Privacy Center

Privacy Policy - For Users in the European Economic Area

Last Updated: 02/15/2024

Topics

• Introduction
• Personal Data We Collect
• Use of Your Personal Data
• Disclosures of Personal Data
• Links to Third-Party Websites
• Security of Your Personal Data
• Retention of Your Personal Data
• Marketing
• B2B Services
• Children
• Your Data Protection Rights
• Cookies
• Data Transfers Outside of the EEA
• Changes to This Policy
• Contact Us

Introduction

Back Porch International, Inc. d/b/a Same Sky (“Company”, “we”, “our”, or “us”) is committed to protecting the privacy and security of your personal data. This Privacy Policy (the “Policy”) is intended to comply with the requirements of the European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation (the “GDPR”). This Policy applies only to users accessing this website from a member state of the European Economic Area (the “EEA”). If you are located outside of the EEA, please see our General Privacy Policy.

Contact information of the controller of personal data:

• Back Porch International, Inc. d/b/a Same Sky
• 6405 SW Rosewood St, Ste C
• Lake Oswego, OR 97035
• USA
• Email: privacy@sameskydevices.com

This Policy explains how the Company uses the personal data we collect about you when you access or use our website, products or services. This Policy also describes your rights regarding the personal data that we hold about you, including how you can access, correct, and request erasure of your personal data. In this Policy, “personal data” means information that identifies, or which could reasonably be used to identify, an individual.

Personal Data We Collect

We collect personal data from you in connection with your access to and use of our website, purchases of our products and services, or if you provide us with personal data through other channels, such as social media, event registrations or customer surveys. You provide some of this data directly, and we get some of it by collecting data about your interactions with and use of our products and services. We may also receive some data about you from third parties, such as our Business Partners, as well as publicly accessible sources. The data we collect depends on the context of your interactions with us, the products and services you use and the choices you make (including your privacy settings) and it can include the following:

Name and contact information. Your name, email address, postal address, telephone number and your company details.

Payment data. Data to process payments, such as your billing information, transaction data, credit/debit card number and the security code associated with your card.

Credentials. Passwords and other security information used for authentication and account access.

Account history. Your purchase history, contact history, and saved items.

Feedback. Your comments and responses to surveys, promotions and requests for feedback.

Demographic data. Data about you, such as country you reside in and your preferred language.

Device and usage data. Information about how you use our website, IT, communication and other systems.

Other information collected automatically from your device. When you access and use our website, we also automatically collect data, including personal data, using cookies, pixels and local storage. This includes usage details, IP addresses, browser type, domain names, access times, frequency of your visits to our website, the routes by which you access our website, your use of hyperlinks available on our website, and information collected through cookies, and other tracking technologies. For detailed information about the cookies we use, please see our Cookie Policy.

Use of Your Personal Data

We use the data we collect to provide you with our products and services, respond to your inquiries, maintain your accounts, personalize and improve our website, as well as advertise and market to you. For these purposes, we combine data we collect from different sources, including sales intelligence platforms (such as ZoomInfo or Dun & Bradstreet), marketing automation and analysis systems. We rely on a variety of legal reasons and permissions (what is sometimes referred to as “legal bases”) to process data, including your consent, a balancing of legitimate interests, contract performance, and compliance with legal obligations, for a variety of purposes listed below. The specific purposes for which we process your personal data are as follows:

