Privacy Policy

ARCTOS (‘Arctos,” “we,” “us,” or “our”) is committed to ensuring that your privacy is protected. If we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this Privacy Policy. 

This Privacy Policy provides an explanation for how any personal data that you provide to us, or that we collect from you, is handled. 

Your Consent 

By using this website, you consent to the collection and use of information as outlined in this Privacy Policy.  

Changes to the Privacy Policy 

We may change this policy from time to time. The Policy in effect at the time you use the website governs how we may use your information.  If we make material changes we will post the revised Privacy Policy and the revised effective date on this website so you can review any changes. This policy was last updated July 2023. 

Information We Collect 

We collect information when you visit our websites or otherwise interact with us this includes information you provide, information we may receive from other sources and information that we automatically collect. 

“Personal Information” is information that, directly or indirectly, identifies you or another individual and which may include, but is not limited to: name; title, company name; expertise; postal address; telephone number; email address; browser and device information (including Internet Protocol (IP) address); and information collected through cookies and other similar technologies. Other information we collect and use includes information or data that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated.  We use this information to facilitate our operation of the Sites and for other purposes described below. 

  1. Information that you provide.  We collect information that you submit when visiting our website, including Conference registration information (your name, email or postal address, telephone number, and user name and password), contact information if you contact us, submit an abstract, or signup to our mailing (name, email address, telephone number, company name, title) or other information you may voluntarily provide when you interact with our website. Our website may allow you to apply for employment with us.  This allows you to submit to us or our third party staffing partner your application information which may include your resume, employment and education history, skills, personal references and other information you choose to submit.  Our website may permit you to make payments, in which case we may collect payment card and billing information.
  2. Information we collect from other sources.  We may also collect information about you from other sources, including information about your attendance or participating in Conferences and job applicant references and background check information.
  3. Automatically collecting information.  We automatically collect details of your visits to our website and the resources that you access, including, but not limited to, technical information about your device, your IP address, traffic data, general location data, weblogs and other communication and logging data. 

Use of Cookies and Tracking Disclosure 

Like most websites, we may gather information about your computer for our services and provide statistical information regarding the use of our website to our Exhibitors/Sponsors. Such information will not identify you personally as it is statistical data about our visitors and their use of our website. 

We may gather information about your general internet use by using a cookie file or similar technology. A cookie is a small file placed on your computer’s hard drive. Cookies help analyze web traffic or let you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. These cookies may stay on your browser into the future until they expire or you delete them. We may also use cookies that are strictly necessary for our website to function.  These cookies are usually deleted when you close your browser window.  Further general information about cookies and how they work is available at www.allaboutcookies.org 

We may allow selected third parties to place cookies through the website to provide us with better insights into the use of the website or user demographics or to provide relevant advertising to you.  These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our website to perform analytic or marketing functions. Our Exhibitors/Sponsors may also use cookies. Such cookies (if used) would be downloaded once you click on Exhibitor/Sponsor links on our website. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties. 

We do not use technology that recognizes a “do-not-track” signal from your web browser except as disclosed in this Privacy Policy.   

Use of Your Information 

The information that we collect and store relating to you is primarily used to enable us to provide our services to you, to improve our website, and to grow our business. In addition, we may use the information for the following purposes: 

  1. To provide you with information requested from us, relating to our products, services, current or future Conference details and associated support.  
  2. To provide information on other Conferences which we feel may be of interest to you. 
  3. To administer or otherwise meet our contractual commitments to you. 
  4. To notify you about any changes to our website, such as improvements or service/product changes, that may affect our service. 
  5. To distribute to Conference Attendees/Exhibitors in the form of an attendee listing. 
  6. To create and manage our accounts, provide customer relationship management, develop and improve our products and services, and quality control. 
  7. To administer our business and operations, including marketing and promotional activities, security, data analysis, testing, research and development, statistical and survey purposes as well as complying with our legal obligations, and enforcing or defending our legal rights. 
  8. If you have applied to work with us, we use your information to assess your qualifications and suitability for the role you applied for, conduct background and reference checks, communicate with you about the recruitment process, keep records and comply with our legal obligations. 

Storing Your Personal Information and Security 

We have implemented appropriate organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our website will be encrypted in transmission to ensure its safety. Complete Credit Card information IS NOT stored on our servers. 

While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure you should keep in mind that the Site is run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is, therefore, entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain parts of our website, you are responsible for keeping this password confidential. Any requests made using your log in credentials will be considered to be authorized by you.  Please take care when sending us Personal Information by email as email communications are not secure. 

