Privacy Policy (July 1, 2023)

Privacy Policy

Last Amended: July 1, 2023

This Privacy Policy (“Privacy Policy”), describe how Zesty Tech Ltd., or its affiliates and subsidiaries (“Company” or “Zesty”) collect, use and disclose certain information, including Personal Data (as defined below) and the rights you have with regards to your information.

Zesty is the developer and operator of a cloud management and optimization software-as-a-service platform (“Platform” and collectively with the services therein shall be referred to as the “Services”). This Privacy Policy is an integral part of our Terms and governs the processing and transfer of information, directly or indirectly when you sign up for or use the Platform (“Customer”), or merely when you browse our website available at: https://zesty.co/ (“Visitor” and “website” respectively).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms, unless otherwise stated herein, Visitors and Customer(s) shall be further, collectively and separately, referred to as “you“.

This Privacy Policy further explains how we safeguard your Personal Data and how you may exercise your rights related to your Personal Data, among others, and where applicable, as required according to the applicable data protection legislation.

(1) POLICY AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website and the update date will be reflected in the “Last Amended” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

(2) CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

Zesty, a company incorporated under the laws of the state of Israel, is the Controller (as such term is defined under the GDPR or equivalent privacy legislation).

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact as follows:

DPO Contact Information:

By Mail: privacy@zesty.co

Zesty Tech Ltd.

20 Lincoln, Tel Aviv-Jaffa, Israel 6713412

Representative for data subjects in the EU and UK:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/17277710417

(3) DATA PROCESSED BY ZESTY

We may collect two types of information from you, depending on your interaction with us.

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the website or Services (such as session duration).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:

Type of Data	Purposes of Processing	Legal Basis under the GDPR
VISITORS
Website Interaction and Marketing: When you interact with our website, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID, unique identifiers (“Online Identifiers”). Further, we will collect your behavior information, which is collected indirectly by our external marketing tools, or analytic tools. This information includes the referring URL (that is, the webpage directing you to our website, and other websites you visited in the session), your interests in our competitors, the web page you visited when you tapped/clicked on our ad, how you interact with our webpage, time, duration of use, pages you have viewed on our website (“Behavior Data”).	First, Online Identifiers and cookies are used, in particular to operate the website and enable its proper functionality, for example to automatically recognize you by the next time you enter the website or to confirm you are not are a real person. Second, the Online Identifiers and the Behavior Data are indirectly processed by marketing and analytic tools, for analytic and remarketing purposes. We process this data to understand how visitors use our website and to measure effectiveness of some ads we use in order to track conversions, build targeted audience, and remarket our Services to people who have taken some action on the website.	Strictly necessary cookies which are required for the proper and basic operation of the website will be processed in our legitimate interest. Other cookies, including any targeting and marketing cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management. You may withdraw consent at any time by using the cookie preference settings available by using the cookie preference setting tool available on our website, or by managing opt-out through your browser or device.
Contact Information: In the event you contact us with any inquiries, either through an online form available on the website (i.e., the contact us and support pages, the DSR form, etc.), or by sending us an email or by any other means, you will be requested to provide us certain information such as your name, telephone number, company name, email address (“Contact Information”).	We will use your Contact Information solely for the purpose of responding to your inquiries. The correspondence and its contents with you may be processed and stored by us in order to improve our customer services and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).	We process Contact Information subject to our legitimate interest.
Additional features: In the event you choose to provide feedback, post on our website or social media pages, participate in our webinars or events we host, you may be required to provide us with certain additional information.	We will use this information for the purpose of providing you with the services that you requested.	We process this information subject to our legitimate interest.
Career: When you apply for a job, promoted on our website, we will process your CV (and the information included therein), as well as additional information such as your contact information (name, email address and phone number), information regarding your education and skills, employment history, and your photo (to the extent provided by you). Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data (collectively, “Recruitment Information”).	We will use your Recruitment Information to process your job application and for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements. Following the completion of the recruitment process, we may further retain and store the Recruitment Information (including other interactions with us under such process) as part of our internal record keeping, including for legal defense from any future claim, as well as, where we find applicable and subject to applicable law requirements, to contact you in the future for other position we believe you qualify for. If you are hired, your Recruitment Information will be kept on our HR systems as part of your employment and our corporate management. We use Hi Bob which processes your Recruitment Information on our behalf subject to this data processing agreement.	We process Recruitment Information subject to our legitimate interest. In some cases, for example, where we will ask you to provide health related information or diversity and inclusion data, we will process such data based upon your consent. You may always withdraw consent at any time. We will retain your data for records keeping and future defense from legal claims under our legitimate interest, or if you have provided consent to contact you in the future. We use third party service provider for the purpose of managing job applications, currently we are using Comeet which processes your Recruitment Information on our behalf subject to this data processing agreement.
CUSTOMERS
Customer Account: In order to use our Services, you will be required to register and open an account or we will designate you with an account based on the information you provided us. During the registration process you will be requested to provide us with certain information such as your name, company name, email address, and other similar contact information, and you will be able to create a user name and password.	We use this information to create your account, authentication, provide account management (including billing and invoices), support and to provide the Services. In addition, we use this information for direct marketing purposes, meaning, as a Customer we may send you marketing related communications (by email or other contact details you have provided), materials and content regarding the Services you are currently using or any services we may offer in the future to keep you up to date, and for example, offers and content such as software updates, new capabilities and features, surveys, etc.	We process this information for the purpose of performing our contract with you. Processing of this information for direct marketing purposes is made subject to our legitimate interest. You can opt-out at any time using the “unsubscribe” option within the body of the message. Please note that if you choose to unsubscribe from our direct marketing, we will still retain your contact details and send you service-related emails, such as invoices.
Customer Support: When you contact us for customer support, we will process your Contact Information.	We will use the Contact Information to provide the customer support needed. We will retain such correspondence for as long as needed, and to evidence the support was provided.	We process such information to provide the support services and fulfill the contractual obligations.
Booking a Demo: In the event you choose to book a free demo you will be requested provide us with your name and company email address.	We will use this information for the purpose of providing you with the information or Services that you have requested.	We process this information for the purpose of performing our contract with you.
Payment Details: We use NetSuite as our payment processor pursuant to NetSuite Privacy Policy (“Payment Information”).	To process your payment and provide you with the service you purchased.	Processing is necessary for the performance of a contract with you.
Usage Data: When you use the Platform, information regarding such use is automatically generated and collected, which may include the click stream within the Platform, the use of the Services (i.e., accessed or used by Customer) and the time spent on those pages or features, crash data and analytics, etc. We record how you interact with our Service. We log crashes, interaction with the Services, how often you use the Service, how long you are on the Service, your purchases, etc.	We use this information to help us to understand how you are using our Services, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers, decide how to improve the Service based on the results obtained from this processing.	We process this information subject to our legitimate interest.
Survey and Feedback: We may ask you to provide feedback on our Services, including any alpha/beta services or free demo services. If you choose to address our request for such feedback or participate in our survey, we will collect your feedback and contact information such as your name, email address, etc.	We use this information to improve, revise and enhance our Service, as well as optimize and customize the Services.	We process such information subject to your consent. You may withdraw your consent at any time by contacting us the contact information provided herein.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in Section 10 “DATA TRANSFER” below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above.

