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TROPICAL SMOOTHIE CAFE

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PRIVACY POLICY

Tropical Smoothie Café, LLC (“TSC”, “we”, “us” or “our”) is committed to
protecting the privacy of customers and users of our Services (as defined
below). 

This Privacy Policy applies to information that identifies or relates to users
of our Services (“Personal Information”) that TSC collects when users interact
with us through our Services and in our corporate owned and operated restaurant
located at 1155 Mount Vernon Hwy Unit #1040, Atlanta, GA 30338. This includes
information collected through our website and mobile application (including our
Tropical Smoothie Cafe App), Tropical Smoothie Cafe branded social networking
services, direct marketing campaigns, and when you purchase our products,
subscribe to our news, and offers, enter one of our promotions or contact
customer support (collectively, our “Services”). 

By accessing or using any of our Services or providing us with your Personal
Information, you agree to our processing and handling of your Personal
Information in accordance with this Privacy Policy. If you are a resident of
California or Virginia, you may have additional rights as set forth in Section 9
below. 

With the exception of our one corporate owned and operated restaurant in
Atlanta, Georgia, Tropical Smoothie Cafe restaurants are independently owned and
operated by franchisees. We ask our franchisees to abide by our privacy
practices, but each franchisee is independently responsible for its legal
compliance, regulatory compliance, and related data practices for any data that
they may collect.

 1. Types of Information We Collect and How It Is Used 

TSC gathers Personal Information, such as first and last name, address, email
address, zip code, mobile number, favorite Tropical Smoothie Cafe location, and
birthdate, when voluntarily submitted by you while using our Services.  We also
track the transactions you make, including where and when you make them, in
connection with our Tropic Rewards® loyalty program (“Tropic Rewards”).

For example, Personal Information may be collected from you to:

 * Provide, develop, and improve the Services;
 * Receive your feedback on our Services and our products;
 * Send you marketing communications based on your interests and preferences;
 * Follow up with you on certain promotions and limited time offerings;
 * Enter you in one of our contests or sweepstakes;
 * Inform you about our brand or events;
 * Maintain records for administrative purposes;
 * Protect customer security;
 * Detect and prevent fraud; and
 * Comply with any law, legal process, or law enforcement request.

We also offer various Services that are provided through third parties. For
example, our online ordering is provided by Olo, which has a privacy policy that
you can view when placing an order online via order.tropicalsmoothiecafe.com.
Olo will provide us and/or our franchisees information relating to your order so
that it can be prepared for delivery or pickup – this includes the items ordered
and the location and time of pickup. We are not responsible for the information
practices of Olo.

If you apply for a position at the Tropical Smoothie Cafe support center, our
one corporate owned and operated restaurant or one of our franchisee owned and
operated restaurants, we collect the name, address, phone number, email address,
employment information, and educational information you submit. We or our
franchisees, as applicable, use this information for processing job applications
and hiring purposes.  Please note that we only hire and employ applicants for
the Tropical Smoothie Cafe support center and our one corporate owned and
operated restaurant located at 1155 Mt. Vernon Highway, Unit #1040, Atlanta,
Georgia 30338.  If you are applying for a position at a franchised restaurant,
your information will be sent directly to the franchise owner who is responsible
for their own hiring and employment-related policies and decisions.

If a customer signs up to receive Tropical Smoothie Cafe emails or creates a
Tropic Rewards account, the customer is opting in to receive email
communications from Tropical Smoothie Cafe. The customer may opt out of
receiving email communications from Tropical Smoothie Cafe by clicking on the
unsubscribe link at the bottom of one of our email communications or clicking
here.

We also collect certain information automatically through the use of cookies and
other tracking technologies.

2. Disclosure of Personal Information

TSC may disclose Personal Information with affiliated companies that we own or
control, as well as our independent franchisees, in connection with providing
you Services. We ask any affiliated companies and independent franchisees to
comply with our Privacy Policy, but such affiliated companies and independent
franchisees are responsible for their compliance with applicable laws and
regulations. 

We may also disclose Personal Information with service providers engaged by us
to perform a variety of functions, such as fulfilling orders, assisting with
promotions, conducting background checks, and providing technical support for
our Services ("service providers”). These service providers may have access to
Personal Information if needed to perform such functions. However, these service
providers may only use such Personal Information to perform that function and
may not use it for any other purpose.