Disclosing Your Information 

Where applicable, we may disclose your personal information to any member of our group. This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries (if any). 

We may also disclose your Personal Information to third parties: 

  • If you request or authorize it. 
  • If the information is provided to help complete a transaction for you. 
  • If the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (such as analyzing data, providing marketing assistance, customer service, payment processing, etc.) 
  • If the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others. 
  • To assist fraud protection and minimize credit risk. 
  • If the disclosure is done as part of a purchase, financing, transfer or sale of services or assets or our company as a whole. 
  • As otherwise described in this Privacy Policy. 

We may disclose de-identified or anonymous information to third parties without restriction. For instance, we may, on occasion, provide Exhibitors/Sponsors with aggregate statistical information about our visitors. 

We do not share your information with third parties for their direct marketing purposes. 

Third Party Links 

You might find links to third party websites on our website. These websites should have their own privacy policies which you should check. We do not endorse or accept any responsibility or liability for their policies whatsoever as we have no control over them. 

Access To Information and Your Choices 

If you wish to receive details about the information that we hold about you or to amend, update or delete your information, please contact us using the details below. 

You can choose not to receive promotional emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us. 

All computers have the ability to automatically accept or decline cookies. This can be done by activating the setting on your browser which determines how to handle cookies. Please note that if you choose to decline cookies, you may be unable to access particular parts of our website. 

Children’s Privacy 

Our website and our services are not designed nor intended to be attractive to use by children under the age of 13.  We do not knowingly collect information from children under the age of 13.  If you are under 13 please do not submit any information to us. 

Data Processing and Cross-Border Data Transfers 

Our website is maintained on servers located in the United States, and personal information submitted is stored on our servers in the United States.  If you are visiting our website from outside the United States, please be advised that your information is transferred to our U.S. servers.  Disclosing your personal information to us pursuant to this Privacy Policy is at your own risk.  We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information. 

Notice to Residents of the United Kingdom and the European Economic Area 

If you are a visitor from the United Kingdom or the European Economic Area (EEA), you may have the following rights in certain circumstances:  

To request access to any Personal Information we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making; 

  • To obtain without undue delay the rectification of any inaccurate Personal Information we hold about you; 
  • To request that Personal Information held about you is deleted; 
  • To prevent or restrict processing of your Personal Information; and 
  • To request transfer of Personal Information directly to a third party where this is technically feasible. 

You can exercise any of these rights by contacting us using the details under “Contacting us” below. We aim to respond to requests made by you within one (1) month but may extend that period by two (2) further months where necessary. Also, where you believe that we have not complied with its obligation under this Privacy Policy or UK or EEA law, you have the right to make a complaint to a UK or an EU Data Protection Authority.  

This Policy describes our legal basis for collecting and using personal information, including with your consent, to comply with our legal obligations, or when we have a lawful basis or legitimate interest where doing so does not override your data protection interests or fundamental rights.  

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, or object to the use of your Personal Information on these grounds, please contact us at the address provided under the “Contacting Us” heading below. 

Contacting Us 

We welcome any questions, comments or requests you may have regarding this Privacy Policy. If you wish to receive details about the information that we hold about you, please do not hesitate to contact us at info@arctos-us.com, ARCTOS Technology Solutions, 2601 Mission Point Blvd, Suite 300, Beavercreek, OH 45431. 

State-Specific Notices 

Notice to Nevada Residents 

We do not transfer personal information for monetary consideration.  If you would like to tell us not to sell your information in the future please email us at info@arctos-us.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line. 

Notice to Colorado, Connecticut, Virginia and Utah Residents 

We are currently not subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future we will update this Privacy Policy accordingly. 

Notices to California Residents 
Your California Privacy Rights. (Shine the Light Disclosure)  

California residents with an established business relationship with us are permitted by California law to choose not to have their information disclosed to others for their direct marketing use  We do not share your personal information with others for their marketing use.   

California Consumer Privacy Act Notice 

The California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”) provides certain verified California residents with the right to: receive disclosure of our information collection and disclosure practices; the specific information collected about them; request that we correct information we hold; make requests that we do not sell information or do not share personal information for cross-context or behavioral marketing purposes; request that we limit processing of sensitive personal information to the purposes for which it was originally provided; or that we delete information subject to certain exceptions. For details on how to exercise these rights, please see below. We will not discriminate against you as a result of your exercise of any of these rights. For purposes of CCPA, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. 

Our California employees (current, former or applicants) can learn about our information collection and disclosure practices and how to exercise their CCPA rights by contacting the Director of Human Resources. 

Information Collected, Sources, and Business Purpose for Collection

The following table lists the categories of personal information defined in the CCPA, whether we have collected information in the category during the past 12 months, the sources of the information, and the business purposes for which we collect and use the information. The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other California resident that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.  

Category of Information
Collected
Source
Business purposes* for collection
A. Identifiers (name, alias, postal address, email address, phone number, account name, Social Security number, driver’s license number, passport number, unique personal identifier, IP address)
Yes
Individuals submitting information to us; information we automatically collect from site visitors; information we may receive from third-party marketing and data partners.
Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair;
ad customization; performing services for you; internal research and development; quality control.
B. Protected Information (name with: Social security number, driver’s license or state ID number, financial account, medical, health, and health insurance information, username and password)
Yes
Individuals submitting information; employment applications; employees.
Auditing relating to transactions; security detection, protection and enforcement; performing services for you; quality control.
C. Protected anti-discrimination classification information (Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).)
Yes
Individuals submitting information.
Performing services for you;

internal research and development;

compliance with law.

D. Commercial information (transaction history, products/services purchased, obtained or considered, product preference)
Yes
Individuals submitting information; information we automatically collect from site visitors; information we may receive from third-party marketing or data partners.
Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services to you; internal research and development; quality control.
E. Electronic network activity (browsing or search history, website interactions, advertisement interactions)
Yes
Information automatically collected from site visitors.
Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.
F. Audio, video or similar information (customer service calls, security monitoring)
No
Not collected
Not collected
G. Biometrics (fingerprints, face or iris or retina scans)
No
Not collected
Not collected
H. Geolocation
Yes
Information we automatically collect from site visitors.
Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.
I. Professional, educational or employment related information
Yes
Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight.
Auditing relating to transactions; security detection, protection and enforcement; performing services for you; employee and vendor management; internal research and development; quality control; compliance with law.
J. Non-public educational information) (Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records).
No
Not collected
Not collected
K. Sensitive Personal Information (may include, social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, health, sex life or sexual orientation.)
Yes
Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight.
Identity verification; employment and benefits administration; vendor oversight; security detection, protection and enforcement; compliance with law.
L. Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)
Yes
Internal analytics
Internal research and development; quality control.

*More specifically, the business purposes include:   

  •  Performing services for you:  
    • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
    • To assist you in completing a transaction or order;
    • To allow tracking of shipments; 
    • To prepare and process invoices;
    • To respond to queries or requests and to provide services and support;
    • To provide aftersales customer relationship management;
    • To create and manage our customer accounts; 
    • To notify you about changes to our services and products; 
    • To administer any promotion, contest, survey, or competition;
    • To provide you information regarding our products and services; and
    • To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.
  • Advertising customization: 
    • For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.
  • Auditing relating to transactions, internal research and development: 
    • To provide for internal business administration and operations, including troubleshooting, Site customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;
    • To create products or services that may meet your needs; and
    • To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.
  • Security detection, protection and enforcement; functionality debugging, error repair: 
    • As part of our efforts to keep our website safe and secure; 
    • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our website, for example, by requesting verification information in order to reset your account password (if applicable);
    • To ensure the physical security of our premises through the monitoring of surveillance images; and
    • To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.
  •  Quality control: 
    • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures; and
    • To develop and improve our products and services, for example, by reviewing visits to the website and various subpages, demand for specific products and services and user comments.
Processing Sensitive Personal Information

We collect and process Sensitive Personal Information for the purposes disclosed at the time we collect this information.  We only process or disclose this information for purposes described above or as permitted by law. The following are permitted purposes under the CCPA: 

  • To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or service;
  • To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information;
  • To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions;
  • To ensure the physical safety of natural persons;
  • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
  • To perform services on behalf of our business;
  • To verify or maintain the quality or safety of products or services that we own or control, and to improve, upgrade, or enhance such products or services; or  
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.   
 Disclosing Personal Information

From time to time we disclose your information as described below. This includes disclosing information to our service providers such as professional advisers, lawyers, bankers, staffing partners, auditors and accountants, and, when required by law, to regulators or law enforcement.  

Disclosure of Personal Information for a Business Purpose.

We may disclose your personal information to service providers and others for a business purpose. The business purposes are listed above. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

In the preceding twelve (12) months, we may have disclosed the following categories of personal information to service providers (such as payment processors, mail houses, marketing partners, employee benefits partners; professional advisors); affiliated companies; government regulators; law enforcement; or strategically aligned businesses. This may include Identifiers, Protected personal information, Protected anti-discrimination classification information, Commercial Information, Electronic network activity information, Geolocation, Professional or employment-related information, Sensitive personal information, and Inferences.

