing it through our compliance with this Policy.

The purpose of this Policy is to describe the types of information we may collect from you or that you may provide to us when you visit https://duluthtrading.com/ or any website that links to, references, or displays this Policy, or information otherwise provided to us online or offline as described in this Policy (the “Site”). By accessing, using, or submitting information to or through the Site or to us, you agree to this Privacy Policy. If you do not agree, you should not use the Site or submit information to us. This Policy may change from time to time and your continued use of the Site or submission of information to us after any such change is deemed to be your acceptance of those changes. We encourage you to visit this Site periodically to ensure you keep up to date with our privacy practices.

DTC’S DATA COLLECTION

Information You Voluntarily Provide to Us Online. As part of the fun and interactive experience of using our Site, there will be places where you can enter personal information, such as your name, postal address, billing or shipping address, email address, telephone number, date of birth, gender, location, preferences, payment method, or any other identifier by which you may be identified online or offline. For example, you may be asked to provide personal information when you:

  • Create an account;
  • Purchase a product;
  • Sign up for email or news updates;
  • Fill out online surveys or respond to marketing initiatives, contests, events, or promotions;
  • Provide information in fillable forms or fields;
  • Request information about us or the Site, whether via email or other electronic means;
  • Submit product reviews;
  • Create a wish list; or
  • Request a catalog.

If you apply for a job with us, we may also collect personal and other information such as work experience, education, skills, behaviors, motivations, licenses and certifications, and any other information you provide to us through our employment application.

In addition, if you make a debit or credit payment online or offline, our third-party payment service providers (our “Payment Providers”), including, for example, Chase Paymentech, may take your payment information on our behalf and process it. Our Payment Providers may provide information back to us to confirm your purchase, to allow us to fulfill your order, and for other purposes outlined in this Policy. We encourage you to visit the privacy policies of our Payment Providers to understand their privacy practices, which may differ from ours.

Information You Provide Through Other Means. We like to know who our customers are and how they are using our products, so we can market the right products to the right people. As a result, we may also collect, obtain, or supplement information about you (including personal information) from sources other than you, including publicly available sources like social networking sites, forums and blogs, other users of our products and services, our affiliates, and our business and marketing partners and service providers.

Information When You Shop at Our Stores. We may also collect information from you when you shop at our stores, including much of the same information we would collect if you shopped online (i.e., order information, payment information, etc.). If you pay by personal check, we may also collect your driver’s license number for verification and fraud prevention purposes. In addition, to keep you and our employees safe, we use CCTV cameras in our retail stores and other company locations. These cameras collect and store images, video and other associated information, to help us with fraud prevention, security, and risk management. Our CCTV cameras are provided by a trusted third-party vendor, so video and images, as well as other associated information, is shared with both DTC and that trusted vendor.

Information We Collect Automatically When You Use the Site. When you use or interact with our Site, we may use a variety of technologies that collect information automatically, including cookies, web beacons, flash cookies, and logging. Those technologies may collect, among other things, your IP address, location, device type, date and time of visit, operating system, and browser type, as well as what webpage you visit immediately prior to or after visiting the Site and your activities on the Site. If you are interacting with the Site on a mobile device, additional information may be collected, including your mobile device’s unique device ID, GPS signal, and information about how you use the Site. The information may also be collected, received by, or shared with third-party vendors who assist us with these activities. We use this information to, for example, help make the Site more useful and appealing to you and to better understand our users.

