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Worklution is the parent company of Wrk Receipts and Caged Bird HR. One privacy notice covers all of our sites and apps, with an additional notice for California residents.

Worklution Inc. Privacy Notice

Last revised October 5, 2024

Welcome to Worklution Inc.! Worklution is the parent company of future of work brands, Caged Bird HR and Wrk Receipts.

Worklution, Inc. (“Worklution”, “we”, “us”, or “our”) provides technology and services that are designed to improve the world of work and empower employees to take control of their work lives. We understand and appreciate your concerns about privacy and want you to be familiar with how we collect, use and disclose Personal Information (as defined below). This Privacy Notice explains what Personal Information we collect, how we use and share that information, and your choices concerning our information practices.

This Privacy Notice governs your (“you” or “Users”) use of worklution.com and any other Worklution owned or operated websites (including mobile sites, and Caged Bird and Wrk Receipts) (collectively, the “Site”), mobile applications, widgets and/or any interactive features other online services controlled by Worklution that post a link to this Privacy Notice or otherwise reference that this Privacy Notice applies to information collected through the Site, application or other features or services (all of the foregoing collectively referred to as the “Service”). However, to the extent that any activities or information are governed by the Health Insurance Portability and Accountability Act (HIPAA) and/or other federal and state law, such laws will govern and such activities and information are outside the scope of this Privacy Notice.

This Privacy Notice does not apply to our handling of information collected from other Users, such as companies or other third-parties (collectively, “Businesses”). Data and information collected through such activities are governed by the Businesses’ privacy policies as well as Worklution’s agreement(s) with such Businesses. If you have questions about a Business’ privacy practices, please reach out to them directly.

Notice at Collection

Before using the Service or submitting any Personal Information to Worklution, please review this Privacy Notice carefully and contact us if you have any questions. By using the Service, you agree to the practices and specifically the collection, disclosure, use and retention of Personal Information described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not access the Site or otherwise use the Service.

1. Personal Information We Collect

When you interact with us through the Service, we collect and combine information and data from you, including information that may identify you or otherwise be considered to be “personal information”, “personal data” or “personally identifiable information” under laws that regulate privacy and data protection (“Personal Information”) as follows:

Personal Information You Provide: We collect the following categories of Personal Information from you when you visit the Site, create a Worklution account, subscribe to the Service, or otherwise provide such information to us:

Identification Information: We collect your name and email address.
Photographs/Videos/Audio: We collect the photos, videos, audio recordings and other graphical and/or auditory depictions you upload to the Service, which may include identifying information of you.
Work-Related Information: We may collect certain information related to your employment or engagement, such as gender, veteran status, company of employment or engagement, job title, income range, and supervisor’s gender and race.
Financial Information: Our payment processor(s) will collect and store the financial information necessary to process your payments for our software services, such as your payment card number and authentication details. We do not process payments for Users in the United States.
Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication information is optional to you.
Location Information: Our Service may use location-based services in order to locate you, such as using your zip or postal code, IP address or other geolocation information, so that we may verify your location and/or deliver you relevant content based on your location.
Commercial Information: We may retain a history of the products and services you browse and/or purchase using the Service.
Social Media Information: We have pages on social media sites like Instagram, Facebook, TikTok, Threads, and Twitter (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. Your posts, comments, replies to and mention of Worklution may be publicly visible, depending on privacy settings. We do not have control over the privacy and retention of your Personal Information on Social Media Pages, which are governed by the privacy policies of the parties that operate the platforms that host the Social Media Pages. We have no responsibility or liability for the manner in which the operators of the Social Media Pages collect, use, disclose, secure or otherwise treat your personal Information.