• Providing our Products. We use data to present our website and its contents to you, process and fulfill orders, provide information regarding products and services, provide notices about your account/subscription, and generate invoices and other order and payment related documentation. The legal bases for this use are (1) the performance of our contract obligations to you (Article 6(1)(b) of the GDPR), and (2) our legitimate interest in providing positive shopping and browsing experiences to our customers and visitors, maintaining a functional website, and ensuring appropriate administration of our business (Art. 6 (1)(f) of the GDPR).
• Customer Support. We use data to manage customer relationships, communicate with you, and address complaints, and handle returns, replacements or repairs. The legal bases for this use are (1) performance of our contract obligations to you (Art. 6(1)(b) of the GDPR), and (2) our legitimate interests, including the ability to communicate with our customers, maintain customer relationships, and properly administer our website, products, and services (Art. 6 (1)(f) of the GDPR).
• Personalization. We use data to provide interactive features on our website, recognize when you return to the website, estimate our audience size and usage patterns, store information about your preferences, analyze the overall use of our website and products, and analyze other interactions with our business. The legal basis for this use is our legitimate interest in better understanding user needs and expectations as well as supporting, improving and securing our website, products and services (Art. 6 (1)(f) of the GDPR).
• Product Improvement. We use data to improve our products and our website, add new features and capabilities. The legal basis for this use is our legitimate interest in providing you with a functional, more intuitive website and best possible products and services (Art. 6 (1)(f) of the GDPR).
• Advertising, Offers and Promotional Communications. We use data to create, target, and send direct marketing communications by email and telephone for marketing-related purposes. For instance, we retain your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which we believe you may also be interested in. The legal bases for this use are (1) your consent to receive our messages ), and (2) our legitimate interest in promoting our business, building and developing relationships with our clients and striving to sell our products and services (Art. 6 (1)(f) of the GDPR).
• Legal Compliance. We use data to comply with our legal and regulatory obligations, resolve disputes, or to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. The legal bases for this use are (1) compliance with our legal obligations (Art. 6(1)(c) of the GDPR), and (2) our legitimate interest in asserting and protecting our legal rights, your legal rights, and the legal rights of others (Art. 6 (1)(f) of the GDPR).
• Security and Fraud Prevention. We use data to prevent fraud and other criminal activity. The legal basis for this use is our legitimate interest in ensuring security of our website, products and services, preventing and detecting security breaches, fraud and other criminal or malicious activities (Art. 6 (1)(f) of the GDPR).
• Core Business Functions. We use data to create and maintain copies of our business records generally. We use data to analyze our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business. The legal bases for this use are (1) compliance with our record-keeping legal obligations (Art. 6(1)(c) of the GDPR), and (2) our legitimate interest in ensuring access to the information necessary to properly and efficiently run our business in accordance with this Policy (Art. 6 (1)(f) of the GDPR).

Disclosures of Personal Data

We may disclose your personal data to third parties in the following circumstances:

(1)Our Service Providers. We may share your personal data with third parties that perform services for us, including but not limited to, payment processing, analytics services, sales intelligence, information technology, product fulfilment, web hosting, customer support, fraud control, advertising and marketing, investigating fraudulent activity, mail, email and text message distribution, and the administration of surveys, promotions, contests or events. We only share the data that the service providers need in order to perform services for us. Since our service providers are located around the world, please note that these disclosures may involve cross-border transfers. Please see “Data Transfers Outside of the EEA” section below for more information about transfers of data outside of the EEA.

(2)Our Business Partners. We may share your personal data with third parties who work with us to provide our products and services to customers, including but not limited to, distributors, and manufacturer sales representatives (collectively, “Business Partners”). We require Business Partners who receive personal data to handle it in a manner consistent with this Policy and any applicable privacy and data protection laws.

(3)Corporate Transactions. We may disclose or transfer your personal data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company about the users of our website, products, and/or services is among the assets transferred.

(4)Professional Advisors. We may share your personal data with our legal, insurance, financial or other advisors in connection with the corporate transactions noted above or in connection with the management of our core business operations.

(5)Compliance with Law. We may disclose your personal data when we believe the disclosure is necessary to comply with the applicable law or legal process (including any court order, subpoena, warrant, or government/regulatory request); to establish, exercise, or defend against legal claims (whether in a court proceeding or in an administrative or out-of-court procedure); or to protect the rights, property or safety of the Company, our customers, employees, agents or others.

(6)Fraudulent Activities. We may disclose your personal data to credit reference agencies to report and prevent fraudulent purchases and other fraudulent activities.

(7)Consent. We may share your personal data with third parties when we have your consent to do so, including fulfilling the purpose for which you provided your personal data to us.

Links to Third-Party Websites

Our website may offer links to websites that are not run by us but by third parties. If you visit one of these linked websites, you should read the website’s privacy policy, terms and conditions, and their other policies. We are not responsible for the policies and practices of third parties. Any information you give to those organizations is dealt with under their privacy policy, terms and conditions, and other policies.

