Privacy Policy - DoctusTech

Introduction

DoctusTech, Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.doctustech.com, or use any of our Services including but not limited to our mobile application, and our web application, HCC Doc, and HCC Doc 360, Doctus VBC Education Platform, Doctus VBC Data Integration Platform, (the “Website”), whether as a guest or a registered user and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Any and all services offered through our Website.
When you use our mobile application, Software-as-a-Service solution, or integration solution.
It does not apply to information collected by:
Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at:

2110 Artesia Blvd., Suite 280

Redondo Beach, CA 90278

privacy@doctustech.com

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
Protected Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act (definition available here: https://www.hhs.gov/answers/hipaa/what-is-phi/index.html ) through participating organizations and customers of ours;
That is about you but individually does not identify you; and/or
About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.

Information You Provide to Us.

The information we collect on or through our Website may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website are served by third-parties, including content providers, integration providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

Except as set forth below, at no time will any of your Personal Data be shared with any third party by Company. Your IP address is not linked to personally identifiable information, but is used to gather broad demographic data and to monitor statistics to improve the Service.
We use Traffic Data to help diagnose problems with its web servers, to administer the Website and to analyze user trends and behaviors.
We may share Traffic Data with certain third parties for the purposes of technical and customer support.
We collect, store, process, and analyze Website Data and produce Analytics. The term Analytics means user profiles and statistics, metrics, abstractions and other analyses that are based on or derived from your use of the Website and Website Data, which are developed in the aggregate with other data, results and measurements or in a manner that does not disclose any Protected Health Information (PHI) or any specific Service Data (except in aggregated or de- identified form).
Company will use your Website Data and exploit Analytics in the manner and for the purposes described in the Terms of Use and Services Agreement, including without limitation:
- to use Website Data to communicate with you;
- to access, record, collect, copy, store, process, analyze and use Website Data to provide the Website;
- to develop, improve, extend and test the Website (and underlying technology platforms); to design, develop and produce Analytics.
To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account, including expiration and renewal notices.
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 Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
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 DoctusTech, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by DoctusTech, Inc. about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use or applicable Services Agreement and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Health Insurance Portability and Accountability Act of 1996 (HIPAA)

In operating the Website, and as it relates to PHI, Company endeavors to comply in all material respects with Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Pursuant to HIPAA, medical facilities or professionals from whom Company receives information about patients may be Covered Entities (as defined under HIPAA), and we may serve as their Business Associate (as defined under HIPAA). As a result, some of the information we collect may constitute PHI (as defined in HIPAA).

Third-Party Connections and Integrations

You may be able to access the Website and/or communicate with the Website from, and you may be able to link or communicate from the Website to, applications, devices, distribution platforms and websites including but not limited to your Electronic Medical Record provider. These other applications, devices, platforms and websites are not operated or controlled by Company. Additional or different terms and conditions (including without limitation, privacy and security practices) apply when you access and use such other applications, devices, platforms and websites, which are not the responsibility of Company.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at privacy@doctustech.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA privacy notice for California Residents.

California’s “shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@doctustech.com or write us at: 2110 Artesia Blvd., Suite 280, Redondo Beach, California 90278.

Data Security

We have implemented measures desiagned to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Deletion Policy

At DoctusTech, we understand the importance of privacy and data protection. We are committed to complying with applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). As part of our commitment to protecting your privacy, we have implemented a data deletion policy that allows you to request the deletion of your personal data from our systems.

We keep your personal data only as long as necessary to provide you with the DoctusTech Service and for DoctusTech legitimate and essential business purposes, such as:

maintaining the performance of the DoctusTech Service
making data-driven business decisions about new features and offerings
complying with our legal obligations
resolving disputes

After your account is deleted, we keep some data for a longer time period but for very limited purposes.

Criteria used to determine the retention periods include:

What is the appropriate retention period to carry out our purpose? Our systems are designed to automatically ‘age out’ data based on a defined retention period. We choose the retention period based on its legitimate business purpose.
Do we need to keep data to ensure the service that users expect? We keep personal data for an appropriate period to deliver a personalized service to returning users or users that accidentally delete their account.

Is DoctusTech subject to a legal or contractual obligation to keep or delete the data? Examples include mandatory data retention laws, government orders to preserve data relevant to an investigation or data kept for the purposes of litigation. Additionally, DoctusTech will retain individual records of Continuing Medical Education credits earned to be in compliance with user audits. Conversely, we will remove unlawful content if the law requires us to do so.

