Retention.com Data Services and Website Privacy Policy

Notwithstanding anything else in this policy, we and/or our partners may use pixels and pixel tags, and place, read or use cookies that collect information from your device and/or Internet browser.

• Information That We Collect and Use in Our Services
• How We Use the Information
• How We Share Information
• Your Marketing and Opt-Out Choices
• Cookies and Similar Technologies
• Data Collected Through Our Corporate Website
• Links
• Security and Data Integrity
• Changes to this Privacy Policy
• Storage of Information in the United States
• Your California Privacy Rights
• Contact Us

These cookies do not contain personally identifiable information, however, it may be possible for our third-party business partners to combine it with other information in order to identify your email address or other personally identifiable information about you. For example, the cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form.

By using our Service, you agree that us and our third-party partners may store, sell, port, combine with other data, monetize, utilize and otherwise use either (i) the personally indefinable information about you that we share with them, or (ii) the personally identifiable information they discover and/or identify as described above. Visitors can also express their choices for display advertising, through the following platforms: Digital Advertising Alliance opt-out platform or the Network Advertising Initiative opt-out platform. We and/or our partners may also use cookies for delivering personalized advertising emails. These cookies are used to identify the visitors of our advertisers’ websites and send personalized emails based on the visitors’ browsing experience.

We and/or our partners use cookies, pixels and other tracking technology to associate certain Internet-related information about you, such as your Internet Protocol address and what Web browser you are using, with certain of your online behaviors, such as opening emails or browsing websites. Such information is used to customize ads or content and may be shared with our partners.

GetEmails, LLC dba Retention.com (“We,” “Our,” “Retention.com”) provides data marketing services (the “Services”) designed to help for-profit and not-profit organizations, and companies that work with them, to market their goods and services in a relevant and efficient way. Our solutions, many of which are described on this website, are used principally to support email marketing.

We take very seriously the privacy interests of the individuals whose information we handle and maintain in our database.  We provide this Privacy Policy (“Privacy Policy”) to explain how we use and manage information, and what rights consumers have to control how their information is used in marketing.

To review the “Addendum” we have created specifically to address disclosures required under the California Consumer Privacy Act, please see our “ADDENDUM FOR CALIFORNIA RESIDENTS” below.

We also operate corporate websites, designed for our own customers and prospective customers, and others who want to learn about our services. We address the information we collect and use for those business purposes (such as information we use to communicate with our corporate customers, and potential customers) in Section 6 of this Privacy Policy.

1. Information That We Collect and Use in Our Services

and Use in Our Services

• First and last name

• Personal email and phone number

• Professional email and phone number

• Information and actions associated with an email, such as whether an email has recently         been in use, and amount and type of marketing or “email open” activity associated with an    email

• IP address

• A cookie or device identifier, which uniquely identifies your browser or device

• Usage data related to your email interactions, such as whether you receive, open or respond    to an email, and related information

• Usage data related to your website interactions, such as whether you visit or log in to a    website, page visits and related information

• Demographic information, such as inferred income or age range, household size, or home ownership

• Information regarding consumer interests, such as what type of products you may be    interested in, or what types of hobbies you might have, such as whether you are a likely pet    owner or a sports or art enthusiast.

Some of the above information may be inferred – for instance, if a household is in a particularly wealthy area, we might infer a particular income range.

We may combine any of the points of Information we collect or receive with other Information.

Retention.com also receives information through this website (and any other website we operate), and our business operations. We describe this information in Section 6.

2. How We Use the Information

Information

Retention.com uses the Information for various purposes, including the following.

As Part of Our Services: • Data Marketing Services. Our Services include providing marketing information to our customers, generally regarding which customers or prospective customers are most likely to be interested (or disinterested) in certain offers. We also help our customers identify and understand their customers better, by providing insights about them. Our customers include (but are not limited to) small and medium-sized businesses, ad and media agencies, brands and marketing data platforms that help their customers to market and advertise to their own customers (and prospective customers). Our customers also may include other data compilers, who work with their own customers.

• Retargeting Services. We sometimes help our customers to “retarget” marketing content to website visitors. In particular, our Services help customers to contact (e.g. through email or telephone) people who visited or logged in to their websites by cross-referencing information such as cookie identifiers and emails for those purposes.

• Additional Marketing Services. Other Services we may provide to our customers (or help them to provide to their own customers), which may supplement the above Services, may involve (a) assisting customers to target and optimize email campaigns, display, or other marketing; (b) measuring how effective marketing campaigns have been, by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases; (d) helping customers to detect and prevent fraud and provide “validation” or data hygiene services, e.g., by verifying or removing or correcting old, incorrect or outdated information or evaluating whether an email address recently has been active.

To Operate Our Services

We also use the Information described above for our own internal purposes – such as to improve, test, update, and verify our own database; develop new products; operate, analyze, improve and secure our Services and our databases and servers.

3. How We Share Information with Third Parties, including Service Providers

with Third Parties, including

Service Providers

Retention.com may share the Information with customers, marketing services and platforms, as well as service providers that help us to provide the Services we’ve described above (or other services we may add in the future).  This includes sharing in the following ways:

• With Our Customers: As described above, we license the Information in various ways to our customers (and something to partners and resellers, who license the Information to their customer), when we provide our Services. We may sometimes share the Information with those Customers’ service providers (for instance, a provider that prints or sends mailings for a Customer).

• With Our Partners: We also may share the Information, including personally identifiable information and Audience Segments, with business and data partners to help provide more tailored targeted marketing, advertising and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our customers’ behalf. • With Our Service Providers: We share the Information with a variety of service providers in order to operate, protect and advertise our Services and maintain our website(s). For instance, we may share the Information with our tech, hosting and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security vendors, payment vendors (as to our business to business information), and other companies help us deliver, secure or develop our Services.

• Corporate transfers: If Retention.com, its stock or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity, and may be shared during due diligence in anticipation of any such transaction.

• Affiliates, parent companies and subsidiaries: Retention.com may share some or all of the Information in our possession with any affiliated or subsidiary companies (if we ever have any).

• As required by law or to protect any person or entity: Retention.com may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Retention.com, our customers, or any other person or entity.

4. Your Marketing and Opt-Out Choices

Choices

There are multiple ways that you can opt-out of having the Information used to market to you:

• First, you may visit our opt-out page at https://app.retention.com/optout to have your personal information removed from our database. We will then in most cases remove your personal information from our active marketing databases within 15 business days, from the time we received the opt-out request. We may in certain cases (and where legally permissible) require that you verify any of the information that you submit, such as through a verified email response or another verified response.

• If you would like to opt-out of email marketing from a particular brand (such as a customer of ours), click on the “opt out” or “unsubscribe” link in the footer (at the bottom) of the marketing email you have received.

• While we generally do not engage in “direct mail” marketing, some of our customers and partners may. If you are interested in opting out of this type of marketing — i.e., materials received in your physical mailbox — we recommend that you visit the DMA Choice website, at thedma.org. The DMA Choice service is run by the Direct Marketing Association and allows you to follow few easy steps to ensure that your marketing preferences are honored.

• To opt out of our Retargeting Services described in section 2, go to and click on the “Opt Out” bar on that page. You will need to do that from each browser that you use (because the retargeting and thus the “opt out” are cookie-based), and if you clear your browser cookies you will need to opt out again.

• If we market to you by email in our corporate capacity — such as if you are a customer or prospective customer of ours and we send information about our Services — you may “unsubscribe” from our marketing emails through a link placed in your emails.

5. Cookies and Similar Technologies

Technologies

Cookies and How We Use Them Retention.com and its business partners use certain industry-standard technologies, including cookies and similarly functioning technologies, which we describe below. We and/or our service providers use these technologies on our website, for instance, and our partners may use these technologies in their own marketing services.

We may work with third parties or service providers to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags, and similar technologies on your browser, which may have cookies with varying expiration periods. Those partners may likewise collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a  unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given website visit.

We, or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

6. Data Collected Through Our Corporate Website

Corporate Website

Information Collected

Retention.com collects information from users of our website(s) (including any page on which this Privacy Policy is posted), including:

• The domain name and IP address of a user’s web browser, as well as a user agent, time stamp and other information about a user’s browser or device.

• Information about what content and pages users access, utilize or visit on our website, or how they interact with our content — for instance, if they spent a certain amount of time reviewing a particular blog post or description of particular services.