  • Cookies. We think it is important that you understand cookies. A cookie is a small text file that is sent to your browser when you access a website, including the Site. We and the third parties described below may use session cookies. A session cookie is available only during the course of the browser session; the information is not sent to or stored on a computer’s hard drive. Closing the browser or logging off will invalidate the session cookie. We and the third parties described below may also use machine cookies, which do remain on a computer hard drive and gather information, sometimes over time and across sites. You can find more information about your choices regarding cookies under the heading “YOUR CHOICES ABOUT OUR COLLECTION, USE, AND DISCLOSURE.”
  • Web Beacons. “Web beacons” or “tracking pixels” are electronic images, tags, or scripts that allow a website to access cookies and, among other things, help track general usage patterns of visitors to a website. Web beacons can recognize certain types of information, such as cookies, time and date of a page view, and a description of the page where the web beacon is placed. We and the third parties described below may use web beacons to compile information regarding your use of the Site.
  • Location Information: We may collect information about your location (via GPS or other technologies), including when your mobile device is set to provide such information. For example, your device’s GPS signal allows us to show you the nearest DTC store.

THIRD-PARTY DATA COLLECTION

Like the internet itself, online marketing is a networked enterprise. Thus, we want to make it clear that we do contract with third parties, including Google, Facebook, and Salesforce, to assist us with marketing (including distributing e-mails on our behalf), analytics, payment, social, and other business purposes. These third parties may use third-party cookies, or other methods or technologies like website scripting, pixels, or action tags to collect information about you when you visit the Site or interact with emails. We use the information collected by third parties for a variety of purposes, including to learn which online advertisements attracted you; to improve our content, products, and services; to inform groups of users about relevant products and services, and to help us analyze the Site and the effectiveness of our marketing. The use of your information by such third parties is governed by each third party’s privacy policy. There is additional information about third-party data collection and targeted advertising in the section titled “Online Behavioral (Targeted) Advertising,” below.

Information from Emails. As noted above, we collect information on our email campaigns from our third-party service providers, including whether you have read an email sent by us or on our behalf, forwarded an email, and when and how many times you have opened an email. We may use this information to improve our marketing, to understand our audience, and to improve the Site and our products and services. If you wish to opt out of receiving emails from us, please see the “Opt-out” section, below.

Information from Chat Function. We use a third party to operate our chat function on the Site and as a result, information is shared between Avtex Solutions, LLC and DTC.

Information from Customer Service Calls. You may also provide us order information, payment information, and other similar information while speaking with our customer service representatives. We also record our calls with you for quality and training purposes. This ensures we are providing you with the outstanding service we are known for here at Duluth. As with our Chat Function, customer service information, including call recordings, is shared between Avtex Solutions, LLC and DTC.

Information from Third-Party Analytics. We also use third party analytics on the Site, such as those provided by Google Analytics, Adobe, and ContentSquare to, for example, enable us to continually improve upon the content we offer to you, for systems administration purposes, to evaluate your use of the Site, to compile reports on activity, to analyze performance metrics, and to collect and evaluate other information related to the Site. Some of our analytics can be used to track users over time, for geo-location purposes, and across third-party websites.

Information from Social Media Platforms. We contract with or otherwise use third parties to gather and analyze data from social media platforms, including, for example, Facebook®, Instagram®, Pinterest®, YouTube ®, and Twitter®. We use these third parties to help us understand your interaction between social media and our Site. One of the ways we obtain information is through web beacons or pixels.

Performance of the Site. We also use third-party services to track information about the performance of the Site. The third-party services collect aggregated data from visits to the Site to help troubleshoot any problems with performance, such as errors in code or page load times. We use this information to optimize your experience with the Site.

Online Behavioral (Targeted) Advertising. Online behavioral advertising is used to deliver advertisements that are catered to your interests (or “targeted” to you) based on your browsing history. We may engage third parties to display ads on our behalf on the Internet, including, for example, Google, and those third parties may use information about you to provide you with our ads. We may also engage our service providers to track and report performance of advertising and marketing campaigns to and from us.

DATA INTEGRATION

While the information that we and our third-party service providers collect automatically does not normally contain personal information, we may maintain it or associate it with personal information we collect from you or that we receive from third parties. This helps us to, among other things: (a) estimate our audience size and usage patterns; (b) store information about your preferences, allowing us to customize our Site according to your individual interests; (c) speed up your searches; (d) recognize you when you return to the Site; (e) improve the Site and any products and services we offer through the Site; and (f) improve our marketing efforts.

