LAST UPDATED: December 30, 2019


This Privacy Policy document provides Attendease’s Privacy Policy for worldwide users of the Attendease software platform, as well as special provisions applicable to European Union and California users.


  • All Users: This Privacy Policy applies between you and Attendease Software Corp.
  • Users Completing a US Transaction: If you are a user completing a US Transaction (as defined in the Attendease Terms of Use, found at, then this Privacy Policy also applies between you and Attendease Registrations USA, LLC to the extent of the US Transaction.
  • European Union Users: If you are a European Union resident, then in addition to the common provisions 1-10 of this Privacy Policy, then the additional provisions EU1.1-EU14.4 also known as the Attendease GDPR Privacy Notice also apply to you. These additional provisions can be found within this document at
  • California Users: If you are a California resident, then in addition to the common provisions 1-10 of this Privacy Policy, then the additional provisions CA1.1-CA7.1 also known as the Attendease CCPA Privacy Notice also apply to you. These additional provisions can be found within this document at


This Privacy Policy explains how Attendease Software Corporation (for all uses of the Services) and Attendease Registrations USA, LLC for US Transactions (as defined in the Terms of Use, found at (Collectively, “Attendease” or “we” or “us” or “our”) collect your Personal Data (defined below) as part of the provision of the services on the Attendease website, the registration website through Attendease Registrations USA, LLC, and certain of its service providers that post or link directly to this Privacy Policy (collectively, the “Site”) and through other means, how we protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. Attendease may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site.

You do not have to provide us with any Personal Data to visit the public portions of the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site or access Services offered by Attendease.

Please note that by accessing the Site, you are accepting the practices described in this Privacy Policy and consenting to our collection and use of your Personal Data and Other Data (defined below) as set out in this Privacy Policy. If you wish to sign up to use the Services, you will be asked to provide your consent to use your Personal Data to contact you for purposes of applicable personal information privacy statutes, credit bureau reporting rules, anti-spam legislation and consumer protection legislation. If you do not agree to these terms, please do not use this Site. If you do agree to these terms you may withdraw your consent at any time by contacting us through the Contact Us section of the Site, found at

This Privacy Policy shall apply to any Attendease mobile application and other forms of Attendease online activity that reference this Privacy Policy. In such instances, the term “Site” shall include the applicable mobile application or other Attendease online activity whenever that term is used herein. In connection with your use of any Attendease mobile application, your Personal Data (and Other Data, as described below) may also be collected and used by your mobile device manufacturer, the mobile application store from which you obtained the Attendease mobile application, your telecommunication provider, or other third parties involved in the delivery of the application or data to your mobile device, and such practices shall be subject to the privacy policy of the applicable third party.

Attendease reserves the right to transfer Personal Information in the event that we merge with or are acquired by a third party. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.


Attendease is a strong supporter of online privacy and individual rights. We respect your privacy and only collect the minimum data necessary to run the Service effectively. Any data you store on Attendease is yours and we claim no rights to it. Attendease will maintain your privacy and will not offer your information to third parties for the purposes of solicitation. This Privacy Policy summarizes what personal information we collect, and how we use and disclose this information.


When you order services, make payments, register, request feedback, download software, or enter contests from the Attendease websites, Attendease may ask you to provide contact and preference information by submitting an online form. We collect this information for a variety of reasons, including Attendease’s effort to inform you of upgrades, changes in service, special offers, and other products and services that you may be interested in. When you submit personal information to Attendease, you understand and agree that Attendease may access, store, and use your customer profile in any of the countries that Attendease has offices. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

Attendease is not responsible for content or privacy practices of web sites that are not affiliated with or any other site that may or may not be linked to the Attendease pages.

Two types of information may be collected through the Site and our Services: Personal Information and Non-Personal Information. Personally Identifiable Information is Data that is personally identifiable when it can be reasonably linked to a particular person, computer or device. This may include persistent identifiers such as device identifiers, MAC addresses and static IP addresses as well as first name/last name combination, email address, Social Insurance Number (Canada), Social Security Number (USA), Driving License Number as well as Passport Number. Attendease will only collect such Personally Identifiable Information as is reasonably necessary to run the Service effectively.