(4) HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the website and Services, we may collect information as follows:

Automatically – we may use cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our website.

Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Services, contact us communications, registration, etc.

Provided by Third Parties. – our third parties service providers which collect personal data on our behalf, such as content enrichment service providers.

(5) COOKIES & TRACKING TECHNOLOGIES

We use “cookies” (or similar tracking technologies) when you access the website or interact with the Services we offer. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes. You can find more information about our use of cookies, as well as change your settings and preferences, as detailed under our cookie declaration available by using the cookie preference setting tool available on our website.

(6) SHARING PERSONAL DATA

We share your Personal Data with third parties, including our partners or service providers that help us provide our Services. You can find in the table below information about the categories of such third-party recipients.

Category of Recipient	Data That Will Be Shared	Purpose of Sharing
Service providers	All types of Personal Data	We employ other companies and individuals to perform functions on our behalf. Examples include: sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), identifying errors and crashes, conducting customer relationship management, and providing training. These third-party service providers have access to Personal Data needed to perform their functions, but they are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Zesty Tech Inc.	Contact Information, prospects information, leads, and customer success.	We may share certain information with our affiliated company, Zesty Tech Inc., for sales and marketing purposes.
Any acquirer of our business	All types of Personal Data	We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Enforcement of our rights and security detections.	All types of data	We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.
Legal and law enforcement	Subject to law enforcement authority request.	We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or security of Zesty, our Customers or others.

(7) YOUR RIGHTS RELATED TO YOUR PERSONAL DATA

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

For detailed information on your rights and how to exercise your rights, please see the Data Subject Request Form (“DSR”) form available here and send it to our privacy team at: privacy@zesty.co

Certain rights can be easily executed independently by you without the need to fill out the DSR Form:

You can you can opt-out from receiving our emails by clicking “unsubscribe” link; and
You can withdraw consent for processing Online Identifiers and Behavior Data, for analytics or marketing purposes, at any time be using the cookie settings available by using the cookie preference setting tool available on our website.

(8) DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

(9) SECURITY

At Zesty, security is our highest priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry standards which you can review here.

Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.

Please contact us at: privacy@zesty.co, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

(10) DATA TRANSFER

We may store or process your Personal Data in the EU, the United States or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our Services. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the EEA is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. Personal Data transferred outside the EEA is transferred, in all cases pursuant to standard contractual clauses approved by the European Union (“SCCs“). Additionally, following the withdrawal of the United Kingdom (UK) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK will also be subject to the SCCs or other contractual clauses that will ensure the security of the Personal Data (pending an adequacy decision from the European Commission).

(11) CHILDREN

Our website and Services are not intended for use by children and we do not knowingly collect or maintain information about anyone under the age of 16. Please contact us at: privacy@zesty.co, if you have reason to believe that a child has shared any information with us.

