Delta Trading Group

Revision Date: 2024-11-12

I. WHO WE ARE

DELTA TRADING GROUP, INC licenses company products and services to Users in association with Delta Trading Group, Inc, SP500 Trader, SP500 Trading Academy, Trading Academy, Delta Centurion Alliance, Delta Centurion Alliance Launch Pad, Delta Trading Groups Launch Pad Program and DeltaD123.

The Company (“we”, “us”, “our”, or “DTG”) values and respects your privacy and is committed to protecting your personal information. This Privacy Policy (“Privacy Policy”) describes how we collect, use, disclose, and safeguard your personal information when you visit our website(s) deltatradinggroup.com, delta-trading-group.thinkific.com, deltacenturionalliance.com, deltalogik.com, deltad123.com, launchpad.deltacenturionalliance.com, dtgportal.com, thetradinggroupshow.com, and sp500emini.com (the “Website”), including any and all content, functionality, and services offered on or through the Website (collectively, the “Company Sites and Materials” or “Services”).

If there are questions about our privacy practices, please refer to the end of this Privacy Policy for information about how to contact us.

II. INFORMATION

We Collect personal information that you voluntarily provide to us when you use our Company Sites and Materials or Services. This information may include your name, email address, phone number, and other contact information. We may also collect non-personal information such as your IP address, browser type, operating system, usage data-collected automatically when using the Company Sites and Materials, and other technical information.

Unless specified otherwise, all Personal Data requested by the Services is required for a User to use the Services and failure to provide this data may make it impossible for the Company to provide the necessary access to Company Sites and Materials or Services. In cases where the Company Sites and Materials or Services indicate that some Personal Data is not required, Users are free not to communicate this data without impact to the availability or the functionality of the Company Sites and Materials or Services.

Users who are uncertain about which Personal Data is required for the Services are welcome to contact the Company.

In addition to the information contained in this Privacy Policy, the Company may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

III. HOW WE USE YOUR INFORMATION

The Company processes Personal Data, including sharing it with third parties, where processing is necessary for the purposes of our legitimate commercial interests and performance of the Services as further described in this Section. 

 

Our legitimate interest in the effective delivery of information and services to you, and the effective and lawful operation of our business includes:

 

• Providing products and services to Users

• Analyze, developing, and improving our website, and your user experience

• Performing analytics on the Services

• Contacting the User

• Respond to your inquiries or customer service requests

• Displaying content from external platforms

• Managing contacts and sending messages

• Performing platform services and hosting

• Managing registration and authentication

• Performing tag management

• Managing system logs and maintenance

• Performing internal operations, such as improving the effectiveness of our Services

• Conducting audits

• Providing information to our representatives and advisors, such as our attorneys, accountants, and others to help us comply with legal, accounting, or security requirements

• Transferring information as part of a merger or sale of the business

• Resolving disputes between Users, customers and the Company

• Protecting the rights, safety, and information of the Company, our customers and their members, and third parties

• Complying with our legal obligations, responding to enforcement requests, protecting the Company’s rights and interests (or those of its Users or third parties) and detecting any malicious or fraudulent activity

• Send you marketing and promotional materials

 

A User’s Personal Data may be used for legal purposes by the Company in court or in the stages leading to possible legal action arising from improper use of the Company Sites and Materials or Services. The User acknowledges and agrees that the Company may be required to reveal Personal Data upon request of public authorities.

The Company may aggregate, combine, anonymize and/or pseudonymize any data that we collect and process, including Personal Data. This may be done for the purpose of performing the Services, correcting data currently held by the Company, expanding data sets and research.

IV. DISCLOSURE OF YOUR INFORMATION

The Company does not sell Personal Data that we collect.

We may share your personal information with third-party service providers who assist us in providing our services. These service providers are contractually obligated to use your information only to provide the services we require and not for any other purpose.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

For the purpose of data sharing your SMS opt-in data and consent status will not be shared, traded, or otherwise sold.

The Company does NOT collect information to be shared with loan providers, service providers, or for other lead generation purposes.

The Company does NOT utilize lead generation or affiliated marketing companies that buy, sell, or share SMS opt-in phone numbers.

SMS Consent or phone numbers are not shared for the purpose of SMS with third parties or affiliates.