“Non-Personal Information” is information of an anonymous nature, such as the domain used to access the Site, and the type and version of browser or operating system being used by visitors to the Site. Aggregate information, such as demographic and interest statistics of our users (e.g. average age, geographical allocation, or affinity categories of our users), number of visitors, what pages users access or visit, and average time spent on the Site. Although the use of certain Non-Personal Information collected, used or disclosed through the Internet as described herein is not restricted (and to the extent that such is the case, the obligations under this Privacy Policy do not apply to such information), we provide information in this Privacy Policy about the collection of such information for the sake of transparency with respect to the operation of the Site. Such Non-Personal Information is collected or derived by us in the course of operating this Site. For example, our web servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie when you choose to visit the Site.

The device or media on which your Personally Identifiable data is stored is identified and tracked by us. This is to ensure your Personally Identifiable data is protected and separated from non-Personally Identifiable data. Your security is important to us.


We use Cookies to track content usage and traffic on the Site and to ensure you obtain the information you request. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. The Site uses cookies to help it compile aggregate statistics about usage of this Site, such as how many users visit the Site, how long users spend viewing the Site, and what pages are viewed most often. This information is used to improve the content of the Site. You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Site. We do not link any of the information we use in cookies to any personally identifiable information submitted by you when you are on the Site. Please understand that any data captured from this system is for internal use only and is not shared with anyone else.


We collect Personal Data from you when you voluntarily provide such information to the Services (including event registration pages within the Services), such as when you register for access to the Services (whether as an Organizer or otherwise), register for an event as a Attendee, contact us with inquiries or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address, zip/postal code and other personally identifiable information.

If you register for a paid event, we will use financial information from you only to process the transaction, this information will not be collected or saved.

In addition, Organizers can set up event registration pages to collect virtually any information from Attendees in connection with registration for an Organizer’s event listed on the Services. Attendease does not control an Organizer’s registration process nor the information the Organizer collects. If an Attendee voluntarily provides information to the Organizer in connection with registration for an event or otherwise, it will be available to us and will be held by us in accordance with this Privacy Policy.

When you purchase tickets to, register for or donate to an event on the Services, you consent to our providing your Personal Data to the Organizers of such event. These Organizers are not bound to treat your Personal Data in accordance with this Privacy Policy. You agree that we are not responsible for the actions of these Organizers with respect to your Personal Data. It is important that you review the applicable policies of the Organizers of an event before providing Personal Data or other information in connection with that event.


The security of your Personal Information is important to us. We protect your Personal Information by maintaining physical, organizational and technological safeguards appropriate to the sensitivity of such Personal Information. Personal Information may only be accessed by persons within our organization who require such access to provide you with the services indicated above. Personal Information we collect is maintained with the source of the information at our head office.

We retain Personal Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements. We destroy Personal Information when it is no longer needed.

Attendease takes the security of Personally Identifiable Information very seriously. Attendease employs firewalls, anti-malware, strong encryption, intrusion detection and prevention systems, as well as adhering to strict security and compliance standards.

Only those individuals with a business need to be able to provide you with the Services have access to your Personally Identifiable Data. These roles are secured in order to better protect your data.

Personally Identifiable data will be securely deleted from Attendease systems after the data is no longer deemed necessary for its business purpose or after you have withdrawn your consent to use the data.


You have a right to access your Personal Information and to request a correction to it if you believe it is inaccurate. You also have the right to request your data to be deleted by withdrawing your consent to its use. To request corrections or withdraw your consent please send a request to Attendease through the Contact Us section of the Site, accessible at


The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. Attendease reserves the right, in its sole discretion, to update or modify this Privacy Policy at any time (collectively, the “Modifications”). Modifications to this Privacy Policy will be posted to the Site with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances, Attendease may, but not need, provide you with additional notice of such Modifications, such as via email or with in-Service notifications. Modifications will be effective fifteen (15) days following the “Updated” date or such other date as communicated in any other notice to you.

Please review the Privacy Policy periodically, and especially before you provide personal data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.


If you have any questions regarding this Privacy Policy, or to access your information, please contact visit the Contact Us section of the Site, found at


LAST UPDATED: December 31st, 2019


  • EU1.1 The general data protection regulations (GDPR) apply if the organization who controls the data or organization who processes the data is based in the European Union. For organizations which are not based on the European Union, the regulations apply for any personal data relating to European Union residents.


  • EU2.1. What kind of data is subject to the GDPR? Any data defined as personal data by the European Union is subject to the general data protection regulation (GDPR). Personal data is broadly defined and can include any kind of data that links back to the personal identity of a European Union Citizen or resident. Examples of such data include (but are not limited to) first name, last name, home address, a photo in which the subject can be identified, an email address, login credentials, government identifier, an email address, banking details, credit card information, identifying posts on Internet forums or social media, medical records, information that identifies the subject’s phone or computer such as IP addresses or cookies or other data which links directly back to an individual and allows identification of that individual.
  • EU2.2 These regulations apply to natural persons, they do not apply to legal persons such as corporations. The protection of GDPR data of natural persons applies to both processing by automated means including but not limited to computerized systems as well as to manual processing if the personal data are contained or are intended to be contained in a structured filing system.
  • EU2.3 Paper files are sets of paper files as well as the cover pages which are not structured according to the regulations are not applicable.
  • EU2.4 The GDPR regulations do not apply to the processing of personal data by natural persons who are processing this data from a purely personal or household activity and with no connection to any kind of commercial or professional organization.
  • EU2.5 The GDPR regulations do not apply to personal data of deceased persons.
  • EU3.1. When will we process your GDPR data? GDPR data only may be processed if there is a lawful basis to do so. There are a limited number of lawful bases for processing GDPR data.
  • EU3.1 We will obtain full, unambiguous and clearly affirmative consent from the subject, to agree to have his or her data processed for one or more specific purposes
  • EU3.2 At no time will we obtain your implied consent by automatic means such as silence being taken to indicate consent, or by pre-ticked boxes or deem inactivity to indicate consent, or any other means of consent by default or implication.
  • EU3.3 Where processing of your GDPR data is for multiple purposes we will obtain consent for each of the purposes.
  • EU3.4 We will only process the data if such data is necessary for the performance of a contract to which the subject has agreed or when the subject requests such processing before a contract is entered into.
  • EU3.5 The data we will collect is sufficient relevant and specific only to what is necessary for the specific requirements of the purpose of processing.
  • EU3.6 You have the right to withdraw consent to process or store your data any time.
  • EU3.7 We will only process your data when it is deemed necessary for each specific purpose.
  • EU3.8 We will maintain a record of all processing activities within which the data is processed this includes purpose of processing, category of processing, and how long we will retain your data in personally identifiable form.
  • EU3.9 We will only process your personal data for purposes other than those for which the personal data first collected when that processing is compatible with the purposes for which the personal data were initially collected.
  • EU3.10 Processing includes any set of operations performed on sets of personal data by manual or automated means including collecting recording organizing structure and storing adapting altering retrieving reporting on use of transmission of or any combination of the above.
  • EU4.1 How will we protect your data when processing it? At all times we will process your data in a way that ensures adequate security and confidentiality are respected including prevention of unauthorized access.
  • EU4.2 Your data will either be encrypted using strong encryption algorithms or your data will be pseudonymized, using strong cryptographic hashing algorithms.
  • EU4.3 If your data is encrypted, the encryption keys will be securely stored separately from the pseudonymized data.
  • EU4.4 We will only retain your data in personally identifiable form as long as is needed for business purposes, at the end of which we will pseudonymize or purge your data.
  • EU4.5 We will periodically review your data and the purposes for which it is stored or processed in order to ensure your data are not kept longer than necessary.
  • EU4.6 When storing or processing GDPR data we will periodically undergo a risk review in order to evaluate the risks inherent in the processing of such data so that we may implement sufficient protective measures to mitigate those risks.
  • EU4.7 Measures taken to mitigate risks to GDPR data will ensure an appropriate level of security which will include confidentiality, integrity and availability. Risks to be considered will include but not be limited to the following: accidental or unlawful destruction loss alteration authorize disclosure of or access to personal data transmitted stored or otherwise processed which may in particular lead to physical material and nonmaterial damage.
  • EU4.8 Measures taken to mitigate data security risk will take into account the state-of-the-art as well as cost to implement in due consideration to the risks and nature of the personal data to be protected.
  • EU4.9 We will show on our website or other correspondence with you a clear and unambiguous statement of our identity.
  • EU4.10 The network upon which the data will be stored will be protected by us by network and information security means including prevention of unauthorized access to the network, prevention of installation of malware on that network, and prevention of denial of service attacks as well as other means of maintaining availability authenticity integrity and confidentiality of the data.
  • EU5.1 What happens if your data is involved in a data breach? We will notify the relevant GDPR supervisory authority as soon as possible, within 24 hours after we have been made aware of the data breach.