Sensitive Personal Information You Provide: Subject to your consent and depending on the products and services you use and your choices, we may collect, process, or disclose certain Personal Information that qualifies as “sensitive data” under applicable U.S. state data privacy laws (“Sensitive Personal Information”). Sensitive Personal Information is a subset of Personal Information. In the list below, we outline the categories of Sensitive Personal Information we collect, the source of the Sensitive Personal Information, our purposes of processing, and the categories of third-party recipients to whom we disclose the Sensitive Personal Information. Categories of Sensitive Personal Information that we may collect:

Racial or ethnic origin, religious or philosophical beliefs, or union membership
Medical or mental health, a mental or physical health condition or diagnosis, sex life, sexual orientation, gender identity, or disability status
Citizenship or immigration status

Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

Geolocation Information: When browsing our website, we may collect general information regarding your geographic location.
Cookies Information: Please see the “Cookies” section below to learn more about how we use cookies.
Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

Personal Information Collected from Other Sources: We may receive Personal Information, such as contact information and marketing preferences, from other sources, such as educational institutions, third-party partners, and publicly available information.

Derived Information: We may infer your preferences for certain products and services based on the Personal Information we collect about you.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies).

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Browser controls are available in Google Chrome, Microsoft Edge, Mozilla Firefox, Opera, and Apple Safari, and many browsers support Global Privacy Control.

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

2. How We Use Personal Information

We may use Personal Information for the following purposes:

To provide, operate, and improve the Service and our business;
To respond to your inquiries, comments, feedback, or questions;
To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
To analyze how you interact with our Service;
To develop new products and services;
To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks;
To deidentify and/or aggregate and anonymize your Personal Information for our own business purposes; and
To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Research and Development: We may aggregate Personal Information and use the aggregated and deidentified information to analyze the effectiveness of the Service, to improve and add features to the Service, gain anonymous insights into product and performance on the Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of Users and share aggregated information like general user statistics with prospective business partners. We will maintain and use the information in deidentified form and will not attempt to identify the information, except for the purpose of determining whether our deidentification process satisfies the requirements of the CCPA, and any other uses allowed under applicable law.

Communications and Marketing: We may use your Personal Information, such as your email address, to contact you to provide the Service and communicate related information.

If you provide your telephone number, you acknowledge and agree that we may contact you, including but not limited to for promotional, informational and other purposes, using SMS text messages, cellular or telephone calls, and push notifications (if applicable) even if you have opted in to the US National Do Not Call List, any state equivalent Do Not Call List or the internal Do Not Call List of any business, and that such messages and calls may be sent using automatic dialing systems or artificial or prerecorded voice messages.

How Long We Keep Your Information: We will only keep your Personal Information for as long as it is reasonably necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

If you would like to opt-out of receiving certain communications, see the “Your Choices” section below.

In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:

Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively and each a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with a Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, including to meet national security or law enforcement requirements, (b) protect and defend our rights or property, (c) prevent fraud, (d) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (e) protect against legal liability.
Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Worklution. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Notice. Affiliates may be located outside the United States of America.
Other Users: The Service may contain a community forum and message board where Users are able to create profiles, writings, reviews, photographs, ideas, videos, audio recordings, computer graphics, pictures, data, or other content, including Personal Information (collectively, “User Content”). The Service may display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it.
Discretion/Consent: We may share your Personal Information at your discretion, including when you submit a product review using a third-party service or otherwise direct us to disclose your Personal Information to a third party. We may also share your Personal Information with your consent.

4. Users Outside of the United States

For the purposes described in this Privacy Notice, we may transfer your Personal Information from the European Economic Area (EU Member States, Iceland, Liechtenstein and Norway) and/or the United Kingdom to our U.S. office or a third party outside of the EEA or the UK and in a jurisdiction not subject to an adequacy decision of the European Commission or the UK Government, as applicable. When we transfer your Personal Information to other third parties outside of the EEA or the UK, for example service providers, we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure the integrity and protection of your Personal Information wherever processed. If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your Personal Information in accordance with this Privacy Notice and applicable law. By providing your Personal Information, you consent to such transfer.