The Company strictly adheres to following TCR, CTIA, Federal and State SMS regulations and guidelines. You WILL NOT receive any messages from the Company that:

• Engage in any illegal activity or otherwise violate our terms of service, including the acceptable use policy.

• Engage in or promote, pornographic or adult entertainment, regardless of legality.

• Contain text or references to violence, hate speech, or otherwise engaging in threatening, abusive, harassing, defamatory, libelous, deceptive or fraudulent behavior.

• Contain text or otherwise reference substances defined as controlled substances under federal law, regardless of legality, including marijuana (cannabis).

• Contain third-party affiliate/lead generation links.

• Contain obfuscated links for the purpose of misleading the reader, or use links contrary to the expectation of the user based on the message text.

• Are structured to evade this policy or the policies of carriers (e.g. misspelling, uncommon capitalization, snowshoeing, etc.).

We may also disclose your information if required by law, to protect our rights or property, or to comply with a court order or legal process.

V. SECURITY OF YOUR INFORMATION

We take reasonable measures to protect your personal information from unauthorized access, disclosure, or use. However, no data transmission over the Internet or electronic storage system can be guaranteed to be 100% secure.

The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of Personal Data. The Company utilizes industry-accepted reasonable security practices and has implemented reasonable technical and organizational measures to protect the confidentiality, security and integrity of User’s Personal Data. The measures that the Company has implemented take into account the current available security technologies, cost, and risk presented by the type of Personal Data the Company processes. Although the Company uses reasonable security measures to help protect Personal Data against unauthorized disclosure or loss, the Company cannot guarantee the security of Personal Data transmitted to the Company over the Internet. While the Company strives to use commercially acceptable means to protect Personal Data, there is no guarantee that information may not be accessed, disclosed, altered or destroyed.

 

The processing of Personal Data is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated herein or through the Services.

 

The Company may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislation, the Company may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any of the other legal bases specified herein. This, however, does not apply whenever the processing of Personal Data is subject to European data protection law;

• provision of data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

• processing is necessary for compliance with a legal obligation to which the Company is subject;

• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company; or

• processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing of a User’s Personal Data, and in particular whether the processing of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

The Personal Data is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located.

 

Depending on the User’s location, data transfers may involve transferring the User’s Personal Data to a country other than their own.

 

Users are entitled to learn about the legal basis of Personal Data transfers to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Company to safeguard their Personal Data.

Who Can Access Personal Data Collected

We will only disclose Personal Data as set forth in this Privacy Policy, as permitted by law, or with the User’s consent. Where third parties are processing Personal Data on our behalf, they will be required to agree, by contractual means or otherwise, to process the Personal Data in accordance with applicable law and to act only on the Company’s instructions.

In addition to being accessible by the Company, in some cases, Personal Data may be accessible to certain types of persons involved with the operation of the Services (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Company.

We may disclose Personal Data to the following entities and for the listed purposes:

• Customers and Other Authorized Business Partners. For the purpose of providing the Services, the Company will share Personal Data with a User’s designated organization (i.e., the Company’s customer).

• Employees. Only authorized employees have access to Personal Data.

• Contractors and Service Providers. the Company’s employs other companies and individuals to perform functions on our behalf. Examples of such functions include fulfillment activities, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing technical support and providing customer service. the Company may share Personal Data with these contractors and service providers as we deems necessary for such third parties to perform their functions related to the Services.

• To Comply with Legal Process, Protect Company, or Enforce our Rights. the Company may further disclose Personal Data when it is necessary to: (i) conform to legal requirements or comply with legal processes; (ii) enforce or apply our conditions of use and other agreements; (iii) protect the rights, safety or property of the Company, our affiliates, our customers, service providers, Users or the public, or (iv) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

• As Part of a Merger or Sale of Business. the Company may disclose or transfer Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Retention Of Personal Data

• Personal Data shall be processed and stored for as long as required by the purpose(s) it has been collected for:

  • Personal Data collected for purposes related to the performance of a contract between the Company and the User (or User’s employer) shall be retained until such contract has been fully performed.

  • Personal Data collected for the purposes of the Company legitimate business interests shall be retained as long as needed to fulfill such purposes.

  • The Company may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn.

  • The Company may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

  • Once the applicable retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to correct and the right to data portability cannot be enforced after expiration of the applicable retention period.

VI. RIGHTS OF USERS

You may choose to opt-out of receiving marketing and promotional materials by following the unsubscribe instructions in our communications. You may also request to access, correct, or delete your personal information by contacting us at [email protected].

Users may exercise certain rights regarding their Personal Data processed by the Company.

• In particular, Users have the right to do the following:
  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Personal Data. Users have the right to object to the processing of their Personal Data if the processing is carried out on a legal basis other than consent.
  • Access their Personal Data. Users have the right to learn if their Personal Data is being processed by the Company, obtain disclosures regarding certain aspects of such processing and obtain a copy of the Personal Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.
  • Restrict the processing of their Personal Data. Users have the right, under certain circumstances, to restrict the processing of their Personal Data. Where Users have and exercise such right, the Company will not process a User’s Personal Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Personal Data from the Company.
  • Receive their Personal Data and have it transferred to another controller. Users have the right to receive their Personal Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Personal Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
• Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Company or for the purposes of the legitimate interests pursued by the Company, Users may object to such processing by providing grounds related to their particular situation to justify the objection.
• Should a User’s Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. The Company does not process Personal Data collected for direct marketing purposes.
• Any requests to exercise User rights can be directed to the Company through the contact details provided in this Privacy Policy.

VII. THIRD-PARTY LINKS

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to read the privacy policies of those websites.

The Services may contain links to third party websites, applications and services not operated by the Company. These links are provided as a service and do not imply any endorsement by the Company of the activities or content of these websites, applications or services nor any association with their operators. The Company is not responsible for the privacy policies or practices of any third party including websites or services directly linked to or from our Services.

VIII. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

The Services do not support “Do Not Track” requests. To determine whether any third-party services used by or linked to the Services honor “Do Not Track” requests, please read the privacy policies for those services.

IX. INFORMATION FOR CALIFORNIAN CONSUMERS

The California Consumer Privacy Act of 2018 (“CCPA”) provides several rights to California residents with regards to the collection, disclosure, sale, and deletion of their Personal Data. The Company Privacy Notice set forth in Schedule 2 (California Privacy Notice) describes in more detail the Company’s compliance with CCPA and how residents of California may exercise their CCPA Rights. If a User has questions about exercising their CCPA Rights, please contact us as set out below.

X. INFORMATION FOR OTHER U.S. CONSUMERS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. The Services are available in all fifty states. 

Schedule 3 describes in detail the Company’s compliance with Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia privacy law.  If a User has questions about exercising their specific state rights, please contact us as set out below.

XI. USERS BASED IN THE EUROPEAN UNION OR THE UNITED KINGDOM

The Company provides Services within North America.

For purposes of the EU’s General Data Protection Regulation (“GDPR”), and the UK GDPR, the Company is a data processor and service provider, with an office at 5151 E Broadway Blvd Ste 1600 11, Tucson, AZ 85711, USA.

The Company is headquartered in the United States. By using any of the Services from outside the United States, Users acknowledge that their Personal Data will be accessed by the Company or transferred to the Company in the United States and to those entities listed in Section V. SECURITY OF YOUR INFORMATION: WHO CAN ACCESS PERSONAL DATA COLLECTED of this Privacy Policy who are located around the world; and that User Personal Data will be transferred to, and stored and processed in, the United States or elsewhere in the world where the Company servers are located.

Recourse, Enforcement, And Liability

In compliance with the EU-U.S. DPF Principles, including the UK Extension of the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, the Company commits to resolve complaints about your privacy and The Company’s collection or use of Personal Data transferred to the United States pursuant to this Policy.

 

European Union, Swiss, and United Kingdom individuals with DPF inquiries or complaints should first contact the Company’s Data Protection & Privacy Department by emailing [email protected].

 

The Company has further committed to refer unresolved privacy complaints under the DPF Principles to an independent recourse mechanism, American Arbitration Association, operated by ICDR-AAA If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit URL for more information and to file a complaint. This service is provided free of charge to you.