• Information, including personally identifiable and contact information that you provide, which could include (for instance) survey information, sign-up information (e.g., if you sign up for our webinars, events or newsletters), requests for information, mailing addresses, and email addresses.

How Retention.com Uses the Information We Collect Through Our Website

We use the Information we collect through our website(s) to do the following:

• Create and manage your user account.

• Provide Services you have requested.

• Respond to and communicate with you (including regarding news and updates about our services).Send you offers and ads for our products and services, when you browse the website(s) or other companies’ websites on the Internet (such as to “retarget” you with information about our Services).

• Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars.Perform data analysis (including market research).

• We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, and advertisements offered, including (but not limited to), those provided on or through our services.

• We may use IP addresses to help diagnose problems with our servers and to administer our website(s). We may also use IP addresses to help identify visitors to our website(s) for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our website(s), how visitors navigate through the website(s), and how we may tailor our website(s) to better meet the needs of our visitors. We also use this Information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.

• If we collect Information from “offline” sources — such as if you provide us your business card at a trade show — we will maintain that information and use it for marketing and business purposes as well.

How Retention.com Shares the Information We Collect Through Our Websites

We may sometimes share or otherwise disclose the Information we collect about you, as described in this Privacy Policy or otherwise disclosed to you when you provide us with the information, including as follows:

•We may share the Information with service providers who help us deliver the services you request or we provide. For instance, we share the Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security and data hygiene vendors, payment vendors (as to our business to business information), and other companies that may help us deliver or develop Services.

• We may share the Information to communicate with you and market to you, including through email, direct mail or display media.

•We will disclose your PII (or other Information) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.

•If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process leading up to any such transaction.

Our website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet).

7. Links

This website may provide links to other websites that Retention.com thinks users may be interested in. Retention.com is not responsible for the privacy practices of these other sites or companies.

8. Security and Data Integrity

Retention.com takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. However, you should be aware that neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion.

9. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website. Please check back to learn of any changes to this Privacy Policy.

10. Storage of Information in the United States

If you are accessing our website from outside of the United States, your connection likely will be through and to servers located in the United States and all Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States (we generally store the Information used in our Services in the United States). Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

11. Your California Privacy Rights

If you are a resident of California, the California Consumer Protection Act (CCPA) provides certain rights of disclosure, access and deletion of your Information as described below in the “Addendum for California Residents” at the end of this Privacy Policy.

12. Contact Us

Retention.com has a designated privacy contact. If you have questions related to this Privacy Policy, or regarding our products or services, please contact us at support@retention.com

We appreciate your comments and questions regarding Retention.com’s privacy practices.

Last updated:  May 3, 2022.

ADDENDUM FOR CALIFORNIA RESIDENTS

Last Modified:  May 3, 2022

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA):

1. Our Collection of Personal Information— the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,

2. Our Disclosure and Sale of Personal Information— the types of recipients to whom we disclose or sell Personal Information.

3. Our Business Purposes—  our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.

4. Your California Privacy Rights and Choices— what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

Category

Identifiers, e.g., name; alias; postal address; mobile ad or cookie identifiers; IP address; telephone number; email address; social network handles

Categories of Sources• Data compilers and consumer data resellers, informational and retail websites (“Commercial Source Categories”)

• Public records and other publicly available sources

• Government entities

• Social networks

Commercial or transactions information

E.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Commercial Source Categories

• Public records and other publicly available sources

Internet or other electronic network activity information

E.g., browsing history; online interests.

• Commercial Source Categories

Professional or employment-related information

E.g., current or past job history or job title.

• Public records and other publicly available sources

• Commercial Source Categories

Inference Data

E.g., consumer information or preferences.

• Commercial Source Categories

  2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category

Categories of Third Parties We Share With

Whether We “Sold” This Category of Personal Information in the Last 12 Months

Identifiers, e.g., name; alias; postal address; mobile ad identifiers; IP address; telephone number; email address; social network handles

• Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, content publishers, non-profit organizations, business-to-business services and organizations, consumer surveys and survey companies, affiliate networks (“Commercial Recipient Categories”)

• Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers

• Social networks

Yes

Commercial or transactions information E.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Commercial Recipient Categories

• Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers

• Social networks

Yes

Internet or other electronic network activity information E.g., browsing history; online interests.

