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CALIFORNIA RESIDENTS ONLY
Effective Date: January 1, 2023
Last Revised/Reviewed on: January 1, 2023
This California Notice at Collection and Privacy Policy (“CCPA Disclosure”) explains how Starwood Property Trust, Inc. and its subsidiaries and affiliates (“we” “us”, “our”, or “Company”) (collectively, “Starwood”), collects, uses, discloses, and/or retains personal information (“Information Practices”) subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). This CCPA Disclosure applies solely to California residents (“consumers” or “you”).
The CCPA does not apply to certain information collected by our financial services subsidiaries or affiliates, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and certain other state or federal privacy laws. For example, this CCPA Disclosure does not apply to information that we collect about individuals who seek, apply for, or obtain financial products and services for personal, family, or household purposes.
This CCPA Disclosure does not apply to information we collect in the context of an individual’s interaction with us as a job applicant, employee, contractor, or other role within Starwood. Please refer to our CCPA Workforce Disclosure.
Notice at Collection
The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared.
General Personal Information
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Categories of
Personal Information
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Purposes for
Collection and Use
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Identifiers: For example, a real name, postal
address, unique personal identifier, Internet Protocol address, email
address, account name, social security number, or other similar identifiers.
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To fulfill or meet the reason for which the information is
provided
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To verify your identity
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To improve our products and services
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To protect against security risks
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For advertising and marketing
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To conduct research, analytics, or other internal analysis
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To conduct business with you or your employer in your role with
a third party that we do business with
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To operate, manage, and maintain our business
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To perform compliance activities or institutional risk control
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To carry out our legal and business purposes, such as complying
with federal, state, and local laws or responding to lawsuits or
investigations, or to exercise our legal rights
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At your direction or with your consent
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Personal Information Categories from Cal. Civ. Code §
1798.80(e): For example, a name, signature, Social Security
number, address, telephone number, driver’s license, education, employment,
employment history, or any other financial information.
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Characteristics of CA or Federal Protected
Classifications: For example, race, religion, national origin), age (40
and over), gender, sexual orientation, medical condition, ancestry, pregnancy
(includes childbirth, breastfeeding and/or related medical conditions),
familial status, disability, veteran status, or genetic information.
We do not intentionally collect this information,
but it may be revealed in identity data or other information we collect
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Commercial Information: For example, records of
personal property, products or services purchased, obtained, or considered,
or other purchasing or consuming histories or tendencies.
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Internet or Other Similar Network Activity: For
example, browsing history, search history, and information regarding a
consumer’s interaction with an Internet Web site or application.
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Geolocation Data: For example, information that can
be used to determine a device’s physical location.
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Professional or Employment-Related Information: For
example, compensation, evaluations, performance reviews, personnel files, and
current and past job history.
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We do not collect: biometric information, sensory
or surveillance data, education information (as defined in the Family Education
Rights and Privacy Act); or profile data.
Sensitive Personal Information
We do not use or disclose the
below sensitive personal information for purposes other than those business
purposes specifically enumerated under CCPA. As a result, we do not offer a
right to limit our use or disclosure of these categories of sensitive personal
information.
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Categories of Sensitive Personal Information
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Purposes for Collection and Use
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Social Security Number, Driver’s License, State
Identification Card, or Passport Number
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To perform services or provide goods you request and reasonably
expect from us
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To detect, prevent, and investigate security incidents
involving your information
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To investigate or curtail malicious, fraudulent, or illegal
actions directed at us and to prosecute those responsible
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To perform services for our business needs such as maintaining
accounts, providing customer service, providing financing, verifying customer
information, processing payments, providing analytics services, storage, and
to fulfill orders
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To collect or process sensitive personal information where such
information is not being used to infer characteristics about you but may be
used to provide a specific good or service based on the sensitive information
you provided
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Account
log-in, financial account, password, or credentials allowing access to an
account
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To enhance your experience on our website in real time, so long
as we do not disclose your information to a third party
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To perform services for our business needs such as maintaining
accounts, providing customer service, providing financing, verifying customer
information, processing payments, providing analytics services, storage, and
to fulfill orders
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To ensure the quality or safety of a product, service, or
device
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To collect or process sensitive personal information where such
information is not being used to infer characteristics about you but may be
used to provide a specific good or service based on the sensitive information
you provided
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We do not collect: precise geolocation; racial or ethnic origin,
religious or philosophical beliefs, or union membership; contents of a
consumer’s mail, email, and text messages (unless we are the intended recipient
of the communication); genetic data; biometric information for the purpose of
unique identification; health information; information concerning sex life or
sexual orientation.