HOW WE USE INFORMATION

The information we gather works every bit as hard as a pair of Fire Hose Work Pants. It allows us to serve you better, in ways such as those described above and below.

Use of Information Collected Automatically. We use information we collect automatically, which typically does not identify you, for various internal business purposes, including those described in this Policy. However, we may use information we collect automatically from your use of the Site that is not personal information and other information we collect or obtain that is otherwise de-identified, aggregated, or anonymous, for any purpose, including sharing it with third parties to improve the content and functionality of the Site, to better understand our customers and markets, and to improve our products and services.

Uses of Personal Information. We may use your personal information:

  • To respond to any request you have made, including for information, products, and/or services;
  • For our marketing efforts, including to keep you informed about existing and new products and services;
  • To confirm and complete transactions requested by you;
  • To provide you with customer support;
  • To resolve problems and disputes;
  • To improve the Site, and our products and services;
  • To protect the security and integrity of the Site and our physical locations;
  • To monitor compliance with and enforce this Policy and our Terms of Use and any other applicable agreements and policies;
  • If necessary, to notify you about changes to the Site and any products or services we offer or provide;
  • In any other way we may describe when you provide the information;
  • To fulfill any other purposes for which you provide it, or offer your consent; and
  • As generally permitted under applicable law.

DISCLOSURE OF YOUR INFORMATION

We may share your information, including your personal information:

  • With our subsidiaries and affiliates;
  • With our subcontractors, service providers, and other third parties we use to support our business and the Site, including our purchasing processors, maintenance providers, and marketing partners;
  • With carefully screened companies and organizations (including marketing cooperatives) whose products and activities might be of interest to you;
  • To a buyer or other successor in the event of or during a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of DTC’s assets or equity, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by DTC is among the assets transferred;
  • For any other purposes disclosed by us when you provide the information; or
  • With your consent.

We may also share your personal information to comply with any court order or legal obligation, including responding to any lawful government or regulatory request, or if we believe disclosure is necessary to enforce or protect our rights, property, or safety, or that of our users or third parties.

YOUR CHOICES ABOUT OUR COLLECTION, USE, AND DISCLOSURE

There are steps you can take to manage your privacy. You have choices regarding the information you provide to us and that we collect, including:

Cookies. If you do not wish us to collect cookies, you may set your browser to refuse some cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of the Site may then be inaccessible or may not function properly. Information on deleting or controlling cookies can be found at www.aboutcookies.com

Analytics. Some of the analytics providers we use allow you to opt out:

Location Information. If you do not wish to share GPS location information with DTC, you may be able to turn off location sharing in your mobile device settings, or otherwise decline the option to allow your web browser to use your location for certain functionality like finding the nearest DTC store.

E-mail Opt-Out. You may opt-out of receiving future communications from us by clicking on the “unsubscribe” link at the bottom of any email from us (or sent on our behalf).

Accessing and Correcting Personal Information. If you have an account on the Site and wish to review and/or update your personal information, please log into the Site and visit your account profile page to make any desired changes.

Google Ads and Online Behavioral Advertising. We use a number of Google services to assist us with advertising. To learn more about Google’s practices with regard to data collection, and to manage Google Ads, click here: https://policies.google.com/technologies/ads. You can also opt out of online behavioral advertising from certain ads on third-party websites by visiting https://youradchoices.com. Furthermore, certain of our ads on third-party websites may display an advertising options icon that you can click to learn about your choices. This icon will only appear on certain platforms. Keep in mind that these opt-outs work using cookies, so if you delete your cookies, then you will need to opt out again. Also, as you use different devices or browsers, you will need to opt out on each browser and device individually. You can also help limit the amount of online and mobile advertising that you can receive by opting out of advertising from Network Advertising Initiative member companies, or the Digital Advertising Alliance at:

You can also opt out of some of our advertising networks by visiting their opt-out pages:

Personal Information Opt-Out. If you prefer not to have your personal information shared with other companies or organizations, just let us know by sending us an email at customerservice@duluthtrading.com, or contact us by mail at 201 East Front Street, Mount Horeb, WI 53572, or call 1-877-382-2345.