• Commercial Recipient Categories

• Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers, and social networks

Yes

Inference Data E.g., consumer information or preferences.

• Commercial Recipient Categories

• Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers

• Social networks

Yes

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction:  We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Sharing of Aggregate Information:  We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“ Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, at our discretion.

OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy and/or our website.

Our Purposes for collecting, using and sharing Personal Information Data marketing services, for example:

• Generally, creating data marketing tools and products for our marketer clients, as more fully described in our Privacy Policy (and on our websites). This includes our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential identifiers), data hygiene services (helping customers to evaluate, validate and correct personal information they hold), and security and anti-fraud services (helping customers to identify potentially fraudulent activity).

• Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.

• Assisting our Clients through our Services to provide their current and prospective customers with better service, generally related to the above.

• Creating “identity” graphs or associations between data points, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, cookie or device identifiers, phone number, email address).

  Additional marketing services, for example (which may overlap with “data marketing services” above):

• Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile, and social media marketing.

• Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.

• Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.

• Providing “hygiene” or “verification” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect, or outdated information.

  Operating our Services, for example:

• Testing, improving, updating and verifying our own database.

• Developing new products.

• Operating, analyzing, improving, and securing our Services.

  Other internal purposes, for example:

For internal operations, auditing, research, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.

We sometimes use the information collected from our own website, from social networks, from other “business to business” interactions (such as information we collect at trade shows) or from data compilers for the above, as well as for our own marketing purposes.

YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests (to the extent permitted by applicable law, we may charge a reasonable fee to comply with your request).

Sometimes, we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing or other data management services), in which case any consumer requests for opt-out, deletion or access to data must be made through that client: we therefore will forward any such requests to a named client, as feasible, such as where a client has been identified.

1. Right to request that we “do not sell” your personal information

You may request that we not “sell” your personal information. If you wish to make such a “do not sell” (also called an “opt out” request), please go to our “Do Not Sell” web form located at app.retention.com/ccpa_details . Alternatively, you can call our toll-free number, 855-306-2455, to request your opt out.   When you make such a request, we will retain your information on an internal “suppression” list, so that we may remove your data from our active database in the event we obtain it again at a later date.

2. Right to request deletion of your personal information

You may request that we delete any personal information that we collected from you, such as if you have been a customer of ours (Note that this is different from your right to “opt out” of us selling your personal information, which is described above; also note that we do not generally collect personal information directly from consumers). You may make a deletion request by calling our toll-free number, 855-306-2455. In our discretion, we may interpret your “deletion” request as a “Do Not Sell” request (and thus place it on a suppression list, as described above), if we in good faith believe that is what you are requesting.

However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

3. Right to request access to your personal information

California residents also have the right to request that we disclose what categories of your personal information that we collect, use, or sell. As a California resident, you may also request the specific pieces of personal information that we have collected from you. You may make such an “access” or “right to know” request here: app.retention.com/request_my_data, or by calling our toll-free number, 855-306-2455. We may withhold some personal information where the risk to you or to others’ privacy rights is too great to disclose the information.For security purposes (and as required under California law), we will verify your identity — in part by requesting certain information from you — when you request to exercise your California privacy rights.  For instance, if you request specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) that reasonably confirms you are the person you claim to be. 4. Right to nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.  5. Right to “opt-out” of the sale of your personal information

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” — including in the definition making available a wide variety of information in exchange for “valuable consideration.”

6. Information about persons under the age of 16

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

7. Authorized agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a legally sufficient power of attorney. We likewise may require that you verify your own identity, depending on the type of request you make.

Consumer Request Statistics Pursuant to California Delete Act

Pursuant to subdivision (c) of Section 1798.99.86 and Sections 1798.105, 1798.110, 1798.115, 1798.120, and 1798.121, during calendar year 2025, we received 23,323 requests. We complied with all 23,323 requests and denied none. The mean number of days within which we substantively responded to these requests pursuant to subdivision (c) of Section 1798.99.86 and Sections 1798.105, 1798.110, 1798.115, 1798.120, and 1798.121 was one (1) day. The median number of days within which we substantively responded to these requests pursuant to subdivision (c) of Section 1798.99.86 and Sections 1798.105, 1798.110, 1798.115, 1798.120, and 1798.121 was one (1) day. We denied zero (0) requests.