Security of Your Personal Data

We use appropriate physical, technical and organizational security measures to protect your personal data against unauthorized access and accidental or unlawful destruction, loss, use or alteration. Your personal data is generally stored in our databases or databases maintained by our service providers. Many of these databases are stored on servers located in the United States. We take appropriate measures, by contract or otherwise, to provide adequate protection for personal data that is shared with a third party or transferred to another country, including transfers within our Company. Please see “ Data Transfers Outside of the EEA ” section below for more information about transfers of data outside of the EEA.

Retention of Your Personal Data

We will retain your personal data only for as long as is necessary for the purposes for which the data was collected or as long as we have a legitimate interest in continuing to retain the data. Specifically, we consider the following criteria in determining the period for which your personal data will be retained in accordance with this Policy: (a) any applicable legal requirements to retain data for a certain period of time; (b) any retention obligations related to actual or potential litigation or government investigations; (c) any retention requirements in relevant agreements with our Business Partners; (d) any retention requirements related to our service provider agreements; (e) the date of your last interaction or communication with us; (f) the length of time between your interactions with us; (g) the sensitivity of the data; and (h) the purposes for which the data was collected. For instance, we retain your personal data for as long as you have your account, or as long as is needed to be able to provide the services or products to you, or for as long as is necessary to provide support-related reporting and trend analysis. If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep personal data as required, after an account is closed or is no longer necessary to provide services.

Marketing

We would like to send you information about our products and services that we think you might like. Whether you have consented to receive marketing or chose not to object to receiving marketing communications from us in connection with products or services similar to those you have previously purchased from us, you may always opt out at a later date. You have the right at any time to stop our Company from contacting you for marketing purposes by emailing us at privacy@sameskydevices.com and stating your request.

B2B Services

Some of our products and services are intended for use by our business associates, including our Business Partners and business customers (“B2B Services”). When our business customers use B2B Services, we process personal data of individuals representing such business customers at their direction and on their behalf, as a service provider. Your use of B2B Services is administered by the relevant business entity (i.e., your company). In such cases, the privacy policies of the relevant business entity apply and not this Policy. If you have any privacy questions related to your personal data being processed in relation to a B2B Service, you should contact your business entity directly.

Children

Our website is not suitable for those under the age of 16. We do not knowingly solicit or collect information from or about children under the age of 16.

Your Data Protection Rights

We want to make sure you are fully aware of all of your data protection rights, which include the following:

• The Right to Access – You have the right to request copies of the personal data that we are processing about you, which we will provide to you in an electronic form.
• The Right to Rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
• The Right to Erasure – You have the right to request that we delete your personal data, under certain conditions.
• The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The Right to Object to Processing – You have the right to object to our processing of your personal data, under certain conditions.
• The Right to Data Portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The Right to Withdraw Consent – If you have provided us with a consent to use your personal data, you have a right to withdraw that consent at any time. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
• Right to Lodge a Complaint with a Supervisory Authority – You have the right to lodge a complaint with a data protection authority. You can contact the data protection authority of your place of residence, place of work or of an alleged infringement of the GDPR. The supervisory authority in Germany is:
  • Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
  • Graurheindorfer Straße 153
  • 53117 Bonn
  • Phone: +49 228 997799 0
  • Email: poststelle@bfdi.bund.de
  • Website: https://www.bfdi.bund.de/anschriften

If you make a request to exercise your rights, please contact us and we will respond within one month. Our contact information is provided in the “Contact Us” section below.

Cookies

Our website uses cookies. A “cookie” is an information file that is stored on your device when you visit a website. Cookies and related technologies improve your user experience by saving your preferences, personalizing your browsing experience, storing information and products in your shopping cart, and enabling the delivery of interest-based advertising. When you visit our website, we collect information from you automatically through cookies or similar technology. To learn more about cookies, please visit www.allaboutcookies.org.

Based on their function and intended purpose, cookies can be divided into four categories:

With respect to cookies and similar technologies that are not strictly necessary for the provision our services, we seek consent from users in the EEA. If you visit our website in one of the EEA countries, you will be shown information about your choices, including whether you can accept or reject certain categories of cookies. Additional information regarding cookies and your cookie options can be found at the Cookie Preferences section of our website.

Analytics and Advertising. We use third-party analytics services to better understand how users engage with our website, including services provided by Google Analytics, Zoominfo, and Dun & Bradstreet, among others. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our products and services in order to provide us with reports and metrics that help us evaluate usage of our website, improve performance, and enhance user experiences. We also use third-party advertising services provided by Google Ads, LinkedIn and others.

Targeted Advertising. We allow selected third parties, including the analytics and advertising entities noted above, to place cookies and pixels on our website. These third parties may collect information about your online activities over time and across third-party websites. We and these third-party ad companies use this information to provide you with relevant ads and to evaluate performance of such ads.

Data Transfers Outside of the EEA

We transfer personal data from the European Economic Area to the United States, Canada, Japan, and other countries, some of which may not have been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority capable of addressing your complaints. While in such jurisdiction, your personal data may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction. When we engage in such data transfers outside of the EEA to countries without an adequacy decision, we ensure that there are appropriate safeguards in place to protect your personal data.

For more information about the safeguards implemented for specific transfers, please contact us at privacy@sameskydevices.com.

Changes to This Policy

This Policy is current as of the effective date identified at the top of this page. Changes to this Policy will be posted on this site, along with information on any material changes. We reserve the right to update or modify this Policy at any time and without prior notice. Any modifications will apply only to personal data collected after the posting.

Contact Us

If you have any questions about this Policy or our use of your personal data, please email us at privacy@sameskydevices.com, or write us at Back Porch International, Inc. d/b/a Same Sky, Attn: Shanari Baird, 6405 SW Rosewood St, Suite C, Lake Oswego, OR 97035, USA.

Notice at Collection and Privacy Policy for California Residents

Last Updates: 02/15/2024

Topics

• Introduction
• Notice at Collection
• Information Sources
• Information Sharing
• Your Rights Under the CCPA
• Exercising Your Rights
• Changes to Our Privacy Policy
• Contact Information

Introduction

Back Porch International, Inc. d/b/a Same Sky (“Company”, “we”, “our”, or “us”) respects your privacy and is committed to protecting it through its compliance with this Privacy Policy for California Residents (this “Policy”). This Policy supplements the information contained in the Company’s General Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Policy to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”), and any terms defined in the CCPA have the same meaning when used in this Policy.

Notice at Collection

Personal Information

Information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer, household, or device constitutes personal information ("Personal Information"). Personal Information does not include publicly available information from government records or deidentified or aggregated consumer information. We may collect and use Personal Information in accordance with the business purposes listed under this Policy (see Business Purposes). In the last twelve (12) months, we have collected the categories of Personal Information as indicated in the chart below. We may also sell or share the categories of Personal Information as indicated in the chart below. The Company does not retain Personal Information for longer than is reasonably necessary to achieve the purpose for which it was collected or as required by law.

Sensitive Personal Information

Personal Information that reveals any of the information listed in the table categories below constitutes sensitive personal information (“Sensitive Personal Information”). We may collect and use Sensitive Personal Information in accordance with the business purposes listed under this Policy (see Business Purposes). In the last twelve (12) months, we have collected the categories of Sensitive Personal Information as indicated in the chart below. We may also sell or share the categories of Sensitive Personal Information as indicated in the chart below. The Company does not retain Sensitive Personal Information for longer than is reasonably necessary to achieve the purpose for which it was collected or as required by law.

Business Purposes

We may use or disclose the Personal Information and Sensitive Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the Personal Information.
• To provide, support, personalize, and develop our website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity.
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• To maintain, improve, upgrade, or enhance our products and services.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including billing and collections.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To comply with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes, or opinions).
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our website users and/or consumers is among the assets transferred.

Information Sources

We obtain the categories of Personal Information and Sensitive Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you contact us, utilize the website chat function, complete forms, or purchase products and services.
• Indirectly from you. For example, from observing your actions on our website.
• Business partners, service providers and other third parties (e.g., our payment processors).
• Through passive collection of information about your interactions, including page clicks, time spent, or other automatically collected meta-data.
• Internet cookies.
• Other publicly available sources.

Information Sharing

We may (i) share your Personal Information with a third party for purposes of cross-context behavioral advertising, (ii) or disclose your Personal Information and Sensitive Personal Information to a third party for a business purpose. As discussed below, you have the right to opt-out of any such third party disclosures, which do not include information about individuals we know are under the age of 16. In the preceding twelve (12) months, the Company has shared or disclosed for a business purpose the following categories of Personal Information and Sensitive Personal Information to the categories of third party recipients indicated below. We do not sell Personal Information or Sensitive Personal Information.

