What Personal Data Do We Receive?

Personal data is any information from or about an identified or identifiable person, including information that Oplign can associate with an individual person. We may collect, or process on behalf of our customers, the following categories of personal data when you use or interact with Oplign products and services:

• Account Information: Information associated with an account that licenses Oplign products and services, which may include administrator name, contact information, account ID, billing and transaction information, and account plan information.
• Profile and Participant Information: Information associated with the Oplign profile of a user who uses Oplign products and services under a licensed account, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the user and/or their account owner.
• Contact Information: Contact information added by accounts and/or their users to create contact lists on Oplign products and services.
• Communications with Oplign: Information about, and contents of, your communications with Oplign, including relating to support questions, website virtual chats, your account, and other inquiries.

How Do We Use Personal Data?

Oplign employees do not access or use Customer data aside from daily quality control checks, and other support as required. Under no circumstance is Customer jobs data considered sensitive information.

As discussed below, Oplign uses personal data to conduct the following activities:

• Provide Oplign Products and Services: To provide and develop products and services to account owners, their licensed end users, and those they invite to join meetings and webinars hosted on their accounts, including to customize Oplign products and services and recommendations for accounts or their users. Oplign also uses personal data to determine what products and services may be available in your location, and uses personal data, including contact information, to route invitations, messages, or Oplign Emails to recipients when users send or receive invitations, messages, or Oplign Emails using Oplign products and services. This may also include using personal data for customer support at the direction of the account owner or their users. We also use personal data to manage our relationships and contracts with account owners and others, including billing, compliance with contractual obligations, and related administration.
• Product Research and Development: If authorized by any applicable customer settings, to develop, test, and improve Oplign products and services, and to troubleshoot products and services. Oplign does not use any of your communications to train Oplign.
• Marketing and Promotions: Oplign hates the internet marketing model, and will not sell your information to third-parties for any reason.
• Authentication, Integrity, Security, and Safety:  To authenticate accounts and activity, detect, investigate, and prevent malicious conduct, fraudulent activity or unsafe experiences, address security threats, protect public safety, and secure Oplign products and services.
• Communicate with You: We use personal data (including contact information) to communicate with you about Oplign products and services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us.
• Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, protect you, us, and others from fraudulent, malicious, deceptive, abusive, or unlawful activities, and to enforce or investigate potential violations of our Terms of Service or policies.

How Do We Share Personal Data?

Oplign provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

• Resellers: If an account owner licensed or purchased Oplign products and services from a third-party reseller of Oplign products and services, the reseller may be able to access personal data and content for users, including meetings, webinars, and messages hosted by the account owner.
• Vendors: Oplign works with third-party service providers to provide, support, and improve Oplign products and services and technical infrastructure, and for business services such as payment processing, including in relation to purchases made through the Oplign App Marketplace. Oplign may also work with third-party service providers to provide advertisements and business analytics regarding Oplign products and services. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Oplign or as required by law. Oplign may integrate third-party technology to provide advanced features, such as Apple's TrueDepth technology, to process information on your device about your face or hand dimensions and gestures to provide video effects. This information is processed on your device, and such information is neither received nor stored by either the third party, or Oplign.
• For Legal Reasons: Oplign may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers' rights and property; and (6) resolve disputes and enforce agreements.
• Marketing, Advertising, and Analytics Partners: Oplign uses third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using Oplign products and services, including our website; and to provide advertising and marketing for Oplign products and services, including targeted advertising based on your use of our website. These third-party partners may receive information about your activities on Oplign's website through third-party cookies placed on Oplign's website. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool, available in Cookies Settings. Where required by law, Oplign will first obtain your consent before engaging in the marketing or advertising activities described.
• Corporate Affiliates: Oplign shares personal information with corporate affiliates, such as Oplign Voice Communications, Inc., to provide integrated and consistent experiences across Oplign products and services (such as enabling an account owner or their user to integrate a Oplign Phone call into a meeting) and to detect, investigate, and prevent fraud, abuse, and threats to public safety.
• Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Oplign's business or assets, including in connection with bankruptcy or similar proceedings.
• Third-Party Developers: If you purchase a third-party app or integration from the Oplign App Marketplace, Oplign may share information about the purchase with the third-party developer, to provide the app or integration.

Who Can See, Share, and Process My Personal Data When I Join Meetings and Use Other Oplign Products and Services?

