Privacy Policy

I. Introduction

A. Keller Technology Corporation (“Keller”) is committed to safeguarding the privacy rights of our website visitors and customers.  This Privacy Notice (“Notice”) is adopted to provide additional information concerning applicable privacy laws, including, but not limited to, the California Consumer Privacy Act (including the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”), the European General Data Protection Regulation (“EU GDPR”), the United Kingdom General Data Protection Regulation (“UK GDPR”) (together referred to herein as “GDPR”), and the China Personal Information Protection Law (“PIPL”) (all applicable privacy laws together referred to as “Data Protection Laws”).

B. This Privacy Notice (“Notice”) applies where we are acting as a data “controller” with respect to the Personal Data of our website visitors and customers from KellerTechnology.com and through our services (the “Services”). Keller Technology acts as a controller of Personal Data when we determine the purposes and mean of the processing of that Personal Data. This Notice does not apply to information collected by us on any other website operated by Keller or any third party that does not link to this Notice; or any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Services. We may provide additional or different privacy policies that are specific to certain features, services, or activities.

C. We use cookies on our website. To the extent that cookies are not strictly necessary in connection with the operation of our website and the provision of our products and services, we will ask you to consent to our use of cookies when you first visit our website.

D. Our website incorporates privacy controls which affect how we will process your Personal Data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via www.KellerTechnology.com. 

E. In this Notice, “we”, “us” and “our” refer to Keller Technology Corporation.  For more information about us, see Section XII. Capitalized terms not otherwise defined herein shall have the same meaning as those designated under applicable Data Protection Laws.

F. Please read this Notice carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this Notice. This Notice may change from time to time. Your continued use of the Services after we make changes as described herein is deemed to be acceptance of those changes, so please check the Notice periodically for updates.

II. What Data We Process and How We May Use Your Data

A.  Generally

1.  In this Section II we will explain:

a. the general categories of Personal Data that we may process. “Personal Data” is defined as data about you by which you may be personally identifiable, and includes the categories of data outlined below;

b. in the case of Personal Data that we did not obtain directly from you, the source of that data;

c. the purposes for which we may process Personal Data; and

d. the legal bases of the processing.

2. In addition to the specific purposes for which we may process your Personal Data (stated below in this Section II):

a. We may process your Personal Data where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

b. We may process your Personal Data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

c. We may also process any of your Personal Data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

d. To provide, operate, and monitor our website, to provide customer support and respond to the requests you direct to us, to send you information or contact you about a product or Service you are using or that we believe may be of interest to you, to detect, prevent, and remedy technical issues, and for any other purposes with your consent.

B. Usage Data

1. We may process data about your use of our website and our products and Services (“Usage Data”). Usage Data may include your IP address, geographical location, referral source, length of visit, page views and website navigation paths, as well as information about the frequency of your use. Usage Data is collected automatically as you navigate through the website.

2. The sources of this Usage Data include, but may not be limited to:

a. Google Analytics, and primary tracking vendors we may use in the future;

b. WhatConverts;  

c.  The Karcher Group; and

d. ThomasNet.

3. This usage data may be processed for the purposes of analyzing the use of our website and our products and Services and for marketing purposes.

4. The legal basis for this processing is our legitimate interests, namely, monitoring our website and improving our products and Services.  Where our legitimate interests are not a sufficient legal basis, we will ask for your consent to use your Personal Data.

C. Profile Data

1. Profile data is the information in your personal profile on our website, which may include your name, address, telephone number, and email address.   

2. We may process your profile data for the purposes of permitting and monitoring your use of our website and so you can contact us to purchase products and Services.

3. The legal bases for this processing are: 

a. our legitimate interests, namely the proper administration of our website and the operation of our business, and

b. the performance of a contract between you and us, or our taking steps, at your request, to enter into such a contract.

Where our legitimate interests are not a sufficient legal basis, we will ask for your consent to use your Personal Data.

D. Service Data

1. Service data includes Personal Data provided in the course of the use of our products and Services. 

2. We may process service data for the purposes of administering our website, offering and providing our products and Services, ensuring the security of our website and products and Services, and communicating with you.

3. The legal bases for this processing are: 

a. our legitimate interests, namely the proper administration of our website and the operation of our business;

b. the performance of a contract between you and us, or our taking steps, at your request, to enter into such a contract.

E. Inquiry Data

1. We may process information contained in any inquiry you submit to us regarding our products or Services for the purposes of offering, marketing and selling relevant goods and/or products and Services to you.

2. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where this is not a sufficient legal basis, we will ask for your consent to use your inquiry data.

F. Notification Data

1. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“Notification Data”).

2. Notification Data may be processed for the purposes of sending you the relevant notifications or newsletters.

3. The legal basis for this processing is the performance of a contract between you and us, and/or our taking steps, at your request, to enter into such a contract.

G. Employment Data

1. Any information that you submit to Keller through the website to apply for a position or internship will be handled in the manner described in this Notice.  By submitting your information to apply for a job or internship, which includes any resume information, contact information, references, username and password, and other application information requested in the job posting or otherwise provided by you, you agree to such information being collected, used, processed, transferred and stored by Keller for the purposes of recruitment and evaluation of qualifications for employment or internship in furtherance of our need to process such information in the pre-employment phase of a possible employment relationship. If selected for a position or internship, such information may also be used for onboarding activities (which may include a background check).

H. Special Category Data or Sensitive Personal Information

1. In order to fulfill certain lawful purposes as outlined in this Notice, we may need to request “Special Category Data” or “Sensitive Personal Information” (together referred to as “Sensitive Information”). This type of data is a special type of Personal Data that, if used illegally, could create more significant risks to an individual’s fundamental rights and freedoms or cause harm to personal security. For example, an unauthorized disclosure of Sensitive Information may put individuals at risk of unlawful discrimination.

2. We may collect limited Sensitive Information when you apply for a job with us, which may include information about your racial or ethnic origin; religion or similar beliefs; sexual orientation or gender identity; financial data; political opinions; trade union membership; medical health-related information; and specific identity.

3. The legal basis for this processing is to comply with any applicable legal obligations, and otherwise with your express consent.

III. Providing Your Personal Data to Others

A. We may disclose your Personal Data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out–of–court procedure.

B. In addition to the specific disclosures of Personal Data set out in this Section III, we may disclose your Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.  We may also disclose your Personal Data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out–of–court proceeding.

C. We may disclose your Personal Data or other data to our subsidiaries and affiliates, and to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep data confidential and use it only for the purposes for which we disclose it to them.

D. We may disclose your Personal Data or other data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Keller’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Keller about our website and Services users is among the assets transferred.

E. We may disclose your information to enforce or apply our any agreements between us, including for billing and collection purposes.

F. We may disclose your information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Keller, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

G. We may disclose your information to fulfill the purpose for which you provide it.

H. We may disclose your information for any other purpose disclosed by us when you provide the information.

I. We may otherwise disclose your information to others with your consent.

IV. Refusing or Withdrawing Consent

A. Data Protection Laws that apply to you may let you refuse to consent to our proposed collection, use, or disclosure of your Personal Data. When we process your Personal Data as part of our relationship with you, such processing is generally based on legal grounds other than consent, such as our contractual obligations to you, our compliance with legal requirements, or our legitimate institutional interests (where allowed under applicable Data Protection Law), rather than on your consent.  However, if we have asked for consent, you have the right to withdraw consent at any time. If you withdraw consent, this does not affect the lawfulness of the processing before you withdrew consent. To withdraw consent, please contact us in writing using the information in Section XII below. However, if you withdraw your consent, we may not be able to adequately provide you with the assistance or Services you requested.

V. Failure to Provide Personal Data

A. If you do not provide certain Personal Data when requested, or if you withdraw your consent for us to process it, we may be unable to fulfill a contract we have with you (if applicable), respond to your requests, meet our legal obligations, or otherwise deliver our products or Services. In some cases, this may require us to stop providing a product or Services to you.

B. If we need specific Personal Data in order to provide a product or Service or to meet our obligations, we will inform you if your refusal to provide consent, where permitted under applicable Data Protection Laws, prevents us from doing so.

VI. Retaining and Deleting Personal Data

A. This Section VI states our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of Personal Data.

B. Personal Data that we process for any purpose shall not be kept for longer than is necessary for that purpose or those purposes.

C. We will retain your Personal Data only as long as the retention of such information is necessary in light of our legitimate interest or other lawful basis for using such Personal Data.

D. If the legal basis of collection is based solely on consent, we will delete your Personal Data once consent is withdrawn.

E. Notwithstanding the other provisions of this Section VI, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

VII. International Data Transfers

A. We are based in the United States of America. We may process, store, and transfer the Personal Data, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own, including the United States of America. In the event we transfer your Personal Data outside your country as part of our processing, we rely, where required, on appropriate or suitable safeguards or specific legal provisions permitting such transfers under applicable Data Protection Laws.

