Privacy Policy

LAST MODIFIED AND REVIEWED: December 16, 2023

INTRODUCTION

Esyoh, LLC (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This policy describes our privacy and data practices with respect to the information we collect or receive relating to users of RegisteredNursing.org (the “Website”).

Please read this policy carefully to understand our policies and practices regarding your information. 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 consent to this privacy policy.

If you have any questions about our Privacy Policy, see the "Contact Information" section below.

We may change this policy. 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.

For information on your choices and opt-out rights, see Choices And Opt Out Rights below.

For information about how to review, correct, or delete the personal information we maintain about you, and to exercise other rights as an individual, see Accessing and Rights regarding Personal Information below.

SCOPE OF THIS PRIVACY POLICY

This policy applies to information that we may collect or receive across the Internet and other digital formats:

• On this Website.
• In e-mail, text and other electronic messages between you and this Website.
• When you interact with our advertising on third-party websites and services.
• From third parties in connection with your use of the Website.

This policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties, including our business customers (except as required by applicable law). See "Third Parties" below for more information.

GEOGRAPHIC RESTRICTION

Our Website is intended for individuals located in the United States and Canada and our Website is operated in the United States. If you access or use the Website from outside of the United States or Canada, you are not authorized to access or use the Website. If you access or use the Website from outside the United States, then the information collected through the Website will be transferred to, stored, and processed in the United States or other countries in which our service providers and third-party partners operate. If we learn or determine that a user of our Website is located outside the United States and Canada, we reserve the right to delete such user's personal information from our systems.

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 our California Privacy Notice below.

California’s “Shine the Light” law permits users of our Website 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 see our Contact Information below.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Information You Provide Directly to Us

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

• Information that you provide by filling in forms on our Website, such as your name, postal address, email address, and phone number. This includes the information that you provide (i) when you request information about a specific school, (ii) when you participate in one of our online contests such as scholarships, or (iii) when you request further information. We may also ask you for information when you report a problem with our Website.
• Information that you provide when posting comments in public areas of our Website.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.

When you ask us to share your information with a specific school, we will share that information directly with the admissions department of that school. We cannot control the actions of the schools and are not responsible for the data practices of the schools.

When you provide comments to be posted in public areas of the Website, or transmitted to other users of the Website or third parties (“User Contributions”), you do so at your own risk. Please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users of the Website who view 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 Means

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

• Details of your visits to our Website, including traffic data, time spent on the Website, preferences you submit and preferences generated based on the data you submit and the number of clicks, aggregated information, communication data, the resources you access and use on the Website, and the page and URL that you visited before visiting on the Website.
• Information about your device, browser and Internet connection.

The technologies we use for automatic data collection 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 allow third parties to issue cookies when you direct your browser to our Website. Third parties such as Facebook, Inc., may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See Cookies and Other Tracking Technologies.

Information We Collect From Third Parties

We may receive from our clients your name and email address that you provided to our clients in response to a request for more information, such as when you request information about a school or educational program. Our clients provide us this information for billing and reporting purposes with respect to our clients and publisher partners. We retain this information as long as necessary to resolve payment and credit disputes with our clients and publisher partners. We may also receive reports containing non-personal information from third parties such as Google, Bing, and Facebook in connection with services that they provide for our Website, including Google Analytics and Facebook Pixel. See Cookies and Other Tracking Technologies.

USE OF YOUR INFORMATION

We may use your information:

• To respond to your inquiries and fulfill your requests.
• To send administrative information to you, for example, information regarding the Website and changes to our terms, conditions, and policies, and information regarding our scholarships.
• To administer our online contests and award scholarships to our winners (for example, we use your school transcript to verify eligibility to receive one of our school scholarships).
• To send you marketing communications from us that we believe may be of interest to you.
• For our business purposes, such as billing our clients, data analysis, audits, fraud monitoring, and prevention, developing new products, operating, enhancing, improving or modifying our Website, identifying usage trends, ensuring the Website functions properly, diagnosing server problems, and determining the effectiveness of our promotional campaigns.
• To personalize your experience while using the Website.
• To recognize you when you return to the Website.
• As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions, including our scholarship terms; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• In any other way, we may describe when you provide the information.
• For any other purpose with your consent.