We may also disclose the Personal Information we collect to our analytics
vendors and partners to develop aggregate analysis and business intelligence for
our advertising and marketing purposes. For example, we use Personal Information
to create custom audiences and measure the success of promotions.

We also disclose Personal Information to social media platforms and third-party
advertising platforms for purposes of targeted advertising of promotions,
products, and services we think may be of interest to you. In certain states,
you can request that we stop such targeted advertising as noted in Section 9
below. 

TSC reserves the right to use or disclose any Personal Information as needed to
satisfy any law, regulation, legal request, or legal process, to exercise or
defend legal claims, to protect the integrity of our Services, to prevent fraud,
to protect the security of our systems and facilities, to fulfill your requests,
or to cooperate in any law enforcement investigation or an investigation on a
matter of public safety.

We may disclose your Personal Information to a third-party that acquires TSC or
our assets as part of a sale, merger, reorganization or bankruptcy, or other
proceeding.

3. Children’s Privacy Notice

Our services are not intended for use by children younger than age 16. If we
learn that we have inadvertently collected the Personal Information of a child
younger than age 16, we will take steps to delete the information as soon as
possible.

If you are a parent or legal guardian and believe we may have collected
information about your child, please:

 * Submit a request through our Privacy Web Form
 * Call us toll-free at: (855) 966-2563

You will be asked to provide proof that you are the child’s parent or legal
guardian to receive any information regarding the child.

4. Data Requests

If at any time you would like to access, correct, or delete the Personal
Information we have about you, or if you would like to change your preferences
for contacts from us or on behalf of our business partners, please use the
Privacy Web Form or toll-free number listed below. We will respond to these
requests to the extent required by law, or if not required by law, in our sole
discretion.

5. Cookies

a. Generally

“Cookies” are pieces of information that a website transfers to an individual’s
hard drive for record-keeping purposes. Cookies allow the website to remember
information that will make the individual’s use of the site more convenient.
Like many websites, TSC uses cookies for a variety of purposes to improve your
online experience. For example, we track the total number of visitors to our
site on an anonymous aggregate basis. We also may employ cookies so that we
remember you when you return to the site, to keep track of the items in your
shopping cart if you purchase merchandise online, to administer certain contests
and sweepstakes and to help customize your Tropical Smoothie Cafe web
experience. We may associate Personal Information with a cookie file in those
instances.

b. Google Cookies

We use the following types of cookies:

Essential Cookies: Essential cookies are cookies are necessary for system
administration, to prevent fraudulent activity, to improve security or to enable
basic features of the Site and services online. 

Functionality Cookies: Functionality cookies are cookies that enable us or
third-party partners to provide certain functions of the website to you. Please
note that if you disable these cookies, we may not be able to provide all
functions of our Services to you.

Analytics and Performance Cookies: Analytics and performance cookies are cookies
that are used to assess the performance of the Services, including as part of
our analytics practices to improve our content and Services.

Targeting Cookies: Targeting cookies are cookies used by us or by third-party
advertising networks and content providers to deliver content, including ads,
relevant to your interests on the Services, and third-party sites across your
devices based on how you interact with our advertisements or content. Where
required by law, we will allow users to opt-out of such cookies.

Social Media Cookies: Social media cookies are cookies set by social media
services that we have added to the website to enable you to share our content
with your friends and networks. They are capable of tracking your browser across
other sites and building up a profile of your interests.

c. Usage Cookies and Similar Technology

We may use certain third-party cookies and similar usage technology on our
Services, including our mobile application, which record and track usage of our
Services. These cookies and technology record and track, among things, what
pages you access, pages viewed, how much time you spent on a page, and how you
reached our website. We also log the details of your visits to our Services and
information generated in the course of using our Services, such as mouse
movements, clicks, page visits, text entered, how long you spent on a page, and
other details of your actions on our Services. By using our Services, you
consent to the use of such cookies and technology, and tracking and recording of
such information.

d. Google Cookies

Our website utilizes Google remarketing. As a visitor to our website, you should
be aware that your data may be used in the following manner:

Where users have chosen to enable Google to associate their web and app browsing
history with their Google account, and to use information from their Google
account to personalize ads they see across the web, Google will use data from
its signed-in users together with our Google Analytics data to build and define
audience lists for cross-device remarketing.

