Privacy Policy | Clipfinite

Last Updated: 29-Feb-2024

This Privacy Policy explains the information that Cass Works Inc. collects when you use its products and services, how that information is used, with whom it may be shared, and your privacy choices.

1. INTRODUCTION

Who we are and what we do

This Privacy Policy covers Cass Works Inc.. (collectively, “we” “us” or “our”). We provide Movies, eSports, cooking classes, games, ebooks and related services through our owned-and-operated websites, including clipfinite.com (the “Services”).

Acceptance and Changes

By registering for, downloading, or using our Services, you accept this Privacy Policy, which is part of our Terms & Conditions. We may modify this Privacy Policy from time to time. We will post any modified version of our Privacy Policy at this page and update the date.

2. CHILDREN'S PRIVACY

We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 18 years old or the age of majority in your jurisdiction, whichever is greater, to use our Services. If you are a parent or legal guardian who believes your child has provided personal information to us without your consent, you may ask us to delete such information by contacting us at [email protected].

3. DATA WE COLLECT ABOUT YOU

We collect information about you when you use our Services. In addition, third parties may collect information about you when you use our Services. Collected information may include or reflect personal information that could identify you, as well as non-personal information. We refer to your information as "your data" for short.

Account Information

To create an account, you must provide a valid email address and password.

Financial Information

To make a purchase, you may need to provide a valid payment method. Your payment information will be collected and processed by our authorized payment vendors. We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. If we allow purchase through a third-party platform, the payment method stored with the third-party platform will be charged.

Other Information You May Submit

You may submit data to us for limited purposes such as requesting customer support; participating in a study or survey; entering contests or sweepstakes; applying for a job; or signing up to receive communications from us or another user.

Automatically-Collected Information

We automatically collect certain types of data when you use our Services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our Services, you agree to our use of these methods as set forth in our Cookie Policy.

Physical Products

We collect your shipping address as part of your payment details.

Information Collected by Third Parties

Some third parties may collect data about you when you use our Services. This may include data you submit (such as payment information) or automatically-collected information (in the case of third-party analytics providers and advertising partners).
We may obtain data from third parties about you. We may combine that data with information that we have collected. For example, some advertisers or advertising platforms may allow us to determine what other online services you might use so that we may place relevant ads on those services.

4. HOW WE USE YOUR DATA

We may use your data for the following purposes:

Identification and authentication: We use your data to verify you when you access your account.
Operating our Services: We use your data to provide our Services, process and fulfill orders, provide customer support, and to otherwise comply with our contractual obligations to you. We (and/or our third-party vendors) use your financial information to process purchases made by you and to pay you amounts you have earned.
Communicating with you: We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
Improving our Services: We use your data to understand how our Services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).
Customizing your experience: We use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying videos that you might enjoy, based upon your viewing choices.
Marketing and advertising: We use your data to show you ads on third-party sites, and to measure the effectiveness of those ads.
Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our Services. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.
Legal compliance: We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.
Protecting your information: Where appropriate, we may anonymize, backup, and delete certain data.

We may use algorithms and other automated means to implement any of the above.
Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:

Performance of a contract;
Legitimate commercial interest;
Compliance with a legal obligation; or
Consent

If you require further information about the balancing test that we have undertaken to justify its reliance on legitimate interest as a lawful basis of processing, see Section 15 for information on how to contact us.

5. WITH WHOM WE SHARE YOUR DATA

We share data with third parties as follows:

With your consent: We may share your data with third parties where we have obtained your express consent to do so.
Authorized vendors: We may share your data with third-party vendors that help us operate our Services, process orders, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM) vendors.
Advertising: We may share your data with advertising companies to display relevant ads to you, and to measure the effectiveness of those ads.
Analytics: We may share your data with analytics providers which help us understand how customers are using our Services.
Affiliates and advisors: We may share your data with our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. We may share your data with our affiliates to the extent necessary to provide you with the services ordered.
Certain legal situations: We may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction as discussed in Section 6.
Aggregated or anonymized information: We may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.

We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share.