B. When transferring Personal Data from a country in the EEA or from the United Kingdom (UK) to a country outside such areas, we may base such transfers on contracts containing legally authorized data protection provisions under GDPR called Standard Contractual Clauses.

VIII. Automated Decision Making

A. Keller may use automated decision-making, including profiling, to assist in providing Services to you. For the purposes of the PIPL, “automated decision-making” refers to the use of computer programs to automatically analyze or assess individuals’ behaviors, habits, interests, or hobbies, or individuals’ financial, health, or credit status, etc. and then to make decisions based on the analysis of such information.

B. You will not be subject to a decision having a major influence on your rights and interests based solely on automated processing, including profiling, unless you explicitly consent. Keller does not use automated decision-making to assist with our employment process.

IX. Amendments

A. We may update this Notice from time to time by publishing a new version on our website.

B. You should check this page occasionally to ensure you are happy with any changes to this Notice.

C. We may notify you of significant changes to this Notice by email or other prominent notice. 

X. Your Rights- International

A. In this Section IX, we have summarized the most important rights that you may have under the applicable Data Protection Laws. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. If you are located in China and if you have questions, you have the right to ask that we explain Personal Data handling rules and policies to you.

B.. Your most important rights under the Data Protection Laws are:

1. The Right to be Informed. You have the right to be informed of our processing or handling activities.

2. The Right to Request Access. You have the right to access, update, or delete the information we have about you.

3. The Right to Rectification/Correction. You have the right to have any incomplete or inaccurate information we hold about you corrected.

4. The Right to Erasure (The “Right to be Forgotten”). In certain circumstances, you have the right to ask us to remove or delete your Personal Data. This right may not apply in all circumstances.

5. The Right to Object to Processing. You have the right to object to our processing of your Personal Data.

6. The Right to Restrict Processing. You have the right to request that we restrict the processing of your Personal Data.

7. The Right to Data Portability. Upon request, we will provide you (or a third party you have chosen) with the Personal Data we have collected about you. Your Personal Data will be provided in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the Personal Data to perform a contract with you.

8. The Right to Complain to a Supervisory Authority. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

9. The Right to Withdraw Consent. You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data.

C. You may exercise any of your rights in relation to your Personal Data by written notice to us using the contact form on our website. Please include your name, email address, and the specific type of request you would like to make. Please note that we may ask you to verify your identity before responding to such requests. We will respond to your written request without unreasonable delay and in accordance with any deadlines imposed by the Data Protection Laws that apply to you. Unless specific circumstances occur, we will not charge you any fee in connection with the exercising of your rights. If we are not able to honor any part of your request, we will notify you in our response as well as the reason we cannot do so.

D. We will comply with all such requests, provided there is not a legal exception to the request, we do not have a legitimate business interest for processing such Personal Data, or are not required to retain any such Personal Data pursuant to applicable law.

E. We do not discriminate against individuals who exercise their privacy rights.

If you are located in California, you may have additional rights related to your information. Please see our California Privacy Rights section below.

XI. Cookies

A. Generally

1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

B. How We May Use Cookies

1. We may use cookies for the following purposes:

a. Authentication – We may use cookies to identify you when you visit our website and as you navigate our website.  

b. Status – We may use cookies to help us to determine if you are logged into our website.

c. Personalization – We may use cookies to store information about your preferences and to personalize the website for you.

d. Analysis – We may use cookies to help us to analyze the use and performance of our website and products and Services. 

e. Cookie Consent. We may use cookies to store your preferences in relation to the use of cookies more generally.

f. Security – We may use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and products and Services generally.

g. Advertising – We may use cookies to help us to display advertisements that will be relevant to you.

C. Cookies Used by our Vendors

1. Our vendors may use cookies and those cookies may be stored on your computer when you visit our website. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

2. We use Google Analytics, WhatConverts, ThomasNet, and the Karchner Group to analyze the use of our website. These vendors gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy. WhatConverts’ privacy policy is available at: https://www.whatconverts.com/privacy/.  ThomasNet’s privacy policy is available at: https://www.thomasnet.com/privacy.html. The Karcher Group is available at: www.tkg.com.

3. We may also use other vendors who use cookies to gather information about website use by means of cookies, and use such information to create reports about the use of our website.  When we use other vendors for these purposes, we will provide a link to their privacy policies in an amendment to this Notice.

4. 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. You can also opt out of the collection and use of this information through tools like the Network Advertising Initiative opt-out page. 