To support this feature, Google Analytics will collect these users’
Google-authenticated identifiers, which are Google’s personal data, and
temporarily join them to your Google Analytics data in order to populate your
audiences.

e. Opting Out of All Cookies and Interest-Based Advertising

You have several ways to opt-out of cookies:

 * If you are a resident of California or Virginia, you can opt-out of cookies
   that are used for cross-context behavioral advertising or targeting
   advertising by following the procedures in Section 9 below.
 * You can use the options in your web browser if you do not wish to receive a
   cookie or if you wish to set your browser to notify you when you receive a
   cookie.  Click on the “Help” section of your browser to learn how to change
   your cookie preferences. If you disable all cookies, you may not be able to
   take advantage of all the features of our website.

Some third-party advertising companies may collect information about you through
cookies and other technologies in connection with their behavioral advertising
programs. Although we do not control the policies, programs or practices of
third-party advertising companies, the Network Advertising Initiative (NAI) and
Digital Advertising Alliance (DAA) maintain an opt-out tool that allows you to
opt out of participating in the behavioral advertising programs of NAI and DAA
member companies. To learn more about behavioral advertising and how to opt out,
visit the NAI website at www.networkadvertising.org/managing/opt_out.asp, or the
DAA website at www.aboutads.info/choices/.

6. Links to Other Sites

We may offer links to sites that are not operated by TSC. If you visit one of
these linked sites, you should review their privacy and other policies. We are
not responsible for the policies and practices of other companies, and any
information you submit to those companies is subject to their privacy policies.

7. Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time and in our sole
discretion.  This Privacy Policy is effective as of January 1, 2023. If we
change our Privacy Policy, we will post the revised version on our website and
indicate the date that the changes are effective. Your continued use of the
Services after the changed Privacy Policy is posted constitutes your acceptance
of the changes.

8. How to Contact Us

For privacy-related issues:

 * Submit a request through our Privacy Web Form
 * Call us toll-free at: (855) 966-2563

For customer service requests or other customer issues, please visit our Guest
Contact Center.

9. State Specific Notices

A. Additional Notice for California Consumers

Tropical Smoothie Cafe is mindful of our responsibilities under the California
Consumer Privacy Act (CCPA as amended by the California Privacy Rights Act
(collectively,
California Privacy Laws)). This portion of our Privacy Policy applies to
California Consumers within the meaning of the California Privacy Laws. 

a. Notice at Collection  

We collect information from users as described in our Privacy Policy. The
“Personal Information,” as defined in California Civil Code § 1798.140(o), we
collect includes:

 * Identifiers such as name, postal and email addresses, internet protocol (IP)
   address, unique personal identifier, online identifier and token identifier
   when you submit your information to create an account with us, join Tropic
   Rewards, interact with us on social media, or sign up to learn more about our
   products and services.
 * The following categories of protected classification characteristics under
   California or federal law: birthdate when you sign up to receive special
   offers as part of Tropic Rewards.
 * Commercial information such as records of products or services purchased, or
   obtained, or considered from us.
 * Internet or other similar network activity information, including, but not
   limited to, browsing history on our websites, search history, information on
   your interaction with our websites or applications.
 * Geolocation data such as physical location or movements.
 * Inferences drawn from other Personal Information, such as profiles reflecting
   consumer preferences.
 * Sensitive Personal Information in the form of precise geolocation but only if
   you turn on location services in your Tropical Smoothie Cafe App.

We collect this Personal Information so that we can provide you Services, get
your feedback, share promotions, enter you into contests, inform you about our
brand, send you marketing communications, personalize your interaction, and
maintain records. We do not sell this Personal Information to third parties but
may disclose it to affiliated companies that we own or control, as well our
independent franchisees. We may also disclose Personal Information with service
providers engaged by us to perform a variety of functions, such as fulfilling
orders, assisting with promotions, providing technical services for our
websites, etc.

We generally retain your Personal Information for as long as you have an account
or as long as required to comply with legal requirements or fulfill the purpose
of the collection.  

b. How We Collect, Use, and Share Personal Information

(i) Personal Information Collected on California Consumers in the Last Twelve
Months 

We collect information from users as described in our Privacy Policy. The
“Personal Information,” as defined in California Civil Code § 1798.140(o), we
have obtained on California residents within the last twelve months includes:

 * Identifiers such as name, postal and email addresses, IP address, unique
   personal identifier, online identifier and token identifier when you submit
   your information to create an account with us, join Tropic Rewards, interact
   with us on social media, or sign up to learn more about our products and
   services.
 * The following categories of protected classification characteristics under
   California or federal law: birthdate when you sign up to receive special
   offers as part of Tropic Rewards.
 * Commercial information such as records of products or services purchased, or
   obtained, or considered from us.
 * Internet or other similar network activity information, including, but not
   limited to, browsing history on our websites, search history, information on
   your interaction with our websites or applications.
 * Geolocation data such as physical location or movements.
 * Inferences drawn from other Personal Information, such as profiles reflecting
   consumer preferences.
 * Sensitive Personal Information in the form of precise geolocation if you have
   allowed such tracking.