EXTERNAL WEBSITES

Third-Party Links. Our Site may contain links to websites operated and maintained by third parties. We have no control over and are not responsible for the privacy policies or content on those websites, and any links to third-party websites do not imply an affiliation between DTC and the website owner, or any endorsement, approval, or verification of any content contained on those websites. Privacy policies on third-party websites and mobile applications may be different from our Policy. You access such links at your own risk. You should always read the privacy policy of a website or mobile application before disclosing any of your information.

Social Media. If you use any functionality of the Site allowing you to interact with social media platforms (e.g., Facebook®, Instagram®, Twitter®, Pinterest®, and YouTube®) or otherwise interact with us on social media, generally, then please be aware that: (a) we may display your email address and/or social media handle (e.g., username) to other users; (b) we may use information you provide about yourself or other users to facilitate communications; and (c) we may collect information about interactions with us and receive information from social media platforms about you, including as described in the section titled “THIRD-PARTY DATA COLLECTION.” Please note that any content you post to social media platforms is subject to the data handling practices of each social media platform, as described in their respective terms of use and privacy policy, which we encourage you to read before posting content.

DO NOT TRACK

The Site does not respond to “do not track” requests. All traffic is treated as equal and processed the same. If you desire to have your browsing be private, we suggest that you use your web browser’s private or incognito function, or a similar option.

NOTICE TO CALIFORNIA RESIDENTS

California Civil Code Section § 1798.83 (the “Shine the Light” law) and the California Consumer Privacy Act of 2018 (“CCPA”) afford additional rights to the residents of the State of California. If you are a California Resident, please scroll down to Appendix A (Your California Privacy Rights) to learn more.

CHILDREN UNDER THE AGE OF 13

Although we appreciate the Duluth Trading customers of the future, this Site is not intended for anyone under the age of 13, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under the age of 13 without parental consent, we will delete that information and otherwise comply with the requirements of any applicable law including the Children’s Online Privacy Protection Act. If you believe that we might have any information from or about a child under the age of 13, please contact us at customerservice@duluthtrading.com.

SECURITY

We strive to use reasonable means to secure your personal information while you are using the Site. However, please keep in mind that the transmission of information over the Internet and on mobile platforms is not always secure, which means we cannot and do not guarantee the security or confidentiality of any personal information you provide to us. Given this reality, your use of the Site, and your decision to provide personal information to us, is at your own risk.

CHANGES TO THIS POLICY

Innovation is part of our company mission. As we constantly evolve and improve how we do business online, from time to time this Policy may change. The effective date of this Policy is the date next to the words “Last Modified” at the top of this Policy. We may update this Policy at any time, at our sole discretion, if we make material changes to the way we handle your personal information, or if material changes are necessary due to law. Our most current Policy will always be posted at https://www.duluthtrading.com, and at any other link you clicked on to reach this Policy. Any changes we make to this Policy will be effective immediately upon the posting of the updated Policy. As such, we encourage you to review this Policy regularly. Your continued use of the Site after we make changes will constitute your acceptance of any such changes.

CONTACT US

Have questions or comments? We want to hear from you. If you have feedback about this Policy or our Terms of Use, wish to remove or change your contact information in our database, or do not want to receive future mailings or other communications, as well as other inquiries, just contact us at any time using one of the options below:

APPENDIX A

(Privacy Information for California Residents)

This Appendix supplements the information contained in the Duluth Holdings Inc. d/b/a Duluth Trading Co. (“Duluth,” “DTC,” “we,” “our,” or “us”) Privacy Policy and applies solely to residents of the State of California ("consumers" or "you").