JURISDICTION-SPECIFIC NOTICES

A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies to California residents only pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.

Please see the CCPA Privacy Notice here which discloses the categories of Personal Information collected, purpose of processing, source, categories of recipients with whom the Personal Information is shared with for a business purpose, whether the Personal Information is sold or shared, the retention period, and how to exercise your rights as a California resident.

B. ADDITIONAL NOTICE TO COLORADO RESIDENTS

GENERAL:

Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting as an individual or in the household context only (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your Personal Data are described below.

“Personal Data” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

Sensitive Data include (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data.

Section 3 to this Privacy Policy, describes our collection and processing operations of Personal Data, the categories of Personal Data that are collected or processed, and the purposes. Additionally, Section 6 details the categories of third-parties that shares the Personal Data with for business purposes.

YOUR RIGHTS UNDER CPA:

The table below details how Colorado consumers can exercise their rights, and appeal our decisions regarding their exercise requests.

Right to Access/ Right to Know	You have the right to confirm whether Zesty is processing your Personal Data and to access such Personal Data.	If you wish to know if Zesty holds any of your Personal Data, please review this Privacy Policy. If you believe Zesty does hold any of your Personal Data and you wish to receive such Personal Data, please fill in our DSR available here. You are not required to create an account with us to submit a request to access your Personal Data.
Right to Correction	You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.	You can exercise this right directly through your account or by filling in our DSR available here.
Right to Deletion	You have the right to delete the Personal Data we hold about you. However please note this right is not absolute, and in certain circumstances we may deny such request, in full or in part, if retaining the Personal Data is necessary for us or our service provider(s) for any of the following reasons: 1) Complete the transaction for which we collected the Personal Data; provide a 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) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 4) Comply with the law or legal obligation. 5) 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. 6) Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us. 7) Make other internal and lawful uses of that Personal Data that are compatible with the context in which you provided it. We will delete or de-identify Personal Data not subject to one of these exceptions from our records and will direct our processors to take similar action.	If you would like to delete your Personal Data, please fill in our DSR available here. You are not required to create an account with us to submit a request to delete your Personal Data.
Right to Portability	You have the right to obtain the Personal Data we process about you, in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.	If you would like to receive the Personal Data, please fill in our DSR available here. We will select a format to provide your Personal Data that is readily usable and should allow you to transmit the Personal Data from one entity to another entity without hindrance.
Right to opt out from selling Personal Data	To the extent applicable to the Personal Data Zesty holds about you, you have the right to opt out of the sale of your Personal Data for the purposes of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer.	In the event Zesty uses your Personal Data for analytic purposes, you may have the right to opt-out from “selling” your Personal Data by clicking the “do not sell or share my personal information” in our website’s footer which will enable you to customize the use of cookies on our website.
Right to opt out from Targeted Advertising		Zesty may “share” Personal Dara with third parties for targeted advertising purposes. To opt out from the use of cookies on our website, please click the “do not sell or share my personal information” in the footer of the website which will enable you to customize the use of cookies on our website.
Right to opt out from Profiling		We do not profile you, thus we do not provide an opt-out mechanism in this regard.
Right to Appeal	If we decline to take action on your request, we will inform you without undue delay, however no longer than 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. If we deny the appeal, you may contact the Colorado Attorney General using this link: https://coag.gov/office-sections/consumer-protection/ or (720) 508-6000.	Not more than 60 days after receipt of an appeal we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decisions.
Duty not to violet the existing laws against discrimination or non-discrimination	Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices.	We do not discriminate our consumers.

HOW TO SUBMIT A REQUEST UNDER CPA?

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. If the DSR is submitted by someone other than the consumer about whom information is being requested, proof of authorization (such as power of attorney or probate documents) will be required.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@zesty.co and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

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.

C. ADDITIONAL NOTICE TO VIRGINIA RESIDENTS

Under the amended Virginia Consumer Data Protection Act (“VCDPA”), if you are a resident of Virginia acting solely in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information. Personal Data does not include de-identified data or publicly available data, and information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

The VCDPA requires Zesty to disclose the Categories of data processing and the purpose of each category, as detailed in Section 3 to this Privacy Policy, the categories of data shared and the third parties with whom it is shared, as detailed in Section 6. Disclosure of sale of data or targeted advertising are detailed in the DSR Form available here. Further, the table above under Section B. “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under VCDPA and how you may exercise your rights.

HOW TO SUBMIT A REQUEST UNDER VCDPA?

We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@zesty.co and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you or your request, we will not be able to grant your request.

D. ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include de-identified data or publicly available information. If further does not include information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

The categories of personal data processed, purpose of processing, are detailed in Section 3, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section 6. Disclosure of sale of data or targeted advertising are detailed in in the DSR Form available here. Further, the table above under Section B. “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.

HOW TO SUBMIT A REQUEST UNDER CDPA?

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests, provided we inform you of such extension within the initial 45 days response period, together with the reason for the extension.

If we decline to take action on your request, we shall so inform you without undue delay, however no longer than within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

Previous Versions: