Updated: February ____, 2022

Table of Contents

I.     Introduction. 4

II.     Personal Information We Collect 4

A. Information That You Provide To Us Directly. 4

B. Information Collected Through Your Use Of The Digital Services 5

(i) IP Addresses and Related Information. 6

(ii) Cookies and Other Tracking Technologies. 6

(iii) Third-Party Analytics Services. 8

C. Information Provided To Us By Others. 8

III.       How We Use The Information We Collect 8

IV.       Who We Share Your Information With. 9

A. No Sale of Personal Information to Third Parties for their Own Use. 9

B. Sharing Personal Information with Affiliates and Service Providers That Help Us Perform Our Business Purposes. 10

C. Sharing Information with Third Parties at Your Direction. 10

D. Monitoring, Enforcement, and Legal Requests. 10

E. Sale of Our Company or Assets. 10

F. Internal Use and Research. 11

V.    Protection Of Your Personal Information. 11

VI.       Other Sites/Third Party Links 12

VII.      Changes To Our Privacy Policy. 12

VIII.     Terms of Use. 12

IX.       Contact Us With Any Questions 12

X.    CALIFORNIA RESIDENTS: Summary Of Consumer Rights Under The California Consumer Privacy Act (“CCPA”) 13

A. Overview.. 13

B. Right to Know. 14

C. Right to Deletion. 14

D. Right to Non-Discrimination. 15

E. Right to Opt-Out. 15

F. Privacy Policy Requirements. 16

XI.       CALIFORNIA RESIDENTS: Additional Disclosure Regarding The CCPA and Interest-Based Advertising. 16

XII.      CALIFORNIA RESIDENTS: How To Make A CCPA Consumer Rights Request. 17

A. Instructions for Submitting a CCPA Consumer Rights Request to Us. 17

B. Verification Of The Person Making A Consumer Rights Request. 17

C. Designating An Authorized Agent to Make A Request for You. 18

D. Response Timing and Format. 18

     I.         Introduction

This Privacy Policy describes how Viva Entertainment Network, Inc. (hereafter, “Viva Entertainment Network,” “we,” “us,” “our” or the “company”) collects, uses, and shares Personal Information. This Privacy Policy applies to the company’s online and offline information gathering and dissemination practices in connection with our websites, including any website where this Privacy Policy is posted, and any subdomains or mobile versions (collectively, the “Site”), or in connection with our mobile messaging programs or any other online or web-enabled technology product or service that we may provide (collectively with the Site, the “Digital Services”). This Policy also applies to any Personal Information we may collect or receive through other means.

If you have arrived at this Privacy Policy by “clicking” on an authorized link directing you to a website operated by Viva Entertainment Network, then this Privacy Policy applies to you and such website. This Privacy Policy does not apply to any website owned and/or operated by or on behalf of any third party, even if we provide a link to such website on our own Site. By accessing or using our Digital Services, you are agreeing to the terms of this Privacy Policy.

Use of our Digital Services is strictly limited to persons who are at least thirteen (13) years of age. We do not solicit or knowingly collect information from children under 13 years of age. If you are not at least 13 years of age, please do not use or provide any information through our Digital Services. If we learn we have collected personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected]

We understand that you care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes the company’s policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

Any questions regarding this Privacy Policy may be directed to us as provided in the section titled “Contact Us With Any Questions” below.

II.         Personal Information We Collect

The following is a description of: (i) the categories of Personal Information we may have collected in the preceding 12 months; (ii) the sources from which we may have collected such information; and (iii) the business purposes for which we may have collected such information.

A. Information That You Provide To Us Directly.

We collect Personal Information from you when you register with or create an account on the Digital Services, place an order with us, enter a contest or other promotion with us, respond to a survey or communication such as email, sign up for our email list or newsletter, or participate in another feature of the Digital Services. You may, however, visit our Site without providing such information.

If you voluntarily choose to submit or otherwise disclose Personal Information to us, including through the Digital Services, or by regular mail, telephone, fax, email or other electronic means of communication, it is governed by this Privacy Policy.

The Personal Information we may collect directly from you from these sources includes your:

  • first and last name;
  • email address;
  • physical/mailing address;
  • home and/or mobile phone number; and
  • credit or debit card number.

We also may collect:

  • Records and copies of your correspondence, if you contact us;
  • Your responses to surveys that we might ask you to complete; and
  • Details of transactions you carry out through our Digital Services and of the fulfillment of your orders.

We do not store or retain any credit or debit card or other payment information. Any online payments made through a link from the Digital Services are transmitted to and from your browser in encrypted form using Secure Sockets Layer (SSL), then immediately sent in encrypted form to our payment gateway provider. We do not store or retain credit or debit card or other payment information on our servers.

If you contact or correspond with us by phone or email, we may keep a record of your contact information and correspondence, and we reserve the right to use your contact information, and any other information that you provide to us in your message, in order to respond thereto. If you wish to change or correct any information you have voluntarily submitted to us, please do so by contacting us in the manner described below.

B. Information Collected Through Your Use Of The Digital Services

As you navigate through and interact with our Digital Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. Such information and technologies include the following.

(i) IP Addresses and Related Information

Like most websites, the Digital Services collect certain information automatically and stores it in log files. Such information may include internet protocol (IP) addresses, the region or general location from which your computer or device is accessing the internet, browser type, operating system, and other information about your use of the Digital Services, including a history of the pages you view. We use this information to help us design our Digital Services to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, detect potential security threats, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

(ii) Cookies and Other Tracking Technologies

When you interact with our Digital Services, we obtain certain information using automated technologies, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. For instance, we use cookies to help us remember and process the items in your shopping cart. Cookies are also used to help us understand and save your preferences based on previous or current site activity.

A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used by a website.

We set some of these automated technologies ourselves. In addition, third parties may be allowed to view, edit, or set their own cookies or place web beacons on our Digital Services. Cookies and web beacons allow us and third parties to distinguish you from other users of our Digital Services, and some of these technologies can be used by us and/or our third-party partners to identify you across platforms, devices, sites, and services.

We and authorized third parties may use cookies and similar technologies for the following purposes:

  • for “essential” or “functional” purposes, such as to enable certain features of our Digital Services (for example, to allow a customer to maintain a “shopping cart”);
  • for “analytics” purposes, such as to analyze the traffic to and on our Digital Services (for example, we can count how many people have looked at a specific page, or see how visitors move around the Digital Services when they use them, what website they visited prior to visiting our Digital Services, and use this information to understand user behaviors and improve the design and functionality of the Digital Services); and
  • for “retargeting” or similar advertising or commercial purposes, such as:
  • for social media integration, for example, via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Digital Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter;
  • to collect information about your preferences and demographics to help target advertisements that are more likely to be of interest to you using targeted advertising (also known as “interest-based” advertising); and
  • to allow us to carry out retargeting (this includes, for example, when advertisements are presented to you for products or services that you have previously viewed on a website but have not purchased).

The use of these technologies by third parties may be subject to their own privacy policies and is not covered by this Policy, except as required by law.

We may also use your information collected in this context for the other purposes set forth in this Policy.

You can opt out of cookies on the Site using the “Cookie Banner” at the bottom of the home page of the Site. You can also choose to have your browser alert you each time a cookie is being placed on your device, or you can choose to disable cookies entirely. You do this through your browser (such as Chrome, Firefox, Edge, or Internet Explorer) settings. Each browser is a little different, so please look at your browser’s Help menu to determine the correct way to modify your cookie settings.

If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device.

Please note that if you opt out of or disable cookies, you may not have access to certain features that make your site experience more efficient and some of our services may not function properly. However, you can still place orders for products and services by contacting Customer Service.

You can learn more about cookies and how to manage your preferences by visiting http://www.allaboutcookies.org.

Certain web browsers allow you to instruct your browser to respond to Do Not Track (“DNT”) signals to website you visit, informing those sites that you do not want your online activities to be tracked. At this time, our Digital Services are not designed to respond to DNT signals or similar mechanisms from browsers.

(iii) Third-Party Analytics Services

As noted above, we may use third-party analytics service providers, such as Google Analytics and Facebook Pixel, to help us with our online services. These providers may use technologies such as cookies, web beacons and web server logs to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services.

These service providers generally are required by contract to keep data that they receive from us private. In addition, they have their own privacy policies that you should be aware of.

  • To learn more about Google Analytics and how to opt out, please visit https://marketingplatform.google.com/about/ or https://support.google.com/analytics/answer/181881?hl=en. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.
  • To learn more about Facebook Pixel cookies, visit www.facebook.com/business/learn/facebook-ads-pixel. For further information regarding how Facebook uses your data, please visit https://www.facebook.com/help/325807937506242/ or log on to your Facebook account and access your settings. To understand more about Facebook advertising, please visit https://www.facebook.com/about/ads.

Additional information on how to modify your browser settings or how to block, manage, and/or filter cookies can be found in your browser’s help page or through third-party websites as www.allaboutcookies.org.

C. Information Provided To Us By Others.

We may receive Personal Information about you from third-party platforms if you place orders through such platforms for our products or services. This information includes your full name, physical/mailing address, email address, and phone numbers. We use this information to fulfill orders for our products and services and to address customer service issues.

III.         How We Use The Information We Collect

We may use the Personal Information we collect in the following ways:

  • To present our Digital Services and their contents to you.
  • To provide you with information, products, or services that you request from us.
  • To improve our Digital Services and our customer service.
  • To process transactions, including orders that you place through our Digital Services.
  • To send periodic emails to you, including information and updates pertaining to orders that you place through our Digital Services.
  • To administer contests, promotions, surveys, and/or other Digital Services features.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Digital Services or any products or services we offer or provide though them.
  • To fulfill any other purpose for which you provide it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Visitors who register on or participate in other Digital Services features such as marketing programs will be given a choice whether they would like to be on our email list and receive email communications from us.

If you no longer want to receive promotional email from us, we include instructions to “unsubscribe” at the bottom of all of our emails. Alternatively, you may contact us in one of the manners set forth in the section titled “Contact Us With Any Questions” below.

IV.         Who We Share Your Information With

A. No Sale of Personal Information to Third Parties for their Own Use.

We do not sell data that directly identifies you—including, but not limited to, your name, mailing address, telephone number, or email address—unless we have your explicit permission. Except as described above with regard to cookies and other tracking technologies, we do not sell, trade, or otherwise transfer to Third Parties for their own use any of your Personal Information, unless we provide you with advance notice and you consent. Except as described in this Privacy Policy, we also do not disclose to Third Parties any personally identifiable information about your visits to our Digital Services.

Likewise, Viva Entertainment Network does not knowingly collect and does not, and will not, sell Personal Information of minors under 16 years of age without affirmative authorization.

B. Sharing Personal Information with Affiliates and Service Providers That Help Us Perform Our Business Purposes.

The term “Third Parties” does not include Viva Entertainment Network or our affiliates. It also does not include website hosting partners and other Service Providers who assist us in operating our Digital Services, conducting our business, or providing products or services to you, so long as those parties agree to keep this information confidential and not use or further disclose it for their own purposes.

We may provide your Personal Information to our Service Providers who help us perform our business purposes, such as:

  • Event promoters, who fulfill certain orders that you may place with us through the Digital Services or otherwise;
  • Event venues, who provide the physical space for events and related products and services associated with orders that you may place with us through the Digital Services or otherwise; and
  • Technology companies, who assist us in maintaining, protecting, and enhancing our Digital Services and our customer service and communication systems.

C. Sharing Information with Third Parties at Your Direction.

We may share your Personal Information with Third Parties to whom you or your agents authorize us in advance to intentionally disclose to or allow to use your Personal Information in connection with products or services that we provide.

D. Monitoring, Enforcement, and Legal Requests.

Viva Entertainment Network has no obligation to monitor the Digital Services or the use of the Digital Services or to retain the content of any user session. However, we reserve the right, at all times, to monitor, review, retain and/or disclose any information, including Personal Information, as may be necessary to satisfy any applicable law, regulation, legal process or governmental request or to cooperate with law enforcement and other authorities.

We may also use IP addresses to identify a Digital Services user when we feel it is necessary to protect the Digital Services, our service, clients, potential clients, or others.

E. Sale of Our Company or Assets.

In the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets or any portion of our business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Digital Services users is among the assets transferred, we reserve the right to transfer to a buyer or other successor any and all information that we collect from individuals, or that we otherwise collect in connection with the Digital Services.

F. Internal Use and Research.

Viva Entertainment Network reserves the right to use and disclose de-identified information; anonymized information; aggregated information; or publicly available information that has not been combined with non-public Personal Information for purposes including, but not limited to, the company’s own internal use, data mining, and research.

Similarly, aggregated, de-identified and non-personally identifiable Digital Services visitor information may be provided to other parties for marketing, advertising, or other uses.

V.         Protection Of Your Personal Information

We implement a variety of reasonable security measures to maintain the safety of your Personal Information. For example,

  • Your Personal Information is stored behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and who are required to keep the information confidential;
  • All payment information you supply in connection with orders for products and services is transmitted to and from your browser via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway database, where it is accessible by a limited number of persons who have special access rights to such systems, and who are required to keep the information confidential; and
  • Once a transaction has been completed, no sensitive personal information (such as credit or debit card numbers, social security numbers, etc.) is stored on our servers.

Unfortunately, transmission of information via the internet is never completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Digital Services. Any transmission of Personal Information is at your own risk. We also are not responsible for circumvention of any privacy settings or security measures contained on the Digital Services.

VI.         Other Sites/Third Party Links

In an attempt to provide you with added value and improve your experience with our Digital Services, we may include third-party links on our Digital Services. When you click on such links and visit such other websites, you need to be aware that we may not control such other websites or such other websites’ business practices, and that this Privacy Policy does not apply to such other websites. Such other websites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of such linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about such other sites (including if a specific link does not work).

VII.         Changes To Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

VIII.         Terms of Use

Please also visit our Terms of Use section establishing the use, disclaimers, and limitations of liability governing the use of our Digital Services. By using our Digital Services, you consent to our Terms of Use.

IX.         Contact Us With Any Questions

We welcome your questions, comments, and concerns about privacy. If you have any questions or comments about this Privacy Policy or our practices, or wish to make a request regarding your Personal Information, please contact us at:

Viva Entertainment Network, Inc.

1106 West Lawrence Avenue

Chicago, Illinois  60640

Phone: (773) 769-3400

Email: [email protected]

X.         CALIFORNIA RESIDENTS: Summary Of Consumer Rights Under The California Consumer Privacy Act (“CCPA”)

A. Overview

The California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100 et seq., (“CCPA)” took effect on January 1, 2020. The CCPA grants new privacy rights to California consumers, including:

  • The right to know what Personal Information is collected, used, shared or sold, both as to the categories and specific pieces of Personal Information;
  • The right to delete Personal Information held by businesses and, by extension, a business’s service providers;
  • The right to opt-out of the sale of Personal Information. Consumers are able to direct a business that sells Personal Information to stop selling that information. Children under the age of 16 must provide opt-in consent, with a parent or guardian consenting for children under 13; and
  • The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA.

A business subject to the CCPA that collects a California consumer’s Personal Information must, at or before the point of collection, inform the consumer as to the categories of Personal Information to be collected and the purposes for which the categories of Personal Information shall be used.

A covered business must disclose and deliver the Personal Information the business collected about the consumer in response to a verifiable consumer request.

For purposes of the CCPA, “Personal Information” does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information; or
  • Information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

A further summary of consumer rights provided by the CCPA follows.

B. Right to Know.

A business subject to the CCPA must disclose in its privacy policy the Personal Information about consumers that the business has collected, sold, or disclosed for a business purpose in the past twelve (12) months.

A business that collects Personal Information must also disclose, in response to a verifiable consumer request, the following:

  • The categories of Personal Information the business has collected about the consumer;
  • The categories of sources from which that Personal Information is collected;
  • The business or commercial purpose for collecting or selling Personal Information collected from consumers;
  • The categories of third parties with which the business shares Personal Information; and
  • The specific pieces of Personal Information the business has collected about the consumer making the request.

A business that sells a consumer’s Personal Information or discloses a consumer’s Personal Information for a business purpose must disclose the following in response to a verifiable consumer request:

  • The categories of Personal Information the business has collected about the individual consumer;
  • The categories of Personal Information the business has sold about the consumer and categories of third parties to which the Personal Information was sold, by category or categories of Personal Information for each third party to which the Personal Information was sold. Alternatively, if the business has not sold any consumer Personal Information, it must state that fact; and
  • The categories of Personal Information the business has disclosed about the consumer for a business purpose. Alternatively, if the business has not disclosed any consumer Personal Information for a business purpose, it must state that fact.

C. Right to Deletion.

You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

Under the CCPA, we may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing, intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §§ 1546, et seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

D. Right to Non-Discrimination.

A business must not discriminate against a consumer who exercises any of the consumer’s rights under the CCPA. However, a business may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided to the consumer by the consumer’s data and may offer financial incentives to a consumer for the collection, sale, or deletion of Personal Information on a prior opt-in consent basis.

E. Right to Opt-Out.

A business that sells consumers’ Personal Information to third parties needs to provide notice to consumers thereof and that consumers have the right to opt out of the sale of their Personal Information. A business must provide a “Do Not Sell My Personal Information” link on its Internet homepage that links to an internet webpage that enables a consumer to opt out of the sale of the consumer’s Personal Information.

A business must not sell the Personal Information of consumers if the business has actual knowledge that the consumer is less than sixteen (16) years of age, unless the consumer, in the case of consumers between thirteen (13) and sixteen (16) years of age, or the consumer’s parent or guardian, in the case of consumers who are less than thirteen (13) years of age, has affirmatively authorized the sale of the consumer’s Personal Information.

F. Privacy Policy Requirements.

A business must describe in its online privacy policy or in any California-specific description of consumer privacy rights the following, which must be updated at least once every twelve (12) months:

  • Consumers’ rights under the CCPA, including the consumer right to opt out of the sale of the consumer’s Personal Information and a separate link to the “Do Not Sell My Personal Information” internet webpage;
  • The methods for submitting and verifying consumer requests; and
  • A list of the categories of Personal Information that the business has collected about consumers, sold about consumers, and disclosed about consumers for a business purpose in the preceding 12 months.

XI.         CALIFORNIA RESIDENTS: Additional Disclosure Regarding The CCPA and Interest-Based Advertising.

As describe above, we and third parties that provide advertising or other functionality on our behalf may use cookies, pixel tags, and other technology to help us advertise our products and services to you as informed by your interests. This approach is called interest-based advertising, which means we tailor our ads to you based on information that gives us a sense of what interests you, such as information collected from your activity on the web. This includes, but is not limited to, information regarding your browsing or purchasing products on or through our Digital Services or on third-party websites, your activity on mobile sites and applications, or your responses to our marketing emails.Based on the CCPA’s broad definition of the term “sale,” certain data collection on our Digital Services for purposes of interest-based advertising may be a “sale” under the CCPA. To opt out of such advertising, please clicking the “Do Not Sell My Information” link in our Site footer and follow the instructions provided. You may also choose to email us at [email protected] with the subject line “do not sell info”, including if you are an authorized agent for a California resident; however, the more immediate way of fulfilling this request is through the link in our Site footer.

In addition to exercising your opt-out right as described immediately above, you can always restrict the placement of cookies on your computer or remove them from your browser through your browser settings. More information on how to manage these settings on common browsers and devices can be found at the following links:

You can also opt out of receiving interest-based ads from third party advertisers who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out pages on the NAI website and DAA website.

Please note that cookie-based opt outs are applicable only to the browser and device you use when you opt out. If you wish to opt out across all devices, you must replicate your choices across each device, including your mobile device. In addition, if you clear or delete your cookies on that browser or device, you may need to reset your cookie opt out.

XII.         CALIFORNIA RESIDENTS: How To Make A CCPA Consumer Rights Request.

A. Instructions for Submitting a CCPA Consumer Rights Request to Us.

If you wish to exercise any of the CCPA consumer rights summarized above, such as a Request to Know or a Request to Delete Personal Information, you can do so in one of the following ways:

[Click here to submit your request online;]

Call us at (773) 769-3400; or

Reach us by email or U.S. mail at:

Viva Entertainment Network, Inc.

1106 West Lawrence Avenue

Chicago, Illinois  60640

Email: [email protected]

Upon receiving a verifiable Request to Know or Request to Delete, we will confirm receipt of the request within ten (10) days and provide some information about how we will verify and handle the request, and by when you should expect to receive a response.

Please note that you may only make a verifiable consumer Request to Know or Request to Access your data under the CCPA two (2) times within any twelve (12) month period.

B. Verification Of The Person Making A Consumer Rights Request.

Of course, we need to be reasonably sure that the person making the request is actually you. So, we may need some information from you to verify that you are the person whose Personal Information you are asking to know about or to delete. Accordingly, the verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

C. Designating An Authorized Agent to Make A Request for You.

Only you or a person registered with the California Secretary of State that you designate and authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. For your protection, we will need some proof that someone seeking to act on your behalf is actually authorized by you to do so. You may also make a verifiable consumer request on behalf of your minor child.

D. Response Timing and Format.

We will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we need more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of the verifiable consumer request.

If you are making a Request to Delete your Personal Information, we will re-confirm with you that you really want your information deleted after verifying your request.

If we cannot respond to or comply with your Request to Know or Request to Delete (for example, because we cannot verify your identity or because an exception applies), we will explain the reasons we cannot comply with your request. For data portability requests, we will select a format in which to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before proceeding with your request.