Your Rights Under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, and Correct), we will disclose to you:

• The specific pieces of Personal Information we collected about you (also called a data portability request).
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• The Personal Information categories sold or shared, if any, and the categories of third
• The Personal Information categories disclosed for a business purpose, if any, and the categories of persons receiving the Personal Information.
• Our business or commercial purpose for collecting, selling, or sharing that Personal Information.

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, and Correct), we will review your request to see if an exception allowing us to retain the information applies. 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 the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract you have entered into with us.
• Help 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 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.

Right to Correct

You have the right to request that we correct any inaccuracies in your Personal Information we hold about you, considering both the Personal Information’s nature and processing purposes. Upon receiving your request (see Exercising Your Rights to Know, Delete, and Correct), we will use commercially reasonable efforts to:

• Correct the Personal Information on our existing systems or alternatively, delete the contested Personal Information if the deletion does not negatively impact you or if you consent to such deletion.

Right to Opt-Out

You have the right to prevent the sharing of your Personal Information to third parties at any time by requesting that we stop doing so (see Exercising Your Rights to Opt-Out).

Right to Limit Sensitive Personal Information

You have the right to limit how we use and disclose your Sensitive Personal Information by requesting that we restrict our use and disclosure of such Sensitive Personal Information to the “Permitted Sensitive Personal Information Purposes”, which allow us to collect, use, and disclose Sensitive Personal Information for the following purposes, even after you exercise your limitation rights:

• To perform services or provide goods that an average consumer requesting those goods or services would reasonably expect.
• To prevent, detect, and investigate security incidents compromising Personal Information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed our business and to prosecute those responsible for those actions.
• To ensure individuals' physical safety.
• For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with that us, so long as we do not: (i) disclose your Sensitive Personal Information to another third party; or (ii) use it to build a profile about you or otherwise alter your experience outside your current interaction with us.
• To perform services for the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing, storage, or providing similar services for the business.
• For products, services, or devices that we own, manufactures (directly or indirectly), or control, to: (i) verify or maintain the quality or safety of the product, service, or device; or (ii) improve, upgrade, or enhance the service or device.
• For purposes that do not infer characteristics about you.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.

Exercising Your Rights

Exercising Your Rights Under the CCPA

To exercise your rights under the CCPA, such as the right to know, delete, or correct described above, please submit a request by either:

• Calling us at 1-877-323-3576.
• Emailing us at privacy@sameskydevices.com

Right to Opt-Out

To exercise your right to opt-out, please submit a request by either:

• Calling us 1-877-323-3576.
• Visiting Do Not Sell or Share My Personal Information link and completing the submission form.

Right to Limit Sensitive Personal Information

To exercise your right to limit Sensitive Personal Information, please submit a request by either:

• Calling us at 1-877-323-3576.
• Visiting Limit the Use of My Sensitive Personal Information link and completing the submission form.

Submission and Response

Once you have submitted a request, we will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Also, we may ask you to describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Only you or a person that you authorize to act on your behalf, may make a Verifiable Consumer Request, as defined in the CCPA, related to your Personal Information. You may also make a Verifiable Consumer Request on behalf of your minor child.

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 the Personal Information relates to you. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights. We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

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.

We commit to respond to a Verifiable Consumer Request within 45 days of its receipt. If we require more time (up to a total of ninety (90) days), we will inform you of the reason and extension period in writing.

Authorized Agent

You may authorize an agent to exercise your rights on your behalf. When a request is submitted by an authorized agent, the Company will require the requestor to: (i) provide the authorized agent’s written permission to do so; and (ii) will require the requestor to verify their own identity directly with the Company. If the Company is unable to verify the identity of the requestor or does not receive proof from the authorized agent that the requestor authorized the agent to act on the requestor’s behalf, the request will be denied.

Changes to Our Privacy Policy

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the website and update the “Last Updated” date accordingly. When appropriate, we may notify you through other means. Your continued use of our website or services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or concerns regarding the policies and practices described in this Policy, please contact Shanari Baird, at 1-877-323-3576.