When you send messages or join meetings and webinars on Oplign, other people and organizations, including third parties outside the meeting, webinar, or message, may be able to see content and information that you share:

• Account Owner: An account owner is the organization or individual that signs up for a Oplign account. Typically, an account owner designates one or more people (called an 'administrator') to manage their account and can grant privileges to users on the account. Depending on their license with Oplign, the account owner can authorize additional users on their account, and the account owner can create and/or access the profile information for all users on their account. The account owner and their users can invite others (including guests not on their account and unlicensed participants) to meetings or webinars hosted on their account. Oplign gives account owners controls and features that they can use to determine whether certain types of content, such as recordings or Oplign Team Chat messages, can be created or sent, and what third-party apps can be used, for meetings and webinars hosted on their account. Depending on their settings, account owners and the users they designate can access personal data for participants who join meetings and webinars on their account or send messages to users on their account. Account owners may also be able to determine what information Oplign and others can access and use. Specifically, account owners may have access to:
• Account Usage:
• Product Usage:  Information about how users and their devices interact with their account, which may include who sent messages to their users in chat, email addresses, IP addresses, device information, and other information about who joined meetings or webinars on their account, whether their users viewed or downloaded a recording, how long participants participated in their meetings, the time a message was sent, information about Oplign Phone integrations, and other usage information and feedback metrics.
• Participant List: Information about the participants in a Oplign meeting, webinar, or chat, which may include name, display name, email address, phone number, and participant or user ID.
• Registration Information: Information provided during registration for a webinar, meeting, Oplign Room, or recording hosted by the account.
• Oplign Team Chat and Out-of-Meeting Collaborations: If enabled on their account, account owners and those they authorize can see information about who sent and received Oplign Team Chat messages, including synced in-meeting messages (e.g., from a dedicated meeting group chat that is synced with Oplign Team Chat), to users on their account, along with information about the message (for example, date and time, and number of members or participants). Depending on their settings, account owners also can see sender and receiver information, and other messaging data, along with the content of messages sent to and from users on their account (including from in-meeting chat where dedicated meeting group chats are enabled), unless the account owner has enabled Advanced Chat Encryption. Depending on their settings, account owners and those they authorize may also see the content shared through collaborative features, including whiteboards, files, and images shared in Oplign Team Chat.
• In-Meeting/Webinar Messages:  Depending on their settings, account owners can see sender and receiver information, along with the content of messages sent to and from users on their account, in the following circumstances:
• Messages sent to Everyone in a meeting that is recorded
• Messages sent to the meeting group chat in a meeting when a dedicated meeting group chat is enabled
• Messages sent to panelists in a webinar that is recorded
• Messages sent in dedicated meeting group chats in Team Chat
• Direct messages if the account owner has enabled archiving
• If a participant in a meeting is subject to archiving, their account owner will have access to messages sent to Everyone in the meeting, as well as direct messages sent to that participant. If a participant who is a member of a dedicated meeting group chat is subject to archiving, the member's account owner will have access to the meeting group chat messages, as well as direct messages sent to that member. If a guest in a meeting with a dedicated meeting group chat is subject to archiving, the guest's account owner will have access to messages sent to the meeting group chat, as well as direct messages sent to that guest.
• Recordings: Account owners can watch the content of recordings of meetings and webinars hosted on their account. They can also view, share, and enable advanced features for transcripts of meeting audio.
• Polling, Q&A, and Feedback: Account owners can see information about who provided responses to their polls, Q&A, or post meeting or webinar feedback requests, including name and contact information, together with the responses or feedback, unless responses are submitted anonymously.
• Oplign Email and Oplign Calendar Content: Depending on their settings, account owners, and designated account administrators, can access email and calendar content sent to and from users on their Oplign Email or Oplign Calendar accounts, even if those Oplign Emails are encrypted.
• Meeting Hosts, Participants, and Invitees: Meeting hosts, participants, and invitees may be able to see your email, display name, profile picture, and presence status, including in Oplign meetings and in Oplign's native calendar service. Meeting hosts, participants, and invitees can also see and (depending on the account owner's settings) record, save, and share meeting content, audio transcripts, messages sent to Everyone, messages sent to meeting group chats (where enabled, and whether sent in Team Chat or in-meeting), or messages sent to them directly, and files, whiteboards or other information shared with them (including during a meeting, or through a dedicated meeting group chat). Meeting hosts may also share chat transcripts to Oplign Team Chat, depending on their account owner's settings. Meeting hosts may also be able to see responses to Q&A and polls generated during the meeting.
• Oplign Email, Calendar and Oplign Team Chat Recipients: Recipients of Oplign Emails and Oplign Calendar invites can see, save, and share your email and calendar content with others, including by sharing emails to Oplign Team Chat. If a recipient shares encrypted content with others, for example, by sharing an encrypted Oplign Email to Oplign Team Chat, or forwarding an encrypted Oplign Email to a third-party recipient without a Oplign Email account, the shared or forwarded content will not be end-to-end encrypted by Oplign. Those with access to your device and login credentials may be able to see, save and share your email and calendar contents on that device. Recipients of Oplign Team Chats can see your messages, reactions, emojis, and related content, including content from Oplign Emails, Oplign Calendar, and emails from third-party services integrated in the Oplign client, that you or a third-party choose to share to Oplign Team Chat, and in-meeting messages that participants send that are synced with Oplign Team Chat through dedicated meeting group chats. Depending on the account owner's settings, Oplign Team Chat recipients may record, save, or share your messages.
• Webinar Panelists and Attendees: Only panelists may be visible to attendees during a webinar, but attendees who agree to unmute can be heard by other attendees. If an attendee agrees to become a panelist during a webinar, they may be visible to other attendees, depending on settings. Panelists and attendees may be able to see the name of a participant who asks a question during a Q&A, along with their question, unless the participant submits the question anonymously.
• Livestreams: Meeting and webinar hosts can choose to livestream to a third-party site or service, which means anyone with access to the livestream will be able to see the meeting or webinar.
• Apps and Integrations:  
• Account owners can choose to add Oplign-developed apps and third-party apps to their account and the Oplign products they use, including via use of the Oplign App Marketplace, and they can also control whether their users can add and use specific Oplign and third-party apps, including in meetings, webinars, and chats hosted on their account.
• Account owners can also choose to integrate other content from third-party services' such as third-party email communications on their corporate account ' to apps and services that they use, such as Oplign Revenue Accelerator (that provides insights and business analytics related to businesses when they use Oplign products). Further, account owners may choose to have Oplign analyze the meeting's audio recording to distinguish one speaker from another in order to create an accurate transcript. The audio analysis is not retained after the transcript is generated.
• Depending on their settings, account owners', users' and guests' personal data and content may be shared with apps and integrations, including Oplign-developed apps, approved by account owners, which may include all of the personal data categories listed above, such as account information, profile and contact information, registration information, participants list, settings, content, product usage, device information, or third-party emails that have been shared with the app.
• Other participants in the meeting may be able to see the app that you are using in a meeting, if the app is receiving content (including audio and video) from the meeting.
• Third-party developers may also integrate or embed Oplign meetings into their website or app experiences or build versions of Oplign that enable access to Oplign products from a third-party app.
• Personal information shared by account owners and users with third-party apps and integrations is collected and processed in accordance with the app developers' terms and privacy policies, not Oplign's.