Please note that Personal Information does not include publicly available
information from government records or made publicly available by you such as on
social media sites, de-identified or aggregate consumer information, and
Personal Information protected by certain other sector-specific federal or
California statutes.

(ii) Our Use of Personal Information for Business or Commercial Purposes in the
Last Twelve Months

For each of the above categories, we use the Personal Information we collect for
the commercial and business purposes disclosed in this Privacy Policy. These
commercial and business purposes include:  

 * Providing, developing and improving our Services;
 * Personalizing our Services to you;
 * Audits and reporting relating to particular transactions and interactions,
   including online interactions, you may have with us or others on our behalf;
 * Detecting and protecting against security incidents, and malicious,
   deceptive, fraudulent or illegal activity, and prosecuting the same;
 * Debugging to identify and repair errors in our systems;
 * Short-term, transient use including contextual customization of ads;
 * Providing services on our behalf or on behalf of another, including
   maintaining or servicing accounts, providing customer service, fulfilling
   transactions, verifying identity information, processing payments, and other
   services;
 * Conducting internal research to develop and demonstrate technology;
 * Conducting activity to verify, enhance, and maintain the quality or safety of
   services or devices which we may own, control, or provide;
 * Preparing statistics and performing analysis to support our operations;
 * Conducting marketing and surveys; and
 * Receiving and responding to inquiries.

We also may use the Personal Information we collect for our own or our service
providers’ other operational purposes, purposes for which we provide you
additional notice, or for purposes compatible with the context in which the
Personal Information was collected. 

(iii) Categories of Sources of Personal Information

We collect the Personal Information listed above directly from you, from our
franchisees, from our service providers, the providers of our online ordering
system and app, online delivery platforms, and data analytics providers.  

(iv) Sharing or Sale of Personal Information in the Past Twelve Months

Within the meaning of the California Privacy Laws, we have not sold Personal
Information identified in the above categories to any third-party within the
last twelve months and will not sell Personal Information to any third-party.   

We may share your Personal Information with third parties for cross-context
behavioral advertising, including with social media platforms, online delivery
platforms, marketing agencies and third-party advertising networks. 

Please note that we do not share, sell or disclose Personal Information of
individuals we know to be under the age of 16 to businesses or third parties
without consent.

(v) Disclosure of Personal Information in the Past Twelve Months to Third
Parties 

In the past twelve months, we have disclosed Personal Information to third
parties for the business as described in Section 2 of this Privacy Policy. The
categories of Personal Information disclosed to third parties includes
identifiers, characteristics of protected classifications, commercial
information, internet or other electronic network activity information,
geolocation data, and inferences drawn from this Personal Information. The
specific business or commercial purpose is to assist in providing Services and
performing a variety of functions, such as fulfilling orders, assisting with
promotions, providing technical services for our websites. 

c. California Rights and Choices

If you are a California resident (“California Consumer”), you have certain
rights related to your Personal Information. Except as otherwise provided by
applicable law, you may exercise the following rights free of charge with
respect to the Personal Information covered by this Privacy Policy. We endeavor
to respond to your request promptly upon verification and as required by
applicable law.  

(i) Right to Know / Portability

You have the right to request that we disclose to you the following Personal
Information we collected about you within the past twelve months:

 * Specific pieces of Personal Information we have collected about you;
 * Categories of Personal Information we have collected about you;
 * Categories of sources from which the Personal Information was collected;
 * Categories of third parties to whom we disclosed Personal Information; and
 * The business or commercial purpose for collecting, selling, or sharing
   Personal Information.

(ii) Right to Correction 

You have the right to correct inaccurate Personal Information that we maintain
about you, taking into account the nature of the Personal Information and the
purposes of the processing of the Personal Information. For Tropic Rewards
members, you can correct your information (with the exception of your birthdate)
by accessing your account.