  • EU5.2 Where we are unable to notify supervisory authority within 24 hours a reason for the delay will be provided, will accompany the notification of breach and subsequent information provided in phases without undue further delay.
  • EU5.3 We will notify you as soon as is reasonably possible if we believe you may suffer any adverse impact as a result of the breach.
  • EU5.4 You will not be notified of any breach of pseudonymized data, as there is no adverse impact from the loss of such data.
  • EU5.5 Additionally we will notify the data controller within 24 hours after we have been made aware of the data breach.
  • EU5.6 After any potential breach we will examine all appropriate technological protection and organizational measures so that we may determine if a personal data breach has actually taken place.
  • EU6.1 Your right to have decisions reconsidered If your data is processed by an automatic decision-making algorithm and the decision made based on your personally identifiable characteristics you have the right to request a review of the decision made.
  • EU7.1 Your right to access your data You have the right to access your GDPR data.
  • EU7.2 You have the right to request information about how your GDPR data is being processed by us.
  • EU7.3 You have the right to ask us for how long we intend to retain your GDPR data
  • EU7.4 We will provide you upon request a description of the categories of data that we process.
  • EU7.5 We will provide you upon request a copy of your data that we store.
  • EU7.6 Will provide you upon request a list of those with which we share your data.
  • EU7.7 We’ll provide you upon request a description of how we acquired your data.
  • EU7.8 You may contact us with respect to your data by email, by phone or through our website.
  • EU7.9 A role shall be appointed, called the data protection officer who will be responsible for ensuring your data is protected under the rules and regulations of the GDPR.
  • EU7.10 Any descriptions, lists, FAQs, explanations or correspondence related to your data will be in clear and plain language which is easy to understand.
  • EU7.11 You have the right to ask us to ensure that any of your personal data which is inaccurate is rectified or erased.
  • EU7.12 You have the right to be forgotten, including the right to ask us to remove and raise your data upon request.
  • EU7.13 We will respond to requests about your data without undue delay and at the latest within one month from the date of the request.
  • EU7.14 Where possible we will provide you with a secure portal in which you will have direct access to your GDPR data
  • EU7.15 We have the right to use all reasonable measures to verify your identity before providing you with online access to GDPR data and if you’re unable to prove to our satisfaction that you have the right to access the data.
  • EU8.1 Your right to erasure You have the right to request that your data is erased at any time by making a request to us to do so.
  • EU9.1 Your right to transfer your data You have the right to ask us to transfer your personal data from us to another electronic processing system upon request. We will do this for you, upon request within a reasonable timeframe.
  • EU9.2 If you ask us to transfer your personal data to another electronic processing system we will provide you a copy of this data in an open standard electronic format.
  • EU10.1 Your right to complain You have the right to Lodge a complaint with the supervisory authority if you believe your rights under the GDPR regulations have been infringed.
  • EU11.1 Responsibilities to supervisory bodies Upon request by the supervisory body we will demonstrate by means of policies, codes of conduct, approved certifications and guidelines to which we are compliant with this regulation.
  • EU11.2 We will implement internal policies and measures which meet the principles of data protection by design and by default. These measures include but are not limited to the minimization of processing of personal data, pseudonymization of personal data as soon as possible, transparency with regards to the functions and processing of personal data, providing ability of the data subject to monitor the data processing, and maintaining strong security measures to protect confidentiality, integrity and availability of the data.
  • EU11.3 Where data is jointly or subsequently processed by third parties a clear allocation and description of responsibilities under these regulations will be agreed upon between us and the third party in a contract which will be made available for review to a supervisory body upon request.
  • EU11.4 Where data is processed by third parties, only third parties providing sufficient guarantees particularly in terms of expert knowledge reliability and resources to implement technical and organizational measures which requirements of the GDPR including for the security of processing will be used to process the data.
  • EU11.5 We will designate a representative of the organization who is available to be addressed by any supervisory body regarding any GDPR data stored or processed by us. The representative will be explicitly designated in written documentation and representative made aware of his or her responsibilities as a representative. The tasks of the representative will be designated in our policies in clear and unambiguous language. The designated representative will be subject to enforcement proceedings in the event of non-compliance by the controller or processor.
  • EU11.6 Any processing of GDPR data will be described and maintained in records of processing activities. These records will be made available to supervisory bodies upon request.
  • EU12.1 Ensuring compliance of third parties With respect to data for which we are the controller, we will ensure compliance with the regulations by validating compliance of any third parties who process your data. We will validate such third parties as to the regulations by validating the following approved code of conduct or an approved certification mechanism.
  • EU12.2 Any GDPR data processed by a third party will be governed by a contract in which the obligations of the third party under the regulations will be spelled-out.
  • EU12.3 Any contracts specifying the obligations of third party processors will be written to comply with European Union member state law.
  • EU12.4 Any contracts specifying the obligations of third party processors will include terms which specify the duration of the period of processing, subject matter content of the data purposes for which the processing will take place, definition and categories of data relating to data subject, tasks and responsibilities of the processor.
  • EU12.5 At the conclusion of the processing of the data on behalf of the controller, the processor will return or erase the data to the controller.


