TPG Privacy Policy - TPG understands that you care about how information about you is used. This privacy policy (the “Policy”) explains how we collect information pertaining to businesses and business people ("Business Information") and all other types of information through our website and online services (the "Site"); how we maintain, use and share that information; and how you can manage the way information about you is handled.
“TPG” for purposes of this Privacy Policy includes The Pipeline Group, Inc., a California corporation, and its affiliates.
For residents of the State of California, find out more about your rights under the California Consumer Privacy Act of 2018 (“CCPA”) below.
Where does TPG get the Business Information for its Public Profiles?
TPG creates profiles of business people and companies, which we call "Public Profiles," from different sources. Once we have collected Business Information about a person or company, we combine multiple mentions of the same person or company into a Public Profile. The resulting directory of Public Profiles (the "Database") is then made available to the users of the Site and our customers and strategic partners.
TPG obtains the data for its Public Profiles in several ways including:
(1) Our search technology scans the web and gathers publicly-available Information.
(2) We license Information from other companies.
(3) Users contribute Business Information about themselves or other people and companies.
(4) Through market research surveys and phone interviews conducted by our in-house research team.
Customer Information
Customer Information Collected. TPG may collect the following information from or regarding its customers: (1) personal contact information regarding users of the Services (“User Information”); (2) information uploaded to our system by a user of the Services (“Uploaded Information”); and (3) usage logs regarding the use of the Site and Services, including logins and other actions taken, time stamps, IP address, and other usage data (“Usage Logs”) (collectively, “Customer Information”).
You may be a user that has been provided access to the Site through your company license agreement. Your employer may require that one or more users have global rights to access any and all information of every user that has access through the company. If you have questions or concerns regarding the rights of other individuals in your company to access your User Information, Uploaded Information, or Usage Logs, you should raise those concerns with the appropriate person at your company.
Use of Customer Information. Customer Information may be used for TPG’s legitimate business interests in connection with your use of the Site, including to respond to user inquiries and fulfill user requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Site. We may use Customer Information to better understand our users in general and to improve the content and functionality of the Site. We may use Customer Information to contact you in the future to tell you about services, promotions, opportunities, and other general information about TPG we believe will be of interest to you. We may use Customer Information to investigate and prosecute potential breaches of TPG’s security or license agreements.
TPG will not disclose Customer Information to any third party except in connection with a legitimate use as set forth herein, in connection with a bona fide legal dispute to which such information is relevant, in response to valid, compulsory legal process, or as otherwise required by law. TPG will, whenever possible, obtain confidentiality agreements from any person or entity to whom Customer Information is disclosed and ensure any recipients are committed to employing appropriate technological security measures.
TPG employs reasonable security and back-up procedures to protect Customer Information. However, in the unlikely event there is a loss or corruption of Customer Information, TPG is not responsible or liable for such loss or corruption. We encourage our users to retain copies of all Uploaded Information on their own system.
How else does TPG Collect and Use Information?
When you submit information through our Site. Visitors to our Site may choose to submit their name, email address and/or other information so that they can learn more about our services, register to take part in a TPG-sponsored event, or participate in a survey, contest or sweepstakes, among other things. By accessing, using, and/or submitting information through the Site, you consent to the practices described in this Policy with regard to the information collected thereby as described herein. If you do not agree with this Policy, you must delete all cookies from your browser cache after visiting the Site and refrain from visiting or using the Site.
When you use our Services. In order to use certain TPG products and services, you may be required to register as a user. From time to time, we may use your email address to send you information and keep you informed of products and services in which you might be interested. You will always be provided with an opportunity to opt out of receiving such emails. Your contact information may also be used to reach you regarding issues concerning your use of our Site, including changes to this Policy. A more detailed description of how we may collect and use customer information is found below under “Customer Information Collected” section above.
When you provide information to our customers. We receive information about our customers’ end-users from or on behalf of our customers. Because of the nature of our Services, this information may contain any type of data, but typically includes name, contact information, and company information, such as company name. We may also collect data about you automatically through your use of our Services, as described in the “Cookies and Similar Technologies” section below. If you are a visitor to or user of a website, application, or service on which a customer uses our Services, then any information that you provide through our Services is subject to the customer’s privacy policy and applicable terms. When we provide our Services to a customer, we act as a “data processor,” and the customer is considered to be the “data controller,” as further described in the “When TPG is a Controller” and “When TPG is a Processor” sections below.
When you refer a friend. If you choose to use our referral service to invite a friend to join TPG, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. TPG will use this information for the sole purpose of sending this one-time email and will not store your friend’s name or email address.
When you purchase our products and Services. If you purchase one of our online subscription-based Services, you may need to provide credit card information. We will use that information solely for the purpose of fulfilling your TPG purchase request. We will process credit card information in an encrypted form and will not sell, share, or use it again without your prior consent. We maintain physical, electronic and procedural safeguards to protect your information, and our employees and vendors are required to follow these privacy standards. (The only exceptions are described in the sections below on “Disclosures to Service Providers,” “Disclosures for Legal Reasons,” and “Disclosures to a Buyer of the Company”).
When you use TPG Integrations. As part of the Services, TPG may make available to its customers certain “Integrations.” In using TPG’s Integrations, such as TPG’s SFNA and web browser extensions, Business Information from customer’s CRM, MAT, or sales enablement software may be transmitted to TPG for purposes of matching or cleansing the customer’s data against TPG’s database as a feature of the Services. In that event, TPG may retain and store such Business Information for purposes of identifying potential contacts to supplement the Services, verifying the accuracy of such Business Information, removing out-of-date Business Information from the Services, or otherwise improving TPG’s research processes and the content provided through the Services. Information so received will not be attributable to the source. In the event that any customer wishes to opt out of TPG’s use of such information, they may do so by visiting the ‘Privacy Center’ within the TPG Salesforce Native Application and adjusting the appropriate controls.
When you connect the Services to your email or calendar. In order to provide certain Services, TPG may require access to your email account and/or calendar (e.g., through G-Suite or Office 365). Depending on the specific Services being used, we may collect email header information, email subjects, email bodies and attachments, and calendar meeting information such as meeting participants, meeting description, subject, and date and time of the meeting. Customers have control over what data is collected, including which mailboxes are connected, whether message attachments or content is collected, and which emails or email domains should not be collected. TPG’s access to and use of information received from Google Accounts will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
How TPG Uses the Information?
In addition to the uses described in the above section, we may also use information for one or more of the following purposes:
How TPG Shares Information?
Disclosures of Business Profiles. We may make any Business Information that our users contribute for inclusion in our Directory, that we collect from public web sources, that we collect through market research surveys and phone interviews conducted by our in-house research team, or that we license from third parties available to users of the Site, to our strategic partners, and to our customers. If you provide information, including Business Information, that information will be included in the Directory and thus can be viewed by third parties.
Disclosures via Public Directory. TPG makes certain limited Business Information from its Business Profiles publicly available in our Public Directory on our Site. The categories of Business Information that may be made available in the Public Directory include past or current name, company, company headquarters telephone number, office address, job title, and/or education information. Information in the Public Directory is publicly available to visitors who visit our Public Directory webpages on our Site.
Disclosures to Affiliates. We may share Business Information with our affiliates who may act for us for any of the purposes set out in this Privacy Policy, including our current and future parents, subsidiaries, and other companies under common control and ownership with TPG.
Disclosures to Service Providers. TPG may from time to time disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose. For example:
Disclosures to Integration Partners. In using TPG’s Integrations, such as TPG’s SFNA and web browser extensions, Business Information from TPG may be disclosed to a customer’s CRM, MAT, or sales enablement software as requested or directed by our customers.
Disclosures for Legal Reasons. We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements; (ii) to address a violation of the law; (iii) to protect the rights, property, or safety of TPG, its users, or the public; or (iv) to allow TPG to exercise its legal rights or respond to a legal claim.
Disclosures to a Buyer of the Company. If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to TPG may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Other Disclosures
If you register for a TPG event with a third-party speaker, your information will generally be shared with the speaker and any third-party sponsors or partners of the event.
We post customer testimonials on our Site which may contain the customer’s name. We always get consent from the customer prior to posting any testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@thepipelinegroup.io.
Our Site offers publicly accessible blogs or community forums. You should be aware that any content you provide in these areas may be read, collected, and used by others who access them. You can request the removal of your personal information from our blog or community forum by contacting us at privacy@thepipelinegroup.io. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
TPG will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual about whom the information pertains. TPG will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.
We also collect information using cookies, as described below.
Cookies
Most websites, including our Site, use a feature of your browser to set a small text file called a "cookie" on your computer. The site placing the cookie on your computer can then recognize the computer when you revisit the site to allow auto login and track how you are using the site.
When you visit our Site, our servers and/or those of our service providers automatically record certain information that your web browser sends, such as your web request, Internet Protocol address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, time and date of use and other information. We may link this information to information that you submit while on our Site, which does allow you to be personally identified.
You are free to decline cookies. You can configure your browser to accept all cookies, reject all cookies, erase cookies or notify you when a cookie is set. Electing to reject or disable cookies may substantially limit your ability to use our Site.
TPG may adopt other technologies that serve similar functions as cookies. If we do so, we will disclose it in this Policy.
Third Party Cookies
The use of cookies by our partners, affiliates, tracking utility company, service providers is not covered by this Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company and service providers may use session ID cookies in order to:
To disable or reject third-party cookies generally, please refer to the third-party’s relevant website.
How Can You Change or Delete Your Professional Information?
To find out if you are in the TPG database, send an email to privacy@thepipelinegroup.io. If you have a common name, please provide your geographical location or companies where you have worked.
Remove Your TPG Profile Completely. If you wish to completely remove your existing individual profile from the Directory, please email privacy@thepipelinegroup.io. If you make this choice, your name, employment history, and contact information (including email address) will be removed from our search results as soon as possible.
How Can You Change or Delete Your Company Information?
To find out if your company is in the TPG database, send an email to privacy@thepipelinegroup.io.
Remove Your Company TPG Profile Completely. TPG is a specialized web search engine, similar to Google but focused on finding information about companies and professionals. We gather all information about companies from corporate web sites, press releases, and/or SEC documents filed with the US government. The company summaries are created automatically by TPG’s software based on the information we find on those documents.
As a company policy, TPG does not remove company information from our search engine. If any of the company information is incorrect, please update your company profile.
How Can You Opt-Out of Certain Uses of Your Information?
TPG gives you the opportunity to “opt out” of having your information used for certain purposes.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication. After we receive your request, we will send you an email message to confirm that you have been unsubscribed.
TPG will not share information about you that you submit when you register for our Services with third parties for promotional uses unless you opt in to such sharing within your TPG account or TPG has separately acquired such information from other sources, in which case TPG will give you the opportunity to opt out via email.
You may also communicate your opt-out request to TPG by telephone or postal mail by using the contact information at the bottom of this Policy.
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of Internet transmission or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
We will retain your information for a period of time consistent with the original purpose(s) for which we collected it, as described in this Privacy Policy. We will retain your information (i) for as long as we have an ongoing relationship with you and as needed to provide you Services; (ii) as necessary to comply with our legal obligation(s); (iii) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (iv) as necessary to enforce our agreements. Retention periods will be determined taking into account the amount, nature, and sensitivity of your information and the purpose(s) for which it was collected. After the retention period ends, we will delete your information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of your information.
This Site contains links to other sites that are not owned or controlled by TPG. We are not responsible for the privacy practices of such other sites. When you leave our Site, we encourage you to be aware and to read the privacy statements of each and every website that collects personally identifiable information. This Policy applies only to information collected by this Site or in the method(s) otherwise discussed herein.
If you use our Site outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries in which we or our affiliates or subcontractors maintain facilities. The laws in the U.S. regarding personal information may be different from the laws of your state or country.
If you are a resident of the EEA, the UK, or Switzerland, the following information applies.
Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Sites. We process personal information on the following legal bases:
(1) with your consent; (2) as necessary to perform our agreement to provide Services; (3) as necessary for compliance with a legal obligation to which we are subject; and (4) as necessary for our legitimate interests in providing the Sites where those interests do not override your fundamental rights and freedom related to data privacy.
TPG’s collection of Business Information, and the creation and licensing of TPG’s Business Profiles and Directory, are within TPG’s legitimate interests to organize and make available business contact information given the limited impact of this data on an individual’s private life and that this information, unlike personal contact details, is widely disclosed. TPG has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities, the use of consent or opt-outs wherever possible, and the implementation of a privacy center.
Right to lodge a complaint: Users that reside in the EEA, the UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Per the applicable requirements of the General Data Protection Regulation (“GDPR”), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR, such as the EU Standard Contractual Clauses. Please see “Privacy Shield Frameworks” below regarding our compliance with the EU- and Swiss-US Privacy Shields.
Individual Rights: If you are a resident of the EEA, the UK, or Switzerland, you are entitled to the following rights under the GDPR. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.
When TPG is a Controller. TPG acts as a data controller when we collect and use information about data subjects who are visitors to our Site, as well as when we collect and use information about data subjects for purposes of creating and maintaining our Business Profiles and providing the Services. TPG’s Legal Officer can be contacted by email at privacy@thepipelinegroup.io.
When TPG is a Processor. When our customers use our Services, they are acting as the data controller and are responsible for ensuring that personal information collected about data subjects is being processed lawfully. In those circumstances, we are acting as the data processor, and receive personal information as agents of our customers merely for processing as instructed by our customers. Our customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all third-party individuals that are a visitor to or user of a website, application, or service on which a customer uses our Services have been provided with adequate notice regarding the processing of their personal information, have given informed consent where such consent is necessary or advised, and that all legal requirements applicable to the collection, use, or other processing of personal information through our Services have been met by such customers. Our customers are also responsible for handling data subject rights requests under appliable law, by their users and other individuals whose data they process through the Services. TPG’s obligations with respect to personal information for which we are solely a data processor are defined in our agreements with our customers and are not covered by this Policy.
The General Data Protection Regulation (“GDPR”) 2016/679
TPG endeavors to comply with the provisions of the GDPR as to any information in its possession regarding European Union-based persons (“data subjects”). As such, TPG only processes personal information on data subjects where it has a lawful basis to do so, which may include the consent of the person (especially in the case of website visitors who provide their information), performance of a contract, compliance with a legal obligation, or the legitimate interest of the controller or a third party. TPG provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten. For any opt-out requests or other inquiries related to privacy, please email privacy@thepipelinegroup.io.
In the course of obtaining data to be included on the Site, if TPG obtains Business Information regarding an individual that TPG has reason to believe is based in the European Union, TPG will provide such individual with a notice detailing the information TPG has on such person, the purpose for which it will be used, and informing such person of their rights with respect to such information, including the right to know what information TPG possesses on them, to correct such information, or to opt out of data collection entirely. Such persons may opt out of the TPG database by emailing privacy@thepipelinegroup.io.
Privacy Shield Frameworks
While TPG continues to be certified by and adhere to the principles of the Privacy Shield Frameworks, in light of the Court of Justice of the European Union decision regarding the legal effect of the EU-US Privacy Shield Framework, TPG does not rely upon the Frameworks to ensure the lawful transfer of data from EEA to non-EEA countries.
TPG complies with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. TPG has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, any rights you may have to binding arbitration before a Privacy Shield Panel, and please visit https://www.privacyshield.gov.
For information received under the Privacy Shield, TPG will require third parties to whom we disclose personal information to safeguard that personal information consistent with this Policy by contract, obligating those third parties to provide at least the same level of protection as is required by the Privacy Shield Principles. EU and Swiss citizens may choose to opt-out of such disclosures. TPG may have liability to you in case of failure to comply with the law or this policy in handling onward transfer of your information to third parties.
In compliance with the Privacy Shield Principles, TPG commits to resolve complaints about your privacy and its collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Policy should first contact TPG at privacy@thepipelinegroup.io. European Union and Swiss individuals have the right to access their personal information.
TPG further has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the US Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information, and to file a complaint.
The Federal Trade Commission has enforcement authority regarding TPG’s compliance with the Privacy Shield Principles.
If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please send your request, by email, to privacy@thepipelinegroup.io.
Your browser or device may include ‘Do Not Track’ functionality. Our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Policy, whether or not a Do Not Track signal is received.
Our Site is not directed to or intended for individuals under the age of 16. We do not knowingly collect or use any personal information from users of our Site who are under the age of 16. No personal information should be submitted to our Site by individuals who are under 16 years of age. If we learn that we have collected information from someone who is under 16, we will take steps to delete the personal information as soon as possible. If you believe we may have collected personal information from someone under 16, please contact us at privacy@thepipelinegroup.io.
TPG reserves the right to modify this Policy from time to time, so please review it regularly. If we make material changes to this policy, we will notify you here, by email, and/or by means of a notice on our homepage prior to the changes becoming effective. Your continued use of the Site after any updates to this Privacy Policy constitutes your acceptance of the updated Privacy Policy.
If you have questions or concerns regarding this Privacy Policy, please contact us at:
TPG
Attn: Privacy
1625 The Alameda #402
San Jose, CA 95126
Email: privacy@thepipelinegroup.io.
This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS supplements the information contained in the TPG Privacy Policy. TPG has adopted this statement to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and other California privacy laws, and it applies solely to “consumers” as that term is defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this statement.
Information TPG Collects
TPG collects personal information. We have collected the categories of personal information indicated below within the last twelve (12) months:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing prior notice.
Categories of Sources from which Personal Information is Collected
TPG collects personal information from the following categories of sources:
Purposes for Collection of Personal Information
TPG collects and shares personal information for the following business and commercial purposes:
Third-Party Recipients
TPG may share personal information with the following third-party recipients:
Disclosure and Sale of Personal Information and the Right to Opt-Out
This section describes our personal information disclosure and sale practices and explains how a consumer can opt-out of the sale or disclosure of their personal information.
A consumer has the right to opt-out of the sale of that consumer’s personal information by emailing privacy@thepipelinegroup.io and submitting a request to remove the consumer’s profile or delete the consumer’s data. In order to submit a request, a consumer or an authorized agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.
In the preceding twelve (12) months, we have sold or disclosed for a business purpose the following categories of personal information to TPG customers, partners, affiliates, or service providers:
For avoidance of doubt, the personal information disclosed and/or sold by TPG within the identified categories is limited to business contact information related to a consumer’s profile as an employee of its employer. No sensitive personal information (i.e., Social Security number, passport number, medical or financial information) is collected, shared, disclosed, or sold by TPG.
We do not sell the personal information of minors under 16 years of age.
A Consumer’s Other CCPA Rights and Choices
The CCPA provides consumers with specific rights regarding their personal information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
A consumer has the right to request that we disclose certain information to that consumer about TPG’s collection and use of that consumer’s personal information over the past twelve (12) months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:
Deletion Request Rights
A consumer has the right to request that TPG delete any of his or her personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s personal information from our records, unless an exception applies.
We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:
(1) Complete the transaction for which we collected the personal information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer. (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 a consumer previously provided informed consent. (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s 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 a consumer provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Contacting us at privacy@thepipelinegroup.io
Only a consumer, or a natural person or business entity registered with the California Secretary of State that a consumer authorizes to act on a consumer’s behalf, may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child.
A consumer or the consumer’s authorized agent may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to a consumer’s or an authorized agent’s request or provide a consumer or authorized agent with personal information if we cannot verify the consumer’s or authorized agent’s identity and/or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided to us in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing 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 the consumer of the reason and extension period in writing. We will deliver our written response by mail or electronically. 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 choose a format to provide a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.
Non-Discrimination
Consumers have the right to not receive discriminatory treatment by a business for exercising their rights under the CCPA. We will not discriminate against a consumer for exercising any CCPA rights.
Changes to Our Privacy Statement
We reserve the right to amend this privacy statement at our discretion and at any time. When we make material changes to this privacy statement, we will provide notification by email or through a notice on our website homepage.
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