Your Rights in Relation to Your Personal Data Under GDPR and/or UK GDPR: Subject to the applicable provision of the GDPR and/or UK GDPR, you have the following rights with respect to your Personal Information:

Right of access (commonly known as a “data subject access request”): If you ask us, we will confirm whether we are processing your Personal Information and, if so, provide you with a copy of that Personal Information along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
Right to rectification: If your Personal Information is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
Right to erasure: You may ask us to erase your Personal Information in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable) and there is no other legal basis for processing.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Information in certain circumstances, such as if you contest its accuracy or object to us processing it.
Right to data portability: You have the right to obtain your Personal Information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
Right to object: You may ask us at any time to stop processing your Personal Information, and we will do so: (a) if we are relying on a legitimate interest (described above) to process your Personal Information, unless we demonstrate compelling legitimate grounds for the processing or your information is needed to establish, exercise, or defend legal claims; or (b) we are processing your Personal Information for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
Right to withdraw consent: If we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time, but this will not affect any processing of your information that has already taken place.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Information, you can report it to the data protection authority that is authorized to hear those concerns (in the United Kingdom, the Information Commissioner’s Office (ICO) at https://ico.org.uk/concerns).

To exercise your rights under the GDPR and/or the UK GDPR, please send us your request as set forth in the “Contact Us” section below.

Your Rights in Relation to Your Personal Data if You Are a Resident of Canada: We may process your information if you have given us specific permission (i.e., express consent) to use your Personal Information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
For investigations and fraud detection and prevention;
For business transactions provided certain conditions are met;
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
For identifying injured, ill, or deceased persons and communicating with next of kin;
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
If the collection is solely for journalistic, artistic, or literary purposes; or
If the information is publicly available and is specified by the regulations.

To exercise your rights as a Canadian resident, please send us your request as set forth in the “Contact Us” section below.

5. State Privacy Rights

Where provided for by law and subject to any applicable exceptions, residents of certain states may have additional rights. If you are a California resident, please see our California Privacy Notice below. If you live in the state of Colorado, Connecticut, Florida, Montana, Oregon, Texas, Utah, Virginia, and effective in 2025 in Delaware, Iowa, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Tennessee, or in locations with similar laws, you may have such rights. These rights are not absolute, and in some cases, they may not apply, including if a legal exception applies. If this is the case, we will not be able to process your request. The rights include:

Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
Right to Opt Out of Targeted Advertising: The right to opt out of the processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising.
Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.
Right to Limit Use and Disclosure of Sensitive Information: In some cases, you may have the right to ask that we limit the way we use your Personal Information. In some cases, you can exercise this right by asking that we delete your Personal Information. You may also have the right to object to how we process Personal Information, or to withdraw your consent if our use is based on consent.

Please note that to protect your information and the integrity of our products, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government issued ID.

Under certain U.S. Privacy Laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued ID, to verify your identity before processing your request to protect your information.

For more information about the possibility of submitting an opt-out request, please refer to the Your Choices section below, or submit a data subject access request.

The information we collect, use, and disclose about you will vary depending on how you interact with the Services. To find out more please visit the following sections of this Privacy Policy: Personal Information We Collect, How We Use Personal Information, and Sharing and Disclosure of Personal Information. If you would like to exercise any of these rights, you may do so by contacting us as set forth in the “Contact Us” section below. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

6. Children

We do not intentionally collect Personal Information from individuals in the U.S. who are under the age of 13. If a child under 13 submits Personal Information to Worklution and we learn that the Personal Information is the information of a child under the age of 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Information from a child under the age of 13, please contact us as set forth in the “Contact Us” section below.

7. Links to Other Websites

The Service may contain links to other websites and services not operated or controlled by Worklution, including social media services (“Third Party Services”). The information that you share with Third Party Services will be governed by the specific privacy policies and terms of service of the Third Party Services and not by this Privacy Notice. By providing these links we do not imply that we endorse or have reviewed these Third Party Services. Please contact the Third Party Services directly for information on their privacy practices and policies.

8. Security

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to Worklution via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or Third Party Services.

9. Your Choices

In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to request updates or corrections to your Personal Information. If you have questions or concerns about other Personal Information collected by us, or are unable to use your Worklution account and would like assistance accessing that information, please contact us as set forth in the “Contact Us” section below.