6. LEGAL AND SAFETY-RELATED DISCLOSURES

We may disclose your data in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) ("requests") that we receive from government authorities or parties to legal proceedings.

We may disclose user data where we reasonably believe that someone's life is at risk. For example, if we become aware of a person threatening to commit suicide, we may share that person's data with appropriate entities that may have the ability to help.

We may disclose user data to report suspected crimes.

We may disclose user data in situations involving legal claims against us or one of our users.

We may share your data with potential transaction partners, advisors, and others in the event our company is, in whole or part, acquired by a third party. In such case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.

7. DATA RETENTION

We retain your data for as long as you have an account. When you close an account, we will delete its content. We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; your address information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

8. YOUR PRIVACY CHOICES

We enable you to make numerous choices about your data:

You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.
You may change your account settings.
You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
You may limit the use of cookies. See our Cookie Policy for options.
You may close your account.

Users in certain jurisdictions may have additional rights. See Section 13.2 and 14 for more details.

9. COMMUNICATIONS FROM US

Emails
If you create an account, you may receive commercial emails from us. This includes newsletters and offers. You may always opt out from receiving commercial messages in your account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

10. PROTECTING YOUR INFORMATION

We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you to use a unique and hard-to-guess password for your account and to not share it with others. You should only grant access rights to people who you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.

11. YOUR RESPONSIBILITIES

You may receive other people's data in using our Services. If you receive information from other users, you must process that information in compliance with your published privacy policy and all applicable laws, including those concerning privacy, data security, and online marketing.

12. THIRD-PARTY SERVICES

We may provide access to online services that we do not own or operate via hyperlinks or integrations. These services fall outside of this Privacy Policy and we have no control over the data they collect. Once on a third-party site, your data may be collected by others. We encourage you to read our Third-Party Service Addendum and the privacy policies of such services before using them.

You may use our Services through third-party sites. For example, you may watch a video that is embedded on a third-party site or use one of our apps on a third-party platform. This Privacy Policy covers our apps and video players, but does not cover any third-party site or any third-party video player.

13. INTERNATIONAL DATA TRANSFERS AND CERTAIN USER RIGHTS

13.1 Location of Data

Cass Works Inc. is based in the United States of America. We provide services globally using computer systems, servers, and databases located in the U.S. and other countries. When you use our Services from outside of the U.S., your information may be transferred to and processed in the U.S.. Please note that U.S. data and privacy laws may not be as comprehensive as those in your country. Residents of certain countries may be subject to additional protections as set forth in Sections 13.2 and 14 below.

13.2 GDPR (EEA and UK Users)

This Section 13.2 applies only to natural persons residing in the European Economic Area and the United Kingdom (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is our policy to comply with the EEA's General Data Protection Regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the U.S. (or other countries) based upon the following legal bases:

Legitimate business interests: We could not provide our Services or comply with our legal obligations without transferring your personal information to the U.S.
Our use of Standard Contractual Clauses (also known as "Model Clauses") where appropriate.

You have the right to: opt out of non-essential cookies (see our Cookie Policy); access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents. We enable exercise of these rights primarily through our Services(which we reserve the right to modify). For example, we allow users to change their information, download their videos, and close their accounts. We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests chargeless unless they would impose an unreasonable cost on us.

If you have a request, complaint or inquiry, please contact our Data Protection Officer at the address listed in Section 15. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

14. U.S. STATE PRIVACY DISCLOSURES AND CONSUMER RIGHTS

This is our U.S. State Privacy Notice (the “Notice”) which applies to “Consumers” as defined under the California Consumer Privacy Act (the “CCPA”), the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, Connecticut’s Act Concerning Personal Data Privacy, and Online Monitoring, Chapter 603A of the Nevada Revised Statutes, and all laws implementing, supplementing or amending the foregoing, including regulations promulgated thereunder (collectively, “U.S. Privacy Laws”). In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to Consumers and their rights under the applicable state privacy law. Capitalized terms used but not defined below will have the meanings given to them in our Privacy Policy.

This Notice does not apply to data that is not treated as personal information or personal data under U.S. Privacy Laws or to the extent the data is subject to an exemption under U.S. Privacy Laws. This Notice also does not apply to information collected by third-party content, websites, applications, platform, code (e.g., plug-ins, application programming interfaces, and software development kits), and certain cookies and other tracking technologies.

14.1. Data Practices

The description of our data practices in this Notice covers the twelve (12) months prior to the “Last Updated” date and will be updated at least annually. This Notice also applies to our current data practices such that it is also meant to provide you with “notice at collection.” For any new or substantially different processing activities not described in this Notice, we will notify you as required by U.S. Privacy Laws, including by either providing additional information at the point of collection, or by updating this Notice.

Collection, Use, & Disclosures

In general, we collect, retain, use, and disclose your personal information and/or data (defined hereafter as “PI”) (including the categories of PI shown in the table below) in order to provide our services and operate our business, which include both the business purposes and commercial purposes described in our Privacy Policy, including in the “How We Use Your Data” section (collectively, “Processing Purposes”). This may include disclosing or otherwise making PI available to our vendors that perform services for us, such as those authorized vendors described in “With Whom We Share Your Data” (including “Service Providers” and “Processors” defined under U.S. Privacy Laws) (“Vendors”).

Our business purposes also include the disclosure of PI to certain recipients, such as:

Vendors in furtherance of the Processing Purposes.
You, or other parties at your direction or through your intentional action.
Assignees as part of a Business Transaction (defined below) where another party assumes control over all or part of our business.
The government or private parties to comply with law or legal process.
In addition, our Vendors and the other recipients listed in the below table may, subject to contractual restrictions imposed by us and/or legal obligations, also use and disclose your PI for business purposes. For example, our Vendors and the other categories of recipients listed in the table below may engage subcontractors to enable them to perform services for us or process for our business purposes.

Some of the Processing Purposes, as we discuss in the table below, implicate “Sale,” “Sharing,” and or “Targeted advertising.” For more details on the meaning of Sale, Sharing, and Targeted Advertising, and how to opt-out of them, please visit the Do Not Sell/Share/Target section below.

The table below outlines the categories of PI (including examples) and categories of recipients also corresponding to each category of PI. The right column states the categories of recipients that receive those specific categories of PI and Sensitive PI as part of disclosures for business purposes, as well as disclosures which may be considered a Sale or Sharing under certain U.S. Privacy Laws:

Category of PI	Categories of Recipients
Identifiers (such as account name, email address, IP address, cookie ID)	Disclosures for business purposes: Software and other business Vendors (“Business Vendors”) Marketing Vendors Subsidiaries and affiliates (“Affiliates and Related Entities”) Sale/Sharing: Third-Party Digital Businesses
Personal Records (such as address, contact information, payment card information)	Disclosures for business purposes: Business Vendors Marketing Vendors Fraud prevention partners Affiliates and related entities Sale/Sharing: Third-Party Digital Businesses
Personal Characteristics or Traits (such as pronouns)	Disclosures for business purposes: Business Vendors Marketing Vendors Fraud prevention partners Affiliates and related entities Sale/Sharing: N/A
Transaction / Commercial Information (such as products or services used, purchased, or considered; and other purchasing or consuming histories or tendencies)	Disclosures for business purposes: Business Vendors Marketing Vendors Affiliates and related entities Sale/Sharing: Third-Party Digital Businesses
Internet Usage Information (such as search, browsing history, and other interactions with the Service)	Disclosures for business purposes: Business Vendors Marketing Vendors Affiliates and Related Entities Sale/Sharing: Third-Party Digital Businesses
Location Data (such as where you enable location-based features on your device, or where we may infer your rough location (such as zip code) based on IP address as part of the Service)	Disclosures for business purposes: Business Vendors Marketing Vendors Affiliates and Related Entities Sale/Sharing: Third-Party Digital Businesses
Audiovisual and Similar Information (such as customer service and sales call recordings)	Disclosures for business purposes: Business Vendors Marketing Vendors Affiliates and Related Entities Sale/Sharing: N/A
Inferences from PI Collected (Inferences we make about you or your interests using PI we have collected)	Disclosures for business purposes: Business Vendors Marketing Vendors Affiliates and Related Entities Sale/Sharing: Third-Party Digital Businesses
Account Information and Password* (we store your account log-in in combination with a password in our systems)	Disclosures for business purposes: Business Vendors Affiliates and Related Entities Sale/Sharing: N/A
Communication Content* (such as when you send messages to our Customer support)	Disclosures for business purposes: Business Vendors Affiliates and Related Entities Sale/Sharing: N/A

*considered Sensitive PI or Sensitive Data under certain of the U.S. Privacy Laws, which we refer to in this Notice as “Sensitive PI”
We also reserve the right to disclose and transfer all such information in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, and during the course of any due diligence process (collectively, “Business Transactions”).

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI, and we may elect not to treat publicly available information as PI.

Processing Purposes Implicating Sale, Sharing, Targeted Advertising, and Profiling
When you provide us PI for the following Processing Purposes, we may use and disclose certain PI that you provide for such purposes in a way that may constitute Selling and/or Sharing, as well as Processing of your PI for purposes of Targeted Advertising.

Operating our services
For purposes disclosed at the time you provide your PI
For our legitimate business purposes that are compatible with the purpose of collecting your PI and that are not prohibited by law

Processing Purposes that may implicate Selling and/or Sharing, as well as Processing of your PI for Targeted Advertising include the following:

Customizing your experience
Marketing and advertising
For purposes disclosed at the time you provide your PI
For our legitimate business purposes that are compatible with the purpose of collecting your PI and that are not prohibited by law

Sources

We collect PI directly from you or your device, Vendors, Third-Party Digital Businesses, our Affiliates and Related Entities, and other third parties.

Retention

Because there are so many different types of PI in each category, and various use cases for different types of data, we are unable to provide data retention ranges based on categories of PI in a way that would be meaningful and transparent to you. Actual retention periods depend upon how long we have a legitimate purpose for the retention consistent with the collection purposes and applicable law. For instance, we may maintain business records for so long as relevant to our business, and may have a legal obligation to hold PI for so long as potentially relevant to prospective or actual litigation or government investigation. We apply the same criteria for determining if we have a legitimate purpose for retaining your PI that you ask us to delete. If you make a deletion request, we will conduct a review of your PI to confirm if legitimate ongoing retention purposes exist, will limit the retention to such purposes for so long as the purpose continues, and will respond to you with information on any retention purposes on which we rely for not deleting your PI. For more information on deletion requests see the Right to Delete section.

14.2. Consumer Rights

We provide Consumers (users who are residents of certain states, as defined above) the privacy rights described in this section. For residents of states without Consumer privacy rights, we will consider requests but reserve the right to apply discretion in how we process such requests.

Making a Request and Scope of Requests

Any request you submit to us is subject to an identity verification process (“Verifiable Consumer Request”) as described in the Verifying Your Request section below.
To make a request, other than a Do Not Sell/Share/Target request, please submit your request to us by email at [email protected]
For instructions on how to submit a Do Not Sell/Share/Target request, please go to the Do Not Sell/Share/Target section below.
Some information we maintain about Consumers that is technically considered PI may nonetheless not be sufficiently associated with information that you provide when making your request. For example, if you provide your name and email address when making a request, we may be unable to associate that information with certain data collection on the Service such as clickstream data tied only to a pseudonymous browser ID. Where we are unable to associate such information with the information you provide, we are therefore unable to associate such information with you and cannot include such information in response to those requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify PI that we collect, process, store, disclose, and otherwise use and to respond to your privacy requests. We will typically not charge a fee to fully respond to your requests; in some circumstances, the U.S. Privacy Laws permit us to, and we may, charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or if we decide to refuse it, we will give you notice explaining why we made that decision in our response to you. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

Verifying Your Request

When you make a request, we will verify that you are the person you say you are, or, if you are seeking information on behalf of another person, that you are authorized to make the request on their behalf (see our “Authorizing an Agent” section immediately below). In addition, we will compare the information you have provided to ensure that we maintain PI about you in our systems. As an initial matter, we ask that you provide us with, at a minimum, full name and email address. Depending on the nature of the request and whether we have the email address you have provided in our systems, we may request further information from you in order to verify that you are the Consumer making the request. We will review the information provided as part of your request, and may ask you to provide additional information via e-mail or other means to complete the verification process. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correction request unless you have provided sufficient information for us to reasonably verify you are the Consumer that is the subject of the request. The same verification process does not apply to opt-outs of Sale or Sharing, or limitation of Sensitive PI requests, but we may apply authentication measures if we suspect fraud (such as verifying access to the email provided when making the request).

The verification standards we are required to apply for each type of request vary. We verify your categories requests and certain deletion and correction requests (e.g., those that are less sensitive in nature) to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. For certain deletion and correction requests (such as those that relate to PI that is more sensitive in nature) and for specific pieces requests, we apply a verification standard of reasonably high degree of certainty. This standard includes matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you, and may include obtaining a signed declaration from you, under penalty of perjury, that you are the individual whose PI is the subject of the request.

If we cannot verify you in respect of certain requests, such as if you do not provide the requested information, we will still take certain action as required by certain U.S. Privacy Laws. For example, if you are a California Consumer:

If we cannot verify your deletion request, we will refer you to this Notice for a general description of our data practices.
If we cannot verify your specific piece request, we will treat it as a category request.

Authorizing an Agent

You may designate an authorized agent to submit your Consumer request on your behalf. An authorized agent submitting a request on your behalf must have sufficient evidence that you have authorized that person to submit the request on your behalf, which may include, at a minimum, evidence of signed permission to submit the request and, as permitted under the U.S. Privacy Laws, we also may require the Consumer to either verify their own identity or directly confirm with us that they provided the agent permission to submit the request.

Your Consumer Privacy Rights

Under the applicable U.S. Privacy Laws, Consumers have the following rights, which can be exercised directly or, in certain cases, through an authorized agent:

i. Right to Limit Sensitive PI Processing

You may, depending on your state of residency, have the right to direct businesses to limit their use and disclosure of Sensitive PI if we use or disclose it beyond certain internal business purposes. Where applicable, we will treat such a request as a revocation of any consent that you may have provided to your processing of Sensitive PI.

ii. Right to Know

Categories: If you are a California resident, you have the right to request that we provide certain information to you about our collection, use, and disclosure of your PI over the 12-month period prior to the request date related to categories of PI. You can request that we confirm whether we are processing your personal information, and disclose to you: (1) the categories of PI we collected about you; (2) the categories of sources for the PI; (3) our business or commercial purpose for collecting or selling that PI; (4) a list of the categories of PI disclosed for a business purpose in the prior 12 months and, for each category of PI, the categories of recipients; and (5) a list of the categories of PI sold or shared about you in the prior 12 months and, for each, the categories of recipients

Specific Pieces: You have the right to request a transportable copy of the specific pieces of PI we collected about you. In some states, such as California, this includes the right to PI collected in the 12-month period preceding your request. Please note that PI is retained by us for various time periods, so there may be certain information that we have collected about you that we do not retain for 12 months (and thus, it would not be able to be included in our response to you). Based on your state of residence, we may apply a limit on the number of “right to know” requests you make over a particular time period, as permitted under U.S. Privacy Laws.

iii. Right to Confirm

You have the right to confirm if we are processing your PI and to access your PI, as just stated in the two immediately prior paragraphs.

iv. Right to Delete

You have the right to request that we delete some or all of the PI that we have about you. Deleting all data will typically require the deletion of your account, along with all content. After we confirm that your deletion request is a Verifiable Consumer Request, subject to permitted retention exceptions, we will carry out one or more of the following: (i) permanently erase your PI on our existing systems with the exception of archived or back-up systems, (ii) de-identify your PI, or (iii) aggregate your PI with other information. Where legal exceptions will apply to your request for deletion, we will tell you which one(s) and will limit retention to the permitted purpose(s) under U.S. Privacy Laws.

v. Right to Correct

You have the right to request that we correct inaccuracies that you find in your PI maintained by us.

vi. Do Not Sell/Share/Target

Under the various U.S. Privacy Laws, Consumers have the right to opt-out of certain processing activities. California and certain other states have opt-outs specific to Targeted Advertising activities - which California’s law refers to as “cross-context behavioral advertising,” and others simply as Targeted Advertising - which involve the use of PI from different businesses or services to target advertisements to you. California provides Consumers the right to opt-out of Sharing, which includes providing or making available PI to third parties for such Targeted Advertising activities, while other states provide Consumers the right to opt-out from processing PI for Targeted Advertising more broadly. There are broad and differing concepts of the Sale of PI under the various U.S. State Privacy Laws, all of which, at a minimum, require providing or otherwise making available PI to a third party.

“Third-Party Digital Businesses” are third-party business partners, including social media platforms and other tech companies that offer digital advertising services, which may operate tracking technologies that collect PI about you on our Services (“cookie PI”), or otherwise collect and process PI that we make available about you, including digital activity information and traditional PI such as email address (“non-cookie PI”). We will treat PI collected by Third-Party Digital Businesses as implicating Sale, Sharing, and/or processing for Targeted Advertising where required, and accordingly apply opt-out requests that you make to such activities, as we describe in further detail below.

When you opt-out pursuant to the instructions below, it will have the effect of opting you out of Sale, Sharing, and processing of your PI for Targeted Advertising, such that our opt-out process is intended to combine all of these state opt-outs into a single opt-out. Please note that there are distinct instructions for opting out of cookie PI and non-cookie PI, which we explain further, below.

Opt-out for non-cookie PI: If you would like to submit a request to opt-out of our processing of your non-cookie PI (e.g., your email address) for Targeted Advertising, or opt-out of the Sale or Sharing of such data you need to send your request to [email protected]

Opt-out for cookie PI: If you would like to submit a request to opt-out of our processing of your cookie-related PI for Targeted Advertising, or opt-out of the sale/sharing of such PI, you can exercise an opt-out request. You must exercise your preferences on each of our websites you visit, from each browser you use, and on each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again.

Some U.S. Privacy Laws require us to state that we do not knowingly Sell or Share the PI of Consumers under the age of 16.

Automated Decision Making and Profiling
We may engage in processing that constitutes automated decision-making or profiling under the CCPA. However, as of the Last Updated date, the definitions of these concepts, and any associated opt-out and access rights have not been added to the updated regulations of the CCPA.

We do not believe we carry out profiling in furtherance of decisions that produce legal or similarly significant effects. If we change our practices, we will change this policy and provide you with the right to opt out of such activities as required by the applicable U.S. Privacy Laws, subject to any applicable exceptions.

vii. Right to Non-Discrimination

You have the right not to receive discriminatory treatment, in a manner prohibited by U.S. Privacy Laws, for the exercise of your privacy rights.

viii. Right to Appeal

Residents of certain states have the right to appeal a decision regarding a privacy request. You can exercise this right by responding to the email we send containing our response to your request, and following the instructions in such email. As of the Last Updated date, residents of Colorado, Connecticut, and Virginia have this right.

14.3. Additional Notices for California Residents

Shine the Light Law

Under California’s “Shine the Light” law, California residents have the right to opt out of disclosing information to third parties for the purpose of allowing such third parties to directly market their products and services. At this time, we do not engage in this type of disclosure.

California Minors

Although our online service(s) are intended for an audience over the age of 18, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us at [email protected], detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

14.4. Additional Notices for Nevada Residents

Nevada residents have the right to opt out of the sale of certain "covered information" collected by operators of websites or online services. We currently do not sell covered information, as "sale" is defined by such law, and we don't have plans to sell this information. However, if you would like to opt out of the future sale of personal information covered by the Act, you can provide us with your name and email address at [email protected]. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our plans change. At that time, we will create a process for verifying your identity and providing an opportunity to verified consumers to complete their opt-out.

15. HOW TO CONTACT US

For any questions, inquiries, or complaints relating to your privacy, please contact us at:

[email protected]