We collect personal information, as that term is defined under the California Consumer Privacy Act (“CCPA”), which is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

Personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from CCPA’s scope, like health or medical information subject to HIPAA, and financial information subject to GLBA or FCRA.

Disclosures

In the past twelve (12) months, our personal information practices were as follows:

Category of Personal Information - Identifiers
This may include a real name, alias, address, email address, phone number, driver’s license number (if payment by personal check), online identifier, IP address, account username and password, job title, or other similar identifiers.
Categories of Sources from Which the Personal Information Is Collected
You, your agents, our other customers; through our third-party service providers, ad networks, data analytics providers, marketing partners and cooperatives, data security services, and social media networks.
How We Use the Personal Information (Business Purposes)
To provide you with information, products, or services; to advertise or market to you; to secure our site from malicious traffic; for anti-fraud measures; to evaluate store locations; and for our own legal obligations and business needs.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; service providers (e.g., shipping partners, fraud analytics partners); ad networks; data analytics providers; prospective purchasers of our business; marketing partners and cooperatives; outside auditors and lawyers; and social networks.
Category of Personal Information - Internet and network information
This may include information on your interaction with a website, application, or advertisement, such as browsing history and how you use your account.
Categories of Sources from Which the Personal Information Is Collected
You, your agents, through our third-party service providers, ad networks, data analytics providers, marketing partners and cooperatives, and social media networks.
How We Use the Personal Information (Business Purposes)
To provide you with information, products, or services; to advertise or market to you; to improve our services and products; and to secure our website and prevent fraud.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; service providers (e.g., fraud analytics partners); marketing partners and cooperatives; ad networks; data analytics providers; and social networks.
Category of Personal Information - Payment and credit information
This may include your credit or debit card information, banking information, information about your payment transaction, or other financial information you provide us.
Categories of Sources from Which the Personal Information Is Collected
You, your agents, and through our third-party service providers.
How We Use the Personal Information (Business Purposes)
To provide you with information, products, or services; to secure our site from malicious traffic; for anti-fraud measures; and for our own legal obligations and business needs.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; service providers (e.g., payment processors and fraud analytics partners); and outside auditors and lawyers.
Category of Personal Information - Device information
This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information.
Categories of Sources from Which the Personal Information Is Collected
You, your agents, through our third-party service providers, marketing partners and cooperatives, ad networks, data analytics providers, and social media networks.
How We Use the Personal Information (Business Purposes)
To provide you with information, products, or services; to advertise or market to you; to improve our services and products; to show you our store locations; and to secure our websites.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; service providers; marketing partners and cooperatives; ad networks; data analytics providers; and social networks.
Category of Personal Information - Protected classification characteristics under California or federal law
This may include your age and sex.
Categories of Sources from Which the Personal Information Is Collected
You, your agents, through our service providers, marketing partners and cooperatives, ad networks, and social media networks.
How We Use the Personal Information (Business Purposes)
To provide you with information, products or services; to advertise or market to you; and to improve our services or products.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; and service providers.
Category of Personal Information - Commercial Information
This may include information about what you order, shipping, returns, product complaints, product reviews, or warranties.
Categories of Sources from Which the Personal Information Is Collected
You, your agents, through our third-party service providers, and marketing partners and cooperatives.
How We Use the Personal Information (Business Purposes)
To provide you with information, products, or services; to advertise or market to you; for our own legal obligations and business needs; and to improve our services and products.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; service providers (e.g., shipping partners,); marketing partners and cooperatives; ad networks; data analytics providers; prospective purchasers of our business; outside auditors, insurers, and lawyers; and social networks.
Category of Personal Information - Geolocation Data
This includes information about your physical location or movements.
Categories of Sources from Which the Personal Information Is Collected
You and your agents.
How We Use the Personal Information (Business Purposes)
To provide you with information, products, or services; show you our store locations; and advertise or market to you.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; marketing partners; ad networks; data analytics providers; and service providers.
Category of Personal Information - Audio, Electronic, or Visual Information (Sensory Data)
This includes the collection of CCTV images in our stores and audio recordings of customer service calls.
Categories of Sources from Which the Personal Information Is Collected
You and through our service providers.
How We Use the Personal Information (Business Purposes)
To improve our services and products; for fraud prevention, security, and risk management.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; service providers (e.g., Avtex Solutions); and outside auditors and lawyers.
Category of Personal Information - Inferences we draw about you
This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products you may be interested in.
Categories of Sources from Which the Personal Information Is Collected
You, your agents, through our third- party service providers, marketing partners and cooperatives, ad networks, data analytics providers, and social media networks.
How We Use the Personal Information (Business Purposes)
To provide you with information, products, or services; to advertise or market to you; to improve our services and products and their availability; and for our own business needs.
Categories of Service Providers and Third Parties with Whom Personal Information Is Shared
Entities that we are legally required to share with pursuant to law; service providers; marketing partners and cooperatives; ad networks; data analytics providers; and social networks.