(iii) Right to Deletion 

You have the right to request that we delete (and direct our service providers
to delete) Personal Information that we collected from you and retained, subject
to certain exceptions. We may deny your deletion request if retaining the
information is necessary for us or our service provider(s) to:

 * complete the transaction for which we collected the Personal Information,
   fulfill the terms of a written warranty or product recall conducted in
   accordance with federal law, provide a good or service that you requested, or
   take actions reasonably anticipated within the context of our ongoing
   business relationship with you, or otherwise perform our contract with you;
 * help to ensure security and integrity to the extent the use of your Personal
   Information is reasonably necessary and proportionate for those purposes;
 * debug products to identify and repair errors that impair existing intended
   functionality;
 * exercise free speech, ensure the right of another consumer to exercise their
   free speech rights, or exercise another right provided for by law;
 * comply with the California Electronic Communications Privacy Act;
 * 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;
 * enable solely internal uses that are reasonably aligned with consumer
   expectations based on your relationship with us and compatible with the
   context in which you provided the information; or
 * comply with a legal obligation.

(iv) Right to Opt Out of Sale/Sharing 

You have a right to opt-out of the sharing of your Personal Information for
cross-context behavioral advertising by completing and submitting our Privacy
Web Form or calling us toll-free. We will also honor opt-out preference signals
that comply with the California Privacy Laws. 

We do not offer a right to opt-out of the sale of your Personal Information
because, within the meaning of the CCPA, we have not sold Personal Information
identified in the above categories to any third party within the last twelve
months and will not sell such Personal Information to any third party. 

(v) Right to Limit Use and Disclosure of Sensitive Personal Information

We also do not offer a right to limit the use or disclosure of sensitive
Personal Information because, within the meaning of the CCPA, we do not use
sensitive Personal Information for inferring characteristics.

(vi) Right to Non-Discrimination for Exercise of a California Privacy Right

We will not discriminate against you because of your exercise of any of the
above rights, or any other rights under the CCPA. This means that we may not
deny you goods or services, charge you different prices or rates for services or
provide you with a different level or quality of services (or suggest that we
will do so), in response to a request made under the CCPA. 

We may, however, charge different prices or rates, or provide a different level
or quality of goods or services, if that difference is reasonably related to the
value provided to us by your Personal Information. 

(vii) How to Submit a Request

You may submit a request to exercise the rights listed above by:

 * Completing and submitting our Privacy Web Form
 * Calling us toll-free at: (855) 966-2563


(viii) Verifiable Request 

As required under applicable law, we take steps to verify your identity before
granting you access to information or acting on your request to exercise your
rights. We may require you to provide information sufficient to allow us to
reasonably verify you are the person about whom we collected Personal
Information or an authorized representative and to describe your request with
sufficient detail that allows us to properly understand, evaluate, and respond
to it. We may limit our response to your exercise of the above rights as
permitted under applicable law.  

(ix) Agent Authorization and Disability Access

You may designate an authorized agent to make a request on your behalf. You may
make such a designation by providing the agent with written permission to act on
your behalf. As permitted by law, we may require additional verification in
response to a request even if you choose to use an agent. We may refuse a
request if the agent does not provide adequate proof of their authorization. You
may also make a verifiable consumer request on behalf of your minor child.

To access this Privacy Policy in an alternative format, please see
our Accessibility Policy. 

d. Other California Privacy Rights

(i) California “Shine the Light” Law (Civil Code Section § 1798.83) 

Under the Shine the Light Law, a California resident may ask us to refrain from
sharing Personal Information with third parties for their direct marketing
purposes. We do not share Personal Information of California residents with
third parties for their marketing purposes. 

(ii) California Do Not Track Disclosure

Our website and apps are not designed to respond to “Do Not Track” requests from
browsers. 

e. Contact Information Regarding this California Notice 

You may contact us with questions or concerns about our privacy policies or
practices and your choices and rights under California law by: 

 * Submitting a request through our Privacy Web Form
 * Calling us toll-free at: (855) 966-2563

f. Notice of Financial Incentive

Members of Tropic Rewards may receive points for every dollar spent on
qualifying purchases and via participation in periodic additional points-earning
opportunities.  Points may be accumulated and redeemed for purchases of eligible
products. We collect Personal Information in connection with providing Tropic
Rewards to consumers.  This includes the following categories of Personal
Information:

 * Identifiers such as name, postal and email addresses, internet protocol (IP)
   address, unique personal identifier, online identifier and token identifier
   when you submit your information to create an account with us, join Tropic
   Rewards, interact with us on social media, or sign up to learn more about our
   products and services.
 * The following categories of protected classification characteristics under
   California or federal law: birthdate when you sign up to receive special
   offers as part of Tropic Rewards. 
 * Commercial information such as purchases you have made and use of loyalty
   program rewards.