Privacy Rights and Choices

Marketing Communications
If you don't want to learn about products and services we or our partners offer, you can opt-out of marketing communications in the communication sent to you (for example, via email or SMS), or by emailing privacy@Oplign.us. Not all of our communications are for marketing, and you'll continue to receive messages related to your products and services, such as bills, transactional notices, or customer service.

Data Rights
If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California or another U.S. state with an applicable privacy law, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:

• Inform you of what personal data we have about you that is under our control;
• Amend or correct such personal data or any previous privacy preferences you selected, or direct you to
  applicable tools; and/or
• Delete such personal data or direct you to applicable tools.

In order to exercise any of your rights as to personal data controlled by Oplign, please click here. Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

Children

Oplign does not allow children under the age of 16 to sign up for a Oplign account.

For educational organizations that use Oplign products and services to provide educational services to children under 18, Oplign's Children's Educational Privacy Statement is available here.

How to Contact Us

If you have any privacy-related questions or comments related to this Privacy Statement, please send an email to info@oplign.com.

You can also contact us by writing to the following address:

Oplign, LLC
Attention: Data Privacy
500 E. Main St., Suite 1600
Norfolk, VA 23510

You can contact our Data Protection Officer by sending an email to info@oplign.com.

Retention

We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.

The criteria used to determine our retention periods include the following:

• The length of time we have an ongoing relationship with you and provide Oplign products and services to you (for example, for as long as you have an account with us or keep using our products);
• Whether account owners modify or their users delete information through their accounts;
• Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

European Data Protection Specific Information

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

• Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or 'port' that data to another provider;
• Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
• Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

To exercise your rights, please click here. If you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Oplign processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

• As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Oplign products and services, features and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services;
• Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available Cookies Settings;
• As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity ('fraud and abuse detection') and compliance with privacy laws;
• To protect your vital interests or those of others :We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
• As necessary for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the products and services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the products and services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.

