(Updated January 21st, 2021)



This California-Specific Privacy Rights Notice supplements our Privacy Policy with regard to visitors, users, and others who reside in the State of California and with regard to personal information collected or disclosed within the State of California.  We adopt this notice to comply with the California Consumer Privacy Act of 2018, California Civil Code sections 1798.100 et seq. (the “CCPA”) and other applicable California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

This notice provides California residents with notice of our practices and notice of their specific rights regarding their personal information.  This notice also describes such individuals’ rights and how to exercise those rights.


Notice of Categories of Personal Information Collected:

Without limiting the descriptions above regarding what information we may collect, we have collected the following categories of personal information about California consumers in the last twelve (12) months via the means described above:


Notice of Purposes for Categories of Personal Information Collected and/or Sharing for a Business Purpose:

Without limiting the description of our purposes for collection and use of information described elsewhere in this Policy, with respect to the categories of personal information noted above, we may also use such information for business or commercial purposes as follows:


Notice of 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:

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months. (CA. Civil Code section 1798.100, 1798.110, or 1798.115) Once we receive and confirm your verifiable consumer request, we will disclose to you (at your option):

Right to Delete:

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. (CA. Civil Code section 1798.105) Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request in whole or in part if retaining certain information is necessary for us or our service providers to:

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

Exercising Your Rights:

To exercise the right to know or the right to delete described above, please submit a verifiable consumer request to us by either: 

You may only make a verifiable consumer request to exercise your rights under the CCPA twice within a 12-month period. The verifiable consumer request must:

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.  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.

Response Timing, Verification and Format:

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

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request. 


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

Appointing an Agent:

You may designate an authorized agent to make a request under the CCPA on your behalf.