 

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not otherwise resolved by other redress mechanisms. For more information about binding arbitration, visit:

https://www.dataprivacyframework.gov/framework-article/G%E2%80%93Arbitration-Procedures.

XII. CHILDREN’S PRIVACY

Our Website is not intended for children under the age of 18. The Company does not knowingly collect Personal Data from children under the age of 18. If the Company learns that Personal Data of persons younger than 18 years-of-age has been collected through the Services, the Company will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child or a minor under the age of 18 has posted, submitted or otherwise communicated Personal Data to the Company without your consent, then you may alert us at [email protected] so that we may take appropriate action to remove the minor’s Personal Data from our systems.

XIII. COOKIES

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When a User first accesses the Services from certain jurisdictions, the User will receive a message advising the User that cookies are in use. By clicking “accept”, the User agrees to the Company’s use of cookies as described in this Privacy Policy. If the User does not wish to receive cookies, the User may withdraw their consent or set their browser to reject cookies or to alert the User when a cookie is placed on their device. If the User withdraws consent, limits or disables the use of cookies when the User visits or uses the Services, the User may not be able to use the full functionality of the Services. For more information about our specific use of cookies, please reference our “Cookie Policy,” which is attached as Schedule 1 (Cookie Policy) and incorporated herein by reference. The Company may also permit select third parties to use cookies to collect information about Users’ online activities across other websites or over time in order to assist us with Services analytics.

Third-Party Use Of Cookies

Some content or applications, including advertisements, found within the Company Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use the Company Sites and Materials or Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

XIV. EMBEDDED CONTENT FROM OTHER WEBSITES

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

XV. DEFINITIONS

“Data Processor”: The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller, as described in this privacy policy.

“Data Subject”: The natural person to whom the Personal Data refers.

“European Union” or “EU”: Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

“Usage Data”: Information collected automatically through the Services (or third-party services utilized for the Services), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Services) and the details about the path followed within the Services with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

“User”: The individual using the Services who, unless otherwise specified, coincides with the Data Subject.

XVI. MISCELLANEOUS

This privacy statement has been prepared based on provisions of multiple legislation, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

More details concerning the collection or processing of Personal Data may be requested from the Company at any time. Please see our contact information for inquiries.

XVII. CHANGES TO OUR PRIVACY POLICY

We reserve the right to update this privacy policy from time to time. We will post any changes on our Website with a new effective date. Your continued use of our Website after the effective date of the revised policy constitutes your acceptance of the policy. Users are strongly recommended to check the Services often, referring to the date at the top of this Privacy Policy for the last modification date.

Should changes to this Privacy Policy affect processing activities performed on the basis of the User’s consent, the Company shall collect new consent from the User, where required.

XVIII. CONTACT US

If you have any questions or concerns about our privacy policy or our data practices, please contact us at [email protected].

XIX. CONCLUSION

We understand that privacy is important to you, and we are committed to protecting your personal information. We hope that this privacy policy has helped you understand how we collect, use, and safeguard your information.

SCHEDULE 1

COOKIES

Cookies are blocks of textual information that are sent electronically from a web server to your browser and are stored on your computer or mobile device. We may use cookies to offer a better browsing experience, to facilitate the use of analytics tools that measure and identify traffic patterns and to track the performance of features and advertisements. By increasing our understanding of how you and our other customers and visitors use our services, cookies enable us to continually improve the form and functionality of our services and to convey to you the most relevant information and current offers. Information gathered through the placement and tracking of cookies may be shared with the Company employees, agents and affiliates.

We classify cookies into the following categories:

• Essential Cookies: These are essential cookies enabled for the proper functioning of websites and are used to perform basic functions. Without these cookies websites may not function as intended.

• Analytics Cookies: These cookies collect aggregated information about how visitors use a website. The information collected is used to provide us with statistical information about the site.

• Personalization Cookies: Also known as ‘preference’ cookies, these cookies help the website remember choices you’ve selected to provide a more personalized user experience.

• Marketing Cookies: Also referred to as “targeted advertising” cookies, these are cookies placed by us or third parties for the purpose of displaying targeted advertisements to you.