You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you, or by updating your settings through your account. If you unsubscribe from our marketing lists, you will no longer receive marketing communications from us but we will continue to contact you to provide the Service, regarding management of your account, other administrative matters, and to respond to your requests.

10. Changes to the Privacy Notice

The Service and our business may change from time to time. As a result, we may change this Privacy Notice at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Notice, you consent to the revised Privacy Notice and practices described in it.

11. Contact Us

If you have any questions or complaints about our Privacy Notice or information practices, would like to request a version of this notice in an accessible format, or would like to contact us in regards to any of the topics discussed above, please feel free to contact us at: (302) 291-2086, privacy@worklution.com; or Worklution, Inc., 16192 Coastal Hwy, Lewes, DE 19958.

Worklution Inc. California Privacy Notice

Last revised October 5, 2024

Privacy Notice for California Residents

This California Consumer Privacy Act Disclosure (“Disclosure”) explains how Worklution, Inc. (“Worklution”, “our”, “us” or “we”) collects, uses, discloses, shares, and retains Personal Information subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).

This Disclosure applies solely to California residents and covers both online and offline practices (e.g., phone and in-person).

What Is Personal Information?

Under the CCPA, “Personal Information” is information that identifies, relates to, describes, or could reasonably be linked with a particular California resident or household. The CCPA, however, does not apply to certain information, such as information subject to the Health Insurance Portability and Accountability Act (HIPAA) and/or other federal and state law, such laws will govern and such activities and information are outside the scope of this Privacy Notice.

Our Information Practices Regarding Personal Information

We collect, use, disclose, share, and retain Personal Information relating to California residents in a variety of contexts, as described below. For example, we collect Personal Information relating to California residents for marketing purposes and from individuals who apply for employment with us or are our employees, vendors, contractors, or similar personnel. The specific Personal Information that we collect, use, disclose, share, and retain, relating to a California resident, will depend on our specific relationship or interaction with that individual.

In the past twelve months, we have collected the following categories of Personal Information relating to California residents:

Personal identifiers, such as name and mailing address;
Personal Information, such as contact information and financial information;
Characteristics of protected classifications under California or federal law, such as age, gender, sexual orientation, religion, immigration status, and citizenship;
Commercial information, such as transaction and account information;
Internet or electronic network activity information, such as browsing history and interactions with our website;
Sensory data, such as call recordings, audio, electronic, visual, and similar information;
Professional or employment-related information, such as current employment information or employment history;
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics; and
Sensitive Personal Information, such as certain Account log-in, financial account, debit or credit card number, and the means to access the account (security or access code, password, credentials, etc.); precise geo-location information; racial or ethnic origin, religious or philosophical beliefs, or union membership; medical or mental health, a mental or physical health condition or diagnosis, sex life, or sexual orientation; genetic or biometric data that may be processed for the purpose of uniquely identifying an individual; citizenship or immigration status; contents of your mail, email, or text messages (where Worklution is not the intended recipient of the communication); and/or Personal Information collected from a known child under 13 years of age.

We may keep Personal Information as long as necessary or relevant for the practices described in this Disclosure or as otherwise required by law. Actual retention periods vary depending on product and service. We use the following to determine retention periods: Personal Information that is needed to provide our products and services as described in this Disclosure, for auditing purposes, to troubleshoot problems or assist with investigations, to enforce our policies and to comply with legal requirements. Laws and regulations require all financial institutions to obtain, verify, and record information that identifies each person for whom we open or have established an account.

In the past twelve months, we have collected the categories of Personal Information set forth above from the following categories of sources:

Directly from you;
Online and mobile app services, including cookies, pixel tags, beacons, and software development kits;
Government entities, including federal, state, or local government(s), or other public sources;
Third parties such as social networks and advertising networks;
Businesses or Non-businesses that you have authorized or directed to disclose your information to us; and
Service providers or contractors, with whom we have a contractual relationship to perform services on our behalf, or that you have authorized or directed to disclose your information with including data brokers as defined under California law.

We may collect Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives. For example, we use the Personal Information we collect to:

Personalize, develop, market, advertise, and provide our products and services (including analytic services);
Provide customer service;
Process payments or transactions, provide financing, or fulfill orders;
Help to ensure security and integrity;
Conduct research and data analysis;
Perform identity verification;
Maintain our systems, infrastructure, and facilities including debugging to identify and repair errors that impair existing intended functionality;
Maintain or service accounts;
Conduct risk and security control and monitoring;
Perform audit functions, including auditing interactions with consumers;
Maintain and enhance a product or service; and
Conduct other internal functions, such as investigations or research for technology development, comply with legal obligations, maintain business records, and exercise and defend legal claims and rights.

We do not use or disclose Sensitive Personal Information for purposes other than as specified in CCPA.

In the past twelve months, we have disclosed the following categories of Personal Information relating to California residents to the following categories for our business purposes, as indicated: None.

Additionally, we have disclosed Personal Information to Business or Nonbusiness third parties based upon the consent or at the direction of a California resident to disclose the information.

In the past twelve months, based upon our actual knowledge, we have not “sold” Personal Information or Sensitive Personal Information relating to California residents (including minors under 16 years of age). For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a business or third party for monetary or other valuable consideration.

Your Rights Under the CCPA

If you are a California resident, you may have certain rights over the Personal Information we have about you. You may request the following:

The categories of Personal Information that we collected about you and the categories of sources from which we collected such information;
The business or commercial purposes for collecting Personal Information about you; the categories of third parties to whom we disclosed such Personal Information (if applicable); the categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that category of Personal Information (if applicable);
Access to specific pieces of Personal Information we collected about you;
Deletion of Personal Information that we collected from you;
Correction of Personal Information that may be inaccurate;
Limitations regarding the use of your Sensitive Personal Information; and
Opt-out of sharing Personal Information with third parties for targeted advertising purposes.

In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer, where the Personal Information that we maintain about you is not subject to CCPA requirements, or where the Personal Information is a trade secret. We may also decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual.

The CCPA also sets forth exceptions for when a business is not required to delete Personal Information, including but not limited to, where it is reasonably necessary to maintain Personal Information to provide a good or service that you requested, comply with a legal obligation, or to help ensure security and integrity. As you would reasonably expect, the Sensitive Personal Information we collect, use, and disclose is done so to provide goods and services you requested, thus we cannot limit the use of your Sensitive Personal Information.

Furthermore, we may decline the request to correct Personal Information depending on the nature of the Personal Information, the accuracy of the request, how the information was obtained and the business purposes for which the information was collected, maintained, or used.

Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

How to Make a Request

If you are a California resident, you may submit a request by contacting us as set forth in the “Contact Us” section below. Additionally, you may enable a tool at the browser or device level that automatically communicates your opt-out preferences, such as Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt-out for the browser or device you are using at that time; this may require separate opt-out on other browsers or devices that you use to visit our website.

You may only exercise your rights to receive specific pieces of Personal Information twice within a 12-month period. The request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information, or you are an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To respond to your request for access, correction, or deletion, we must verify your identity or authority to make the request and confirm the Personal Information in our systems relates to you or the person for whom you are authorized to make the request. We will use Personal Information provided by you, including your name, home address, email address, date of birth, last four digits of your Social Security number, and telephone number, for security purposes and to verify your identity to make the request. We will provide you with an identification code via a one-time text message or one-time prerecorded voice message at the telephone number you provide. You will need to provide this identification code to us to continue with your request. We use a third-party identity verification service to assist with ensuring that you are properly authenticated prior to fulfilling your request.

If you intend to submit a request on behalf of someone else, we must have on file or you must provide to us sufficient documentation, such as an appropriate power of attorney, guardian, conservator or trustee or other such verification confirming you have the authority to act on behalf of the individual for whom you are submitting the request. To submit a request on behalf of someone else, please submit a request by contacting us as set forth in the “Contact Us” section below.

California “Shine the Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by contacting us as set forth in the “Contact Us” section below.