FOR CALIFORNIA RESIDENTS
Last Modified: 07/01/2024
California Shine the Light Law
Subject to certain limitations, California residents may ask us to provide them with (1) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. To make this request, California residents may contact us as specified in the How to Contact Us section of our Privacy Notice. For such requests, indicate 鈥淐A Shine the Light Request鈥� in the subject field of your request.
NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (鈥淐CPA鈥�) and California Privacy Rights Act of 2020 (“CPRA”) provide certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (鈥淐alifornia Consumer鈥�) and use our Site. This notice supplements the information in our Privacy Notice above. Certain terms used below have the meanings given to them in the CCPA and CPRA. The CCPA and CPRA shall be collectively referred to herein as the “CPRA”
The following sets forth the categories of information we collect and purposes for which we may use California Consumers鈥� personal information by the Site:
Categories of Personal Information We Collect About You, Why and How
Categories of Personal Information Collected:
- Identifiers, such as your contact information (name, email address, postal address, phone number), government identifiers (social security number) or unique personal identifiers (wireless device ID, cookies, IP address) (“Identifiers“);
- Internet or other network or device activity (such as browsing history, browser type and language, operating system or usage) (“Internet Data“);
- Geo-location information (such as city, state and zip code associated with a unique identifier (“Geo-location Data“).
More details on the categories of personal information we may collect are set forth in the Information We Collect and Obtain section of our Privacy Notice.
Business or Commercial Purposes for which We Collected or Disclosed Personal Information:
- performing services, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services (“Performing Services“);
- auditing related to a current interaction with you and concurrent transactions (“Auditing“);
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (鈥�Data Security & Fraud Prevention鈥�);
- debugging to identify and repair errors that impair existing intended functionality (“Repairs“); and
- to advance the commercial or economic interests of the Company, such as by inducing another to subscribe to or provide information or services, or enabling or effecting, directly or indirectly, a commercial transaction (鈥�Commercial Interests鈥�).
More details concerning the business or commercial purposes are set forth in the How We Use the Information We Obtain section of our Privacy Notice.
Categories of Sources from which We Collected Personal Information:
- Directly from you (“You“)
- From other sources (such as analytics providers)(“Service Providers“)
- Through your use of the Site (“Site Use“)
Summarized in the table below are the categories of personal information we may collect about you over the past twelve (12) months, the purposes and sources of collection and retention period of each category of information.
| Categories of information collected | Purposes of Collection | Sources of personal information | Retention Period |
|---|---|---|---|
| Identifiers | – Performing Services – Auditing – Commercial Interests | – You – Site Use | – Social Security Numbers or other tax identification numbers of investors who enroll in electronic delivery through the Site are maintained with the Company鈥檚 Service Provider for as long as the investor holds stock in the Company and remains enrolled in the electronic delivery program. – Identifiers such as email addresses of investors are deleted by the Company鈥檚 Service Provider 120 days after the email addresses remain inactive – Contact forms of investors are maintained by the Company鈥檚 Service Provider for one (1) year after submission |
| Internet Data | – Performing Services – Auditing – Data Security & Fraud Prevention – Repairs | – Service Providers – Site Use | – 26 months |
| Geo-location Data | – Performing Services – Auditing – Data Security & Fraud Prevention Repairs | – Service Providers – Site Use | – 26 months |
More details on the categories of personal information, the purposes for which we collected such information and the sources from which we obtain your personal information are outlined below, and otherwise set forth in the Information we Collect and Obtain and How We Use the Information We Obtain Sections of our Privacy Notice.
HOW WE DISCLOSE YOUR INFORMATION
We do not 鈥渟ell鈥� your personal information to third parties. We will disclose, however, any or all of the personal information collected from and about you over the past twelve (12) months as discussed above with our data analytics providers for various business purposes.
More details on the categories of personal information we may disclose for a business purpose are set forth in the Information We Collect and Obtain and Information We Share sections of our Privacy Notice.
California Consumer Privacy Rights and Choices
In addition to rights of access, correction, deletion and data portability, as described in the Privacy Notice, California Consumers may have certain additional rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:
The right to access and disclosure and portability. You may have the right to request, twice during a twelve month period, the following information about the personal information we have collected about you for the time period from the date of your request to January 1, 2022:
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected or sold the personal information;
- the categories of third parties with whom we shared the personal information;
- the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose; and
- the specific pieces of personal information we obtained from you in a format that is easily understandable, and to the extent technically feasible, in a structured commonly used, machine-readable format.
The right to nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.