We will not use data we collect for the purpose of determining employment eligibility, credit eligibility, healthcare eligibility, or insurance eligibility and underwriting and pricing.

In some instances, we may combine other information with certain personal information (such as combining your date of birth with your name). If we combine any other information with personal information, the combined information will be treated by us as personal information as long as it is combined.

DISCLOSURE OF YOUR INFORMATION

We may disclose your information:

• To our subsidiaries and corporate affiliates. Esyoh, LLC is the party responsible for the management of the personal information used by it and its corporate affiliates.
• To contractors, service providers and other third parties we use to support our business.
• To schools when you ask us to share your information with a specific school.
• 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 Esyoh LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Esyoh, LLC about our Website users is among the assets transferred.
• Directly by you, on public pages to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information, and may be available to users of the Website and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, on the Website.
• As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions, including our scholarship terms; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• To other parties for any other purpose disclosed by us when you provide the information.
• To other parties with your consent.

RETENTION OF INFORMATION

We will retain your information for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies and Similar Technologies

We and our service providers use cookies in connection with our Website. A cookie is a small data file that is stored on your computer's or mobile device’s memory. We may use cookies on our Website to recognize you when you return to our Website and to remove advertisements from our Website when we deem it appropriate. Our service providers may also use “pixel tags,” “web beacons”, “clear GIFs” or similar means (individually or collectively “Pixel Tags“. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1-pixel x 1-pixel) that is placed on a web page or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users' devices. Pixel Tags show the number of users who have visited our Website and pages within our Website and help determine the effectiveness of marketing campaigns.

Third parties may use cookies or similar technologies on visitors of our Website to serve interest-based advertisements to such visitors when they visit other websites and mobile applications. The collection of information through cookies or similar technologies by such third parties will be governed by such third parties' own privacy policies and principles, which Esyoh, LLC does not control.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org. To read about your choices with regard to cookies, please see "Choices And Opt Out Rights".

We do not respond to browser Do Not Track (DNT) signals at this time.

Google Analytics and Bing Webmaster Tools

We use Google Analytics, a Google Inc. web analysis service, and Bing Webmaster Tools, a search engine optimization and web analytics tool of Microsoft Corporation. Google and Microsoft use cookies, text files that are saved on users’ computers and allow the use of the online service to be analyzed.

Google and Microsoft may use this information on our behalf in order to assess users’ use of the Website, in order to compile reports on the activities within this online service and in order to render additional services for us associated with the use of the Website and Internet use. Google and Microsoft may use the data in order to create user profiles.

We do not control and we are not responsible for these tools or any of Google’s or Microsoft's tracking technologies or how they may be used. If you have any questions about the privacy and data practices of Google or Microsoft, you should contact Google or Microsoft directly.

Social Plugins

Our Website uses social plugins (“plugins”) provided by social networks, including Facebook, Twitter, LinkedIn, and Pinterest. These plugins are identifiable by their logos on our Website.

When you interact with a social plugin via our Website or you access our Website while logged into a social network, your device establishes a direct connection to the applicable social network's servers. This enables the plugin to receive information about your access to the respective pages of our Website. We have no influence on the data gathered by the plugin.

We do not control and we are not responsible for the plugins on our Website. If you have any questions about the privacy and data practices of any plugin, you should contact the plugin directly.

Facebook Pixel

Within our Website, we use the “Facebook Pixel” of the social network Facebook, which is operated by Facebook Inc. The Facebook Pixel allows us and Facebook to determine the relevant target audiences to display advertisements (referred to as “Facebook-Ads”) in reference to the potential interests of the users. We use the Facebook Pixel to display Facebook-Ads to users who displayed an interest in our Website. The Facebook Pixel allows us and Facebook to determine, whether our Ads were effective and satisfactory for users by being able to comprehend users’ actions before and after they were on our Website.

The Facebook Pixel enables Facebook to receive information and store a cookie on your device. The cookie allows Facebook to store the relevant information within your device and retrieve it for targeted advertising. Facebook may connect the data with your user profile within its network.

We do not control and we are not responsible for the Facebook Pixel or any of Facebook's tracking technologies or how they may be used. If you have any questions about the privacy and data practices of Facebook, you should contact Facebook directly.

Amazon

As an Amazon Associate Esyoh, LLC may earn from qualifying purchases.

Other Content or Applications

Some other content or applications, including advertisements, on the Website, are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies 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. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control and we are not responsible for 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 the privacy and data practices of these providers, you should contact such providers directly.

THIRD PARTIES

This policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties (unless required by law), including schools who receive your information from us at your request, our vendors, or any other third party operating any site or service to which the Website links. The inclusion of a link on the Website does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations (unless required by law), such as Facebook, Apple, Google, Microsoft, RIM, Pinterest or any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the Website.

You should always read the privacy policy of any website you access or social network page through which you share information carefully in order to understand their specific privacy and information usage practices.

CHOICES AND OPT-OUT RIGHTS

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

• Cookie Opt-Out – You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable, delete or refuse cookies, please note that some parts of this Website may not function properly. When you disable or delete cookies you are also deleting any opt-out cookies you have set on that browser or device. You will need to re-set opt outs after you have disabled or deleted your cookies on that browser or device.
• Opting Out of Targeted Advertising by Third Parties – If you do not want Facebook to deliver to you interest-based targeted advertisements, you can go to Facebook.com to view your options. You can find and manage many online ad cookies from companies by visiting the website optout.aboutads.info. Other third parties (such as Google) also use cookies when you visit our Website. These third parties may have opt-out mechanisms directly through their website or through an industry-developed web page. If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes. When you opt-out of receiving interest-based advertising from third parties, note that the opt-out only applies to the applicable browser in which you set it. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
• Opting out of Promotional Emails from the Company – If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services via email, you can opt-out by sending us an e-mail stating your request via our Contact Us page. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.

California Residents: If you reside in California, see the California Privacy Notice for additional opt-out rights.

ACCESSING AND RIGHTS REGARDING YOUR PERSONAL INFORMATION

You may send us an e-mail via our Contact Us page to request access to, correct or delete any personal information that you have provided to us. If we believe the change would violate any law or legal requirement or cause the information to be incorrect, we may not accommodate a request to change information.

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.

See "Choices" above for additional information about your choices with respect to the processing of your personal information.

California Residents: If you reside in California, see the California Privacy Notice below for additional rights regarding your information.

SENSITIVE INFORMATION

We ask that you not send us, and you do not disclose, any sensitive personal information (e.g., social security numbers or other government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal convictions and offenses, trade union membership, or any genetic data, biometric data, or information relating to an individual's sex life or sexual orientation) on or through the Website or otherwise to us, except where such information is legally required.

SECURITY

Information that we collect is stored using procedures and practices reasonably designed to help protect from an accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem. See Contact Information.

CHILDREN

Our Website is not intended for or directed to, children. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website, do not use any of the interactive or public comment features of this Website and do not provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child, please contact us see Contact Information. By using the Website, you are representing to us that you are not under the age of 18.

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. The most recent version of the Privacy Policy is indicated by the date at the beginning of this privacy policy. Please review this privacy policy frequently to stay updated on changes that may affect you. Your continued use of the Website signifies your continuing consent to the data practices set forth in this privacy policy. Where required by law, we will obtain your consent to make changes.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy and data practices, please contact us via our Contact Us page or the following mailing address:

Esyoh, LLC
Attn: Privacy Policy
30 M. Gould Street, Suite 25007
Sheridan, WY 82801

CALIFORNIA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective as of January 1, 2020

This California privacy notice is in response to the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning in this California privacy notice.

This California Privacy Notice ("California Notice") is for individuals who are California residents and provides additional information and adds to our privacy policy above. Note that certain California residents (e.g., employees, job applicants, contractors, owners, directors, officers, and medical staff of the Company) do not have all of the rights under this California Notice with respect to their personal information. See additional information about excluded personal information under "Information We Collect about California Residents." In addition, the CCPA exempts certain personal information reflecting a written or verbal business-to-business communication or transaction ("B2B personal information") from some of its requirements. We will note that below.

Information We Collect About California Residents

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household (“personal information“).

We have collected the following categories of personal information from our consumers within the last twelve (12) months:

The Company obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from web forms you complete on our Website (such as when you provide your information to request information about a school).
• Indirectly from you. For example, from observing your actions on our Website.
• From schools that are our business customers.
• From third parties such as Facebook in connection with the Facebook Pixel and Microsoft in connection with the Bing Webmasters Tool.
• From the use of cookies and similar tracking technologies.
• From your interactions with our advertisements.
• From your location.

Personal information does not include:

• The following information:
  • 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) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
• Publicly available information from government records.
• De-identified or aggregated information.

Additional excluded personal information: Pursuant to the CCPA, certain personal information is excluded from our definition of personal information from January 1, 2020, through December 31, 2020. Excluded personal information is information we collect about an individual resident of California in the course of the individual acting as a job applicant, an employee, a controlling owner, a board director, an officer, a contractor, or a medical staff member of the Company, including emergency contact information of the individuals above and information necessary to administer benefits. This information will not be covered by this California Notice. Such individuals should contact Esyoh, LLC for a copy of Esyoh's privacy notice for personnel.

Use of Personal Information of California Residents

We may use personal information for one or more of the following purposes:

• To respond to your inquiries and fulfill your requests.
• To send administrative information to you.
• To administer our online contests and award scholarships to our winners.
• To send you marketing communications.
• For our business purposes, such as billing our clients, data analysis, audits, fraud monitoring, and prevention, developing new products, operating, enhancing, improving or modifying our Website, identifying usage trends, ensuring the Website functions properly, diagnosing server problems, and determining the effectiveness of our promotional campaigns.
• To personalize your experience while using the Website.
• To recognize you when you return to the Website.
• As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions, including our scholarship terms; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• 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 as otherwise set forth in the CCPA.

The Company will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information of California Residents

Disclosures of Personal Information of California Residents for a Business Purpose

The Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, Company has disclosed the following categories of personal information of California residents for a business purpose:

We share your personal information for a business purpose with the following categories of third parties:

• Our subsidiaries and corporate affiliates.
• Schools who are our business customers and schools who are not our business customers.
• Service providers.
• A buyer of our business, or similar transaction.
• The public if you post something in a publicly accessible section of our Website.
• As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions, including our scholarship terms; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• To other parties as disclosed to you at the time of collection.
• To other parties with your consent.

Sales of Personal Information

In the preceding twelve (12) months, the Company has not sold personal information. "Sold" is defined under the CCPA.

Rights and Choices of California Residents

The CCPA provides certain California residents with rights about their personal information. This section describes your CCPA rights and explains how to exercise those rights. Please note that certain California residents will not have these rights to the extent their personal information is "excluded personal information" as described above. The CCPA does not provide these rights to B2B personal information.

California Residents' Access to Specific Information and Data Portability Rights

You have the right to request that the Company disclose certain information to you about our collection of your personal information over the past 12 months. First, we must verify the identity of the consumer making the request. After verification, we will disclose to you (based on your request):

• 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 that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (which allows you to port or copy your data).
• Two separate lists disclosing:
  • that we did not sell your personal information; and
  • the personal information categories that each category of recipient obtained.

Deletion Request Rights of California Residents

California residents have the right to request that we delete any of their personal information that we collected and retained, subject to certain exceptions. First, we will verify your identity. After we verify your identity, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You must contact the applicable schools directly to delete your information that they have in their systems.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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.
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.

We may also limit our deletion to the extent permitted by applicable law.

How California Residents can Exercise 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:

• Filling out our web form on the Contact Us page and selecting "deletion request" or "access and portability request" in the drop-down menu (https://www.registerednursing.org/contact-us/).
• Sending an email to privacy at esyoh dot com (at means @ and dot means .),
• Sending us a request at our physical address:

ESYOH, LLC
Attention: Privacy
30 N. Gould Street, Suite 25007
Sheridan, WY 82801

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative.
• 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.

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.

Timing of our Respond and the Format

We will try to respond to a verifiable consumer request within forty-five (45) days of our receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our response to you either via email or mail.

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 useable and should allow you to copy and 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 against California Residents

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 to the Company 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. Currently, we do not provide any financial incentives to our users.