D. Managing Cookies

1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary. You can however obtain up–to–date information about blocking and deleting cookies via these links:

a.             https://support.google.com/chrome/answer/95647 (Chrome)

b.             https://support.mozilla.org/en–US/kb/enable–and–disable–cookies–website–preferences (Firefox)

c.             https://support.microsoft.com/en–gb/help/17442/windows–internet–explorer–delete–manage–cookies (Internet Explorer)

d.             https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac (Safari)

2. Blocking all cookies will have a negative impact upon the usability and performance of many websites.

3. If you do not want us to collect information about you through the use of cookies or other technology, you can manage certain technologies and other cookies through our cookie consent manager (also called a cookie preference tool), which is available through the cookie banner and/or a persistent link or button on our website.

4.             If you block cookies, you may not be able to use all the features on our website.

XII. Information About Us

A. General Information

1. This website is owned and operated by Keller Technology Corporation, a New York corporation with its principal place of business located at 2320 Military Road, Tonawanda, NY 14150. 

2. You can contact us as follows:

a. Using our website contact form.

b. By mail, to:

Keller Technology Corporation

2320 Military Road

Tonawanda, NY 14150

Attention: Elizabeth Keller

c.             By email, using the email address stated on our website from time to time.

B.            Data Protection Officer

1.             Our Data Protection Officer’s contact details are:

Elizabeth Keller

Keller Technology Corporation

2320 Military Road

Tonawanda, NY 14150

California Privacy Right Section:

This California Consumer Privacy Section (“California Section”) supplements the information contained in the Privacy Notice and is adopted to comply with the California Consumer Privacy Act (including the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”) and applies solely to visitors, users, and individuals who reside in the State of California (“consumers”). Any terms or analogous terms defined under CCPA have the same meaning when used in this California Section. All other capitalized terms shall have the same meaning as those designated in the Privacy Notice. This California Section explains how Keller collects, uses, discloses and retains Personal Information (or Personal Data as defined in the Notice) and how consumers may exercise their rights under applicable CCPA.

WHAT INFORMATION IS COLLECTED 

Keller’s data collection practices include the collection and use of Personal Information as described in this Notice as set forth above. This California Section applies to our data practices both online and offline. Keller retains this information as set forth in Section VI of the Notice.

Generally, Keller collects the following categories of Personal Information:

• Identifiers, including contact information and biographic information;

• Commercial information;

• Internet or other similar network, browsing, or search activity; and

• Professional or employment-related information.

• Sensitive Personal Information as it relates to job applicants.

OUR PURPOSES FOR THE COLLECTION AND USE OF PERSONAL INFORMATION

Our collection of Personal Information is limited to business and commercial purposes as described below:

1. To perform our Services;

2. For execution of a contract or to enforce the terms and conditions arising under a contract (e.g., performing Services, maintaining the client relationship, keeping the client informed, invoicing and bill collection) or other agreements between the parties;

3. To perform client acceptance procedures, including verifying identities and addresses and performing other due diligence to protect our business interests and to determine eligibility for Services;

4. To comply with legal, tax, accounting, or regulatory obligations to which Keller or a third party is subject;

5. To manage risk and operations, legal obligations, including ensuring internal compliance with our policies and procedures, to respond to regulatory and government oversight applicable to Keller, and to investigate complaints or pursue and defend claims, proceedings, or disputes;

6. To protect the security and integrity of Keller’s information technology systems;

7. To provide information about and market relevant goods and/or products and Services offered by Keller, and opportunities and experiences offered by Keller;

8. To evaluate, develop and improve the quality of Keller’s Services or our Website and for other related internal business purposes;

9. To seek professional advice, such as from professional advisors (including, but not limited to, legal counsel);

10. For website related services, like analytics, insights, or customer support, quality and safety maintenance, or to develop new technological improvements;

11. For the evaluation and hiring of job applicants;

12. For the purpose of subscribing to our email notifications and/or newsletters, and sending you the relevant notifications and newsletters

13. To provide customer support and respond to the requests you direct to us

14. For other purposes that are compatible with this Privacy Notice or where permitted by applicable law; and

15. As otherwise disclosed upon collection, or to the extent a data subject provides other consent or authorization to the collection, use, disclosure and storage of Personal Information.

SOURCES OF COLLECTION OF PERSONAL INFORMATION 

We may collect Personal Information from the following sources:

• From your employer;

• Directly from you;

• From users of our website, both directly and through automatic means such as cookies;

• From certain affiliates, business partners or agents;

• If you provide us with information when contacting us, request information about our Services, or contact our customer service or support departments;

• Fraud prevention and detection agencies and organizations, including law enforcement; and

• From third party sources, including publicly available sources and governmental agencies and departments.

The chart below describes the categories of Personal Information collected in the previous twelve months and the business or commercial purposes for such collection. For more information about the exact identifiers we collect, please see our relevant Notice sections above. The numbers below align with the “Our Purposes for Collection and Use of Personal Information” section outlined above.

CATEGORIES OF THIRD PARTIES WITH WHOM WE DISCLOSE PERSONAL INFORMATION

We disclose the categories of Personal Information outlined above to affiliates, certain service providers or other third parties for business purposes, to provide our products and Services, or for other purposes as provided by applicable law. This includes to:

1. service providers for or to support business operations or provision of Services;

2. information technology, software, and cloud providers, security providers, and similar services in connection with providing services and in the support of daily operations;

3. service providers to develop, operate, and maintain our website;

4. service providers for marketing purposes; and

5. our employees, affiliated companies, contractors, agents and third-party vendors to perform services related to your account, to offer our products and services, and for business operations.

We may also have to disclose your information to:

1. government agencies or regulatory bodies to fulfill legal obligations;

2. a buyer, investor or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including potentially 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 or to third parties in connection with Keller’s acquisition of other entities;

3. law enforcement or government officials;

4. any other entity disclosed by Keller when you provide the information, or for which you provide authorization; or

5. third party fraud prevention and credit risk reduction companies and organizations.

“SELLING” OR “SHARING” OF PERSONAL INFORMATION

Keller does not sell or share Personal Information with third parties. We only make business purpose Personal Information disclosures as detailed above and pursuant to written contracts that describe the purpose of use, require the recipient to keep Personal Information confidential, and prohibit using the disclosed Personal Information for any purpose except performing the services for Keller.

CONSUMER RIGHTS UNDER CCPA

CCPA provides consumers with specific rights regarding their Personal Information. This section explains how those rights may be exercised.

California consumers have the following rights:

1. Consumers have the right to request to certain information about our collection and use of Personal Information (the “Right to Know”) or access to specific pieces of personal information (“Specific Request to Know”). Consumers may only submit two requests per a twelve-month period, beginning on the date of their first request.

2. Consumers have the right to request correction of inaccurate Personal Information (“Right to Correct”) maintained by Keller.

3. Consumers have the right to opt-out of the sale or sharing of Personal Information (“Right to Opt-Out”).

4. Consumers have the right to request deletion of Personal Information, subject to certain exceptions (the “Right to Delete”). Once we receive a request and confirm the consumer’s identity, we will review the request to determine if an exception allowing us to retain the information applies. We may deny a deletion request if retaining the Personal Information is necessary for us to:

1. • Complete the transaction(s) for which we collected the Personal Information including to provide services requested or otherwise to fulfill our contractual obligations; and/or

   • As otherwise allowed by CCPA.

We will not discriminate against consumers for exercising CCPA rights including refusing services or offering different pricing models.

HOW TO EXERCISE RIGHTS UNDER US CONSUMER PRIVACY LAWS

California consumers or authorized agents may exercise any of the rights enumerated above by contacting us using the email address stated on our website; by mail to 2320 Military Road, Tonawanda, NY 14150; calling us at (716) 261-2289 or (704) 228-2696, or via our online “contact us” web form. Please note that we may ask you to verify your identity before responding to such requests.

Authorized Agents: If you are making a request as an Authorized Agent, please submit the request on behalf of the individual and provide proof that the individual provided you signed permission to submit the request. We may also require that you confirm your identity by providing a driver’s license or other form of identification.  

Verification of Requests: When submitting a request under CCPA, we are required to reasonably validate or authenticate the requestor to appropriately secure Personal Information. If we cannot validate the requestor based on the information provided, we will notify the requestor that we are unable to fulfill the request. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it. We will confirm receipt of a request. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will detail why we made that decision and provide a cost estimate before completing the request.

CALIFORNIA’S SHINE THE LIGHT LAW

In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of Personal Information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received Personal Information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, see Section XII above.

“DO NOT TRACK” POLICY AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CalOPPA)

The Website does not respond to or support Do Not Track (“DNT”) signals. 

Do Not Track is a preference you can set in your web browser to inform websites you do not want to be tracked.  You can enable or disable DNT by visiting the preferences or settings page of your web browser.