Disclosing Personal Information in Sale Arrangements

We do not sell personal information for monetary consideration but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and analytics, and security, which may fall under the definition of for “other valuable consideration” and which may therefore be considered a “sale” under the CCPA. We do not sell the personal information of individuals we actually know are less than sixteen (16) years of age. Please see below for opting out of having your information sold. In the preceding twelve (12) months we may have disclosed the following categories of information for a business purpose which falls within the definition of a ‘sale:’ Identifiers, Electronic network activity information, Geolocation (general). 

Sharing Personal Information for Cross-Context Behavioral Marketing

Sharing your personal information means making it available to a third-party so that they can use it to display targeted or cross-context behavioral advertisements to you. Cross-context behavioral or targeted advertising means that we display an advertisement to you that is selected based on personal information about you that we obtained or inferred over time from your activities across other companies’ websites, applications or online services that we use to predict your preferences or interests. Targeted advertising does not include using your interactions with us or information that you provide to us to select advertisements to show you. We do not share information for cross-context behavioral marketing purposes. 

CCPA Rights.

The CCPA provides California residents with specific rights regarding their personal information.  This section describes your CCPA rights. 

Information Access Rights

As a California resident, you have the right to request that we disclose certain information upon request about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12 month period. Once we receive and confirm your verifiable request, we will disclose to you: 

  • The categories of personal information we collected about you, the sources of the information, our business or commercial purpose for collecting the information and whether the information was disclosed for a business purpose, shared or sold;  
  • The categories of information we disclosed for a business purpose and the categories of information we sold or shared during the prior 12 months along with the categories of recipients of such information; and 
  • The specific pieces of personal information we collected about you during the prior 12 months, or, at your option, since the applicable calendar year. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us. 

 Information Deletion Rights

California residents have the right to request that we delete any of the personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm a verifiable request, we will delete (and direct our service providers to delete) the personal information from our records, unless an exception applies. You may make deletion requests at any time. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; 
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities and to help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; 
  • Debug products to identify and repair errors that impair existing intended functionality; 
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; 
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); 
  • Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s ability to complete such research, if you previously provided informed consent; 
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information; 
  • Comply with a legal obligation; or 
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

Information Correction Rights

California residents have the right to request that we correct information that we hold which is inaccurate.  We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account. You can make information correction requests at any time. 

Opt-Out Rights

  • Do Not Sell My Personal Information.  If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. 
  • Do Not Share My Personal Information.  You have the right to opt out of having your personal information shared with others for cross-context or behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us to select advertisements to show you. We do not share your information with third parties for cross-context behavioral advertising purposes. 
  • Limit Processing of Sensitive Personal Information.  You have the right to tell us not to process or disclose Sensitive Personal Information for any purpose other than the legally permitted purposes or the purposes disclosed at or before the time we originally collected it. We only process Sensitive Personal Information for the legally permitted purposes.  

Exercising Your CCPA Rights

  • Access, Correction and Deletion.  To exercise the access, correction, and deletion rights California residents may contact us by emailing us at info@arctos-us.com with “CCPA Request” in the subject line or calling us toll-free at 1-888-833-4251.  We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. Any disclosures we provide will only cover the 12-month period preceding receipt of your request, but you may request that expand the 12-month period to cover information collected since January 1, 2022, and we will honor that expanded request unless doing so would involve a disproportionate effort.  We will acknowledge receipt of your request within 10 business days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you. 
  • Opt-Out Rights.  To opt out of the sale of your personal information you may submit a request to us by clicking the following link: “Do Not Sell My Info“.  You may also call us toll free at 1-888-833-4251. 

You may also opt out by activating a user-enabled global privacy control, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicates or signals your choice to opt-out of the sale and sharing of personal information. When we receive such a signal we will stop setting third party, analytics, or advertising partner cookies on your browser.  This will prevent the sale or sharing of information relating to that specific device through cookies to our advertising or analytics partners. This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email address or ZIP Code and we may have arrangements with other companies that qualify as a sale where your identifiable information, such as your name or email address, is disclosed.  If you delete cookies on your browser, any prior do not sell or do not share signal is also deleted and you should make sure that your user-enabled setting is always activated. 

We will comply with your request promptly, and at least within 15 business days. Once we receive your request we will wait at least 12 months before asking you to reauthorize personal information sales or sharing. 

Using an Authorized Agent. 

You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Non-Discrimination.

We will not discriminate against you as a result of your exercise of any of these rights.

Retention of Personal Information

We will store personal information in a form which permits us to identify consumers, for as long as necessary for the purpose for which the personal information is processed.  We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the CCPA for a period of two years.