Sales of Personal Information

CCPA defines a “sale” of personal information broadly to include more than exchanges for monetary purposes. A sale can include personal information shared with a third party for “valuable consideration,” or information shared with a third party (even if they are performing services on our behalf) if they are permitted to use the information for their own purposes.

DTC does not sell your personal information for monetary payment, whatsoever. To ensure we can share our products with you and tailor our advertisements, we do allow some of our advertising partners to use cookies, pixels, and other technologies to collect personal information on our website and we also share personal information with them directly, both of which may constitute a “sale” of personal information under CCPA. We also utilize marketing partners and cooperatives, which allow us to send and receive personal information to enhance our marketing efforts and permit you to receive ads for products and services that might be of interest to you, and this too may constitute a “sale” of personal information under CCPA.

Given the foregoing, we have disclosed the following information for valuable consideration (“sold”) during the past twelve (12) months: Identifiers, Internet and Network Information, Device Information, Commercial Information, and Inferences.

DTC does not knowingly sell the personal information of minors under sixteen (16) years of age.

Personal Information Sales Opt-Out

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt out of personal information sales may opt in to future sales at any time.

To exercise the right to opt out, you (or your authorized representative) may submit a request via our webform.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us at customerservice@duluthtrading.com.

You do not need to create an account with us to exercise your opt-out rights. We will use the personal information provided in an opt-out request only to review and comply with the request.

California Residents’ Rights and Choices

Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their personal information, described below. Below are your CCPA rights and how to exercise those rights.

1. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources of the personal information we collected about you.
  • Our business or commercial purpose for collecting 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.

2. Deletion Request Rights

You have the right to request that we delete some or all of the personal information that we have collected from you and retained, subject to a number of exceptions. We (and our service providers) are not required to delete personal information where it is, for example: (a) necessary to complete a transaction with you or for warranty or product recalls; (b) used for security purposes, to prevent fraud, to fix errors, or to comply with law; (c) reasonable for us to use for internal purposes given our relationship with you; or (d) compatible with the context in which you provided the information. The list of exceptions above is not exhaustive and we may also deny a deletion request as otherwise permitted by law.

3. Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by either:

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. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual.

You may make a verifiable consumer request for access or data portability only twice within a 12-month period. The verifiable consumer 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; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may not be able to fulfill 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. To verify your identity, we may request certain pieces of personal information about you, and we reserve the right to take additional steps as necessary to verify your identity if we have reason to believe a request is fraudulent.

We will use the personal information provided in a verifiable consumer request only to verify the requestor's identity or authority to make the request.

4. Response Timing and Format

We 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. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will cover only the 12-month period preceding the date we receive 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 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.

5. Non-Discrimination

You have the right to not be discriminated against 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; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the information provided in the CONTACT US section of our Privacy Policy.