For more details, please refer to the cookie banner interface presented in accordance with applicable laws and regulations when you visit our website. You can use this banner to configure your cookie preferences in connection with our website. Please note, if you use different devices or browsers to interact with our websites, you may need to indicate your preferences again. You may modify these preferences at any time directly within the cookie banner interface. Additionally, this banner may describe the specific cookies utilized, their purpose(s), their source(s), and expiration period. Some cookies may last for only as long as you are on the website (‘session’ cookies), others may remain for longer periods of time in accordance with their purpose (‘persistent’ cookies).

Alternatively, most web browsers and mobile devices offer settings that permit the user to manage cookies. You can set your browser or mobile device to refuse all or some browser cookies or to alert you when websites set or access cookies. Please note that if you should elect to refuse or delete cookies provided by a Company website or service, you may experience some inconvenience in your use of Company products and services. For example, you may be asked for additional verification while signing in to access your account or we may not be able to recognize your device or your previously established online preferences.

The Company may allow other companies or third-party advertising services to place cookies onto your computer or mobile device while browsing a Company website. In such cases, these third-party companies generally use these cookies in a manner consistent with our use and are typically doing so in support of campaigns sponsored by DTG companies. In instances where you may be directed to leave a Company website as it relates to the services provided to you or to complete the performance of a contract with you, please read the cookies policy of the third-party company, so you are aware of how that third-party company may use your information and, when presented with the opportunity to choose how you want to share your data, you can make an informed decision regarding cookie management of your data with that third-party.

SCHEDULUE 2

I. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information the Company has collected about them, and whether The Company disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Data Collection” and “Use Of Personal Data And Purpose Of Processing” above, respectively.

II. “SALES” OF PERSONAL INFORMATION UNDER THE CCPA

For purposes of the CCPA, the Company does not “sell” personal information, nor do we have actual knowledge of any “sale” of User personal information, as the term “sell” is commonly understood. 

III. ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

Information

You can request the following information about how we have collected and used your Personal Information during the past 12 months:

• The categories of Personal Information that we have collected.

• The categories of sources from which we collected Personal Information.

• The business or commercial purpose for collecting and/or selling Personal Information.

• The categories of third parties with which we share Personal Information.

• The categories of Personal Information that we sold or disclosed for a business purpose.

• The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

 

Access

You can request a copy of the Personal Information that we have collected about you.

Appeal

You can appeal our denial of any request validly submitted.

Correction

You can ask us to correct inaccurate Personal Information that we have collected about you.

Deletion

You can ask us to delete the Personal Information that we have collected from you.

Opt-out

• Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.

• Opt-out of profiling/automated decision making. You can opt-out of automated processing or profiling performed on personal information to evaluate, analyze, or predict personal aspects related to a person’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

• Opt-out of other sales of personal data. You can opt-out of other sales of your Personal Information.

Limit processing of Sensitive Personal Information

You have the right to limit certain uses or disclosures of sensitive personal information; however, we do not collect, use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.

 

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent

Only you, or someone legally authorized 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. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification

To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” in the Privacy Policy above. We will process such requests in accordance with applicable laws.

SCHEDULE 3

PRIVACY RIGHTS OF OTHER U.S. RESIDENTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. The Services are available in all fifty states. 

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide their state residents with rights to:

• Confirm whether we process their personal information.

• Access and delete certain personal information.

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).

• Data portability.

• Opt-out of personal data processing for: (i) targeted advertising (excluding Iowa); (2) sales; or (3) profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

• Either limit (opt-out of) or require consent to process sensitive personal data.

 

The exact scope of these rights may vary by state. To exercise any of these rights please contact us, or have your authorized representative contact us, as set forth in “Contact Us” in the Privacy Policy above. In the event you have an authorized representative submit a request to delete, request to correct, or request to know on your behalf, you will have to provide written authorization demonstrating this grant of authority, which can include a Power of Attorney. Authorized representatives may not submit any other types of requests on your behalf. 

For purposes of requests to delete, correct and to know, we will verify your identity based on information we have collected about you, including your name, address, and phone number, but will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the Personal Information. If we are unable to verify your identity, we may deny your request.

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.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada Residents who wish to exercise this sale opt-out rights may contact us as set forth in “Contact Us” in the Privacy Policy above. However, please know we do not currently sell data triggering that statute’s opt-out requirements.