  • EU13.1 Compliance Measurement The Attendease team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner.
  • EU13.2 Exceptions Any exception to the policy must be approved by the Attendease team in advance.
  • EU13.3 Non-Compliance An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.


At intervals of no less than once per year, this policy is to be reviewed, and if necessary, revised under the supervision of the CEO.


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LAST UPDATED: December 30, 2019


We collect 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”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Example Collected
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. 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). NO
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
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. NO
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 data Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • 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 our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our website ( For example, from submissions through our website portal or website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform.


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 present its 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.


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:
  • Category B:
  • Category C:
  • Category I:

California Customer Records personal information categories. Protected classification characteristics under California or federal law. Professional or employment-related information.
We disclose your 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.

In the preceding twelve (12) months, we have not sold any personal information.


The CCPA provides consumers (California residents) with specific rights regarding their personal information. This includes:

CA4.1.1 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 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 sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosuresforabusinesspurpose,identifyingthepersonalinformationcategories that each category of recipient obtained.

CA4.1.2 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:

    1. 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.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Debug products to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech; ensure the right of another consumer to exercise their free speech rights; or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
    6. 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.
    7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    8. Comply with a legal obligation.
    9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

CA4.1.3 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 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.
You may only make a verifiable consumer request for access or data portability 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.
        • 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.

CA4.1.4 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. 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 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.


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.


We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.


If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at “”.