What data do we delete?

We will delete any personal data that you have provided to us in connection with your use of our application, including:

Your name and contact information
Your performance data
Your history taking and preventative testing data

How do you request data deletion?

If you would like to request the deletion of your personal data, please contact us at info@doctustech.com. We will respond to your request as soon as possible and within the timeframes required by applicable data protection laws.

For in-app Premium users, there will be a delete button available in the application, allowing for a seamless process of removing your account.

For Enterprise users, your request for deletion will be forwarded to your administrator for approval. Once approved, the stated process in the policy will be followed.

What happens after we receive your deletion request?

Once we receive your deletion request, we will delete your personal data from our systems as soon as possible and within the timeframes required by applicable data protection laws. We will also take reasonable steps to inform any third-party service providers who may have access to your data to delete your data as well.

Exceptions to deletion

Please note that we may be required to retain certain data for legal or regulatory reasons, such as to comply with a court order or to establish or defend legal claims. In such cases, we will only retain the minimum amount of data necessary to meet our legal or regulatory obligations.

We hope that you find this data deletion policy helpful. If you have any questions or concerns, please do not hesitate to contact us.

INAPP PURCHASE:

DoctusTech values your privacy and is committed to protecting the personal information you provide to us when using our mobile application. Our InApp Purchase policy sets out how we collect, use, and protect your personal information when you use the App, including when you make in-app purchases (IAPs).

Information Collection:
When you make an IAP, we collect certain personal information from you, such as your name, email address, billing information, and any other information you provide to us. We use this information to process your purchase and to communicate with you regarding your purchase. We may also collect information about your device, such as the device type, operating system, and IP address.

Information Use:
We use the personal information we collect to provide the services you request through the App and to improve the App and our services. We may also use your personal information to contact you with offers and promotions related to our products and services. We may also use your personal information for research and analytics purposes, to help us understand how our customers use our App and services.

Information Sharing:
We do not share your personal information with third parties for their marketing purposes without your consent. We may share your personal information with third-party service providers who perform services on our behalf, such as processing credit card payments, providing customer service, and conducting research and analytics. These third-party service providers are contractually prohibited from using your personal information for any other purpose and are required to maintain the confidentiality and security of your personal information.

Information Security:
We take reasonable measures to protect the personal information we collect from unauthorized access, use, or disclosure. However, no security measures can be 100% effective, and we cannot guarantee the security of your personal information.

Your Rights:
You have the right to access, correct, or delete your personal information. You also have the right to request that we stop using your personal information for direct marketing purposes. To exercise these rights, please contact us at info@doctustech.com

Changes to this Policy:
We may update this Policy from time to time. We will notify you of any changes by posting the new Policy on the App or by other means. Your continued use of the App after any changes to this Policy indicates your acceptance of the new Policy.

Contact Us:
If you have any questions or concerns about this Policy or our use of your personal information, please contact us at privacy@doctustech.com

International Data Transfer:
If you are located outside of the country where our App is provided, please be aware that your personal information may be transferred to, stored, and processed in other countries, including the United States, where data protection laws may be different than those of your country. By using our App and providing us with your personal information, you consent to the transfer, storage, and processing of your personal information in other countries.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

2110 Artesia Blvd., Suite 280
Redondo Beach, CA 90278
privacy@doctustech.com
To register a complaint or concern, please privacy@doctustech.com.

Last Updated on: 04/02/2023

This Privacy Policy for California Residents supplements the information contained in DoctusTech Inc. Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- 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), clinical trial data, or other qualifying research 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.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	“A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.”	YES
C. Protected classification characteristics under California or federal law.	“Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).”	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Website.
Through integrations offered through our products that connect to third party applications such as Electronic Medical Record systems.

Use of Personal Information

We may use, or disclose the personal information according to our main Privacy Policy.
notice.

Sharing Personal Information

We may share your personal information according to our main Privacy Policy.We do not sell personal information.

Your Rights and Choices

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 and Data Portability

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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B 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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
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.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Emailing us at privacy@doctustech.com
Visiting https://www.doctustech.com/contact-us/

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by contacting us and proving your relationship to your child.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Photo identification verification.
- Verification through other means such as an identity verification software.
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 the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. [However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.]

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 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 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do 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 completing your request.

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.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.