You are given the choice to opt-in to Tropic Rewards when you register for an
account in the Tropical Smoothie Cafe App. You may withdraw from Tropic Rewards
at any time on the Tropical Smoothie Cafe App. We benefit financially from
Tropic Rewards through increased customer loyalty, but we do not assign an
independent monetary value to the Personal Information we collect in connection
with Tropic Rewards. We estimate in good faith that the value of the Personal
Information that we collect through Tropic Rewards would be less than the value
that Tropic Rewards provides to consumers. To the extent that we calculate the
value of the Personal Information we collect through Tropic Rewards, we do so in
good faith based on the expenses related to the collection and retention of
Personal Information in connection with Tropic Rewards.

B. Additional Notice for Virginia Consumers

TSC is mindful of our responsibilities under the Virginia Consumer Data
Protection Act (VCDPA). This portion of our Privacy Policy applies to Virginia
Consumers as that term is defined under the VCDPA.    

a. How We Collect, Use, and Share Personal Information

(i) Personal Information Collected 

We collect the following categories of Personal Information: identifiers,
protected classification characteristics (such as birthdate), commercial
information, Internet or other similar network activity information, geolocation
data, and inferences drawn from the above. 

(ii) Our Use of Personal Information for Business Purposes

The purposes for processing Personal Information are described in Section 1 of
our Privacy Policy. 

(iii) Sharing of Personal Information

We may share the following categories of Personal Information to third parties:
identifiers, protected classification characteristics (such as birthdate),
commercial information, Internet or other similar network activity information,
geolocation data, and inferences drawn from the above. We share each category
with our franchisees and service providers and other third parties, as described
in Section 2 of our Privacy Policy.  We also share Personal Information with
social media platforms, delivery platforms and third-party advertising networks
for purposes of targeted advertising.

b. Virginia Rights and Choices

If you are a Virginia resident, you have certain rights related to your Personal
Information. Except as otherwise provided by applicable law, you may exercise
the following rights free of charge with respect to the Personal Information
covered by this Privacy Policy. We endeavor to respond to your request promptly
upon verification and as required by applicable law.  

(i) Right to Know 

You have the right to confirm whether we are processing your Personal
Information and to access that Personal Information.

(ii) Right to Correction

You have the right to correct inaccuracies in Personal Information, taking into
account the nature of the Personal Information and the purposes of the
processing of the Personal Information. Tropic Rewards members can correct their
Personal Information (with the exception of your birthdate) by accessing their
account profile.

(iii) Right to Deletion 

You have the right to delete personal data provided and obtained about you.

(iv) Right to Portability 

You have the right to obtain a copy of your Personal Information that you
previously provided to us in a portable and, to the extent technically feasible,
a readily usable format. Tropic Rewards members can obtain a copy of their
Personal Information by accessing their account profile. 

(v) Right to Opt-Out 

You have the right to opt out of the processing of the Personal Information for
purposes of (i) targeted advertising, (ii) the sale of Personal Information, or
(iii) profiling in furtherance of decisions that produce legal or similarly
significant effects concerning the consumer. As noted above we do not sell your
Personal Information or engage in profiling and so do not offer an opt-out from
such activities. We do engage in some targeted advertising for which you can
exercise your opt-out rights as set forth in subsection (vi) below. 

(vi) How to Submit a Request 

You may submit a request to exercise the rights listed above by:

 * Completing and submitting our Privacy Web Form
 * Calling us toll-free at: (855) 966-2563

(vii) Verifiable Request 

As required under applicable law, we take steps to verify your identity before
granting you access to information or acting on your request to exercise your
rights. We may require you to provide information sufficient to allow us to
reasonably verify you are the person about whom we collected Personal
Information or an authorized representative and to describe your request with
sufficient detail that allows us to properly understand, evaluate, and respond
to it. We may limit our response to your exercise of the above rights as
permitted under applicable law.  

To appeal our decision regarding a request related to these rights, you may call
us toll-free at (855) 966-2563.

This Privacy Policy was last updated June 1, 2023.

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