International Data Transfers

Oplign operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where Oplign or its service providers have customers or facilities ' including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.

Therefore, by using Oplign products and services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission's standard contractual clauses. Please contact us if you would like further information in that respect.

California & Other U.S. States Notice at Collection

Categories of Personal Information Oplign Receives: Oplign may collect, or process on behalf of our customers, the following categories of personal data, as described above, in the 'What Personal Data Do We Receive?' section: identifiers (such as in Account Information, Profile and Participant Information, Contact Information, and Registration Information), financial account information (such as in Account Information); commercial information (such as in Account Information); internet or other electronic network activity information (such as Device Information, Usage Information Regarding Meetings, Webinars, Message, Collaborative Features, and the Website, and Limited Information from Oplign Email and Calendar Services); audio, electronic, and visual information (such as in Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features) education information such as from university customers; inferences we derive from the preceding or other information we collect; and sensitive personal information (such as certain categories in Account Information, Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features.

Sources: We receive information from sources as described in the 'What Personal Data Do We Receive?' section, including: from you (including through your use of our products and services); from partners; from customers; and from publicly available sources. We collect education information from schools that use our services. Please see our Children's Educational Privacy Statement for more information.

Oplign's business and commercial purposes for use: Oplign uses personal data for the following business and commercial purposes: to provide Oplign Products and Services; for Product Research and Development; for Marketing and Promotions (Oplign does not use meeting, webinar, or messaging content, or any content generated or shared as part of other collaborative features for any marketing or promotions); Authentication, Integrity, Security, and Safety; to Communicate with You; and for Legal Reasons. For more information, please see 'How We Share Personal Data?' Categories of third parties to whom we disclose Personal Information for business purposes are described in 'How We Share Personal Data?'

Oplign may permit advertising and analytics services that are intended to deliver advertising to you and/or analyze your interactions, based on your interactions with our website or app which may constitute a 'sale' or 'sharing' of data for targeted advertising purposes under certain state privacy laws. See 'California & Other U.S. State Privacy Rights' for more information regarding your right to opt-out.

Retention: Oplign retains personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under Retention, above.

California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:

• Access the categories and specific pieces of personal data Oplign has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Oplign has shared personal data, and obtain the personal data in a portable and, to the extent technically feasible, readily usable format;
• Delete personal data under certain circumstances;
• Correct personal data under certain circumstances; and
• Opt out of the 'sale' of personal data or 'sharing' of personal data for targeted advertising purposes. We do not sell your personal data in the conventional sense. However, like many companies, we may use advertising and analytics services that are intended to analyze your interactions with our website or app, based on information obtained from cookies or other trackers, including for delivering advertising to you (such as interest-based, targeted, or cross-context behavioral advertising). You can get more information and opt out of the use of cookies and other trackers on our website and app by clicking the Cookies SettingsYour Privacy Choices link, also on our homepage, and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings. California and Connecticut residents may also set the Global Privacy Control (GPC) to opt out of the 'sale' or 'sharing' of your personal information for targeted advertising for each participating browser system that you use. Oplign does not have actual knowledge that it 'sells' or 'shares' the personal information of consumers under 16 years of age.
• Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing privacy@Oplign.us.

Oplign will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law.

Sensitive Information. Oplign receives information that may be considered sensitive under some state laws, such as certain Account Information (e.g., financial information, log-in information) , certain Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features and certain Limited Information from Oplign Email and Calendar Services (e.g., messaging content in cases described herein) Oplign processes sensitive personal information to provide Oplign products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. Oplign does not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require Oplign to provide a right to limit under the CCPA. Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual's information that would produce a legal or similarly significant effect. Oplign does not engage in this type of profiling of individuals.

To exercise your rights, please click here or call +1-888-799-0566. To opt out of the use of cookies on our sites for interest-based advertising purposes, follow the instructions above.

We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to a total of 90 days) in writing.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to log into your existing Oplign account (if applicable), give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of personal information relating to your account (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

To see our Disclosure of Privacy Rights Requests, please click here.

California's Shine the Light Law

California Civil Code Section 1798.83, also known as 'Shine The Light' law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties' direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties' direct marketing purposes.

Changes

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Statement on our website, with a 'Last Updated' date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our products and services.