We have not and do not sell any of your personal information or
share with third parties for cross-context behavioral advertising (including
any sensitive personal information).
Retention Periods
We retain information for different periods of time depending on the
purposes for which we collect and use it. For example, if you have a commercial
loan with us, we will retain your information for the life of the loan, plus
any applicable legal requirements.
We will delete or de-identify information when it is no longer needed
to fulfill the purposes listed for each category above, unless a longer
retention period is required to comply with applicable laws. There may be
technical or other operational reasons where we are unable to fully delete or
de-identify your information. Where this is the case, we will take reasonable
measures to prevent further processing your information.
Please review our Privacy Policy below.
Privacy Policy
The purpose of this privacy
policy is to provide you with a comprehensive description of our online and
offline practices regarding our collection, use, disclosure, and retention of
personal information and of your rights as it relates to our Information
Practices and how you can exercise those rights.
The following table includes
disclosures for the preceding 12 months of: categories of personal information
we have collected about consumers, the categories we have disclosed for a
business purpose, and categories of third parties with whom we shared the
personal information during that period.
General Personal Information
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Category
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In the preceding
12 months this category was:
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Business or
Commercial Purpose for Collection & Disclosure
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Categories of
third parties to whom the information was disclosed
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Collected
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Disclosed
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Identifiers
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For our operational purposes or the operational purposes of our
service provider or contractors
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Keeping track of visitors to our website and monitoring the
effectiveness of our advertising, including auditing relating to counting ad
impressions of unique visitors, verifying positioning and quality, and
auditing compliance.
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Ensuring security and integrity of personal information as
needed and as reasonably necessary and proportionate for this purpose
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Debugging to identify and repair errors that impair existing
functionality
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Short-term, transient use
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Performing services on behalf of the business, including
maintaining or servicing accounts, providing products or services, providing
customer service, processing orders or transactions, verifying customer
information, processing payments, providing financing, providing analytic
services, storage, or other similar services.
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Providing advertising and marketing services, except for
cross-contextual advertising.
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Undertaking internal research for technological development.
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Undertaking activities to verify or maintain quality or safety
of a service or device and to improve or enhance a service or device.
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Service Providers who assist us in offering a product or
service to you
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Law enforcement, or other legal authorities
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Government entities
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Service providers who assist our business in operations, such
as cloud storage providers, cybersecurity providers, operating and management
companies
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Personal Information Categories from Cal. Civ. Code §
1798.80(e)
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Service Providers who assist us in offering a product or
service to you
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Law enforcement, or other legal authorities
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Government entities
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Service providers who assist our business in operations, such
as cloud storage providers, cybersecurity providers, operating and management
companies
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Characteristics of CA or Federal Protected
Classifications
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We do not
intentionally collect this information but it may be revealed in identity
data or other information we collect
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N/A
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Commercial Information
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- Service Providers who assist us in offering a product or service
to you
- Law enforcement, or other legal authorities
- Government entities
- Service providers who assist our business in operations, such as
cloud storage providers, cybersecurity providers, operating and
management companies
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Internet or Other Similar Network Activity
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- Service Providers who assist us in offering a product or service
to you
- Law enforcement, or other legal authorities
- Government entities
- Service providers who assist our business in operations, such as
cloud storage providers, cybersecurity providers, operating and
management companies
- Web analytics providers
- Web hosting service providers
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Geolocation Data
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- Service Providers who assist us in offering a product or service
to you
- Law enforcement, or other legal authorities
- Government entities
- Service providers who assist our business in operations, such as
cloud storage providers, cybersecurity providers, operating and
management companies
- Web analytics providers
- Web hosting service providers
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Professional or Employment-Related Information
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- Service Providers who assist us in offering a product or service
to you
- Law enforcement, or other legal authorities
- Government entities
- Service providers who assist our business in operations, such as
cloud storage providers, cybersecurity providers, operating and
management companies
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We do not collect: biometric information,
sensory or surveillance data, education information (as defined in the Family
Education Rights and Privacy Act); or profile data.
Sensitive Personal Information
We do not use or disclose the
below sensitive personal information for purposes other
than those business purposes specifically enumerated under CCPA. As a
result, we do not offer a right to limit our use or disclosure of these
categories of sensitive personal information.
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Category
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In the preceding 12 months this category was:
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Business or Commercial Purpose for Collection &
Disclosure
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Categories of third parties to whom the information
was disclosed
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Collected
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Disclosed
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Social
Security Number, Driver’s License, State Identification Card, or Passport
Number
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☒
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To perform services or provide goods you request and reasonably
expect from us
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To detect, prevent, and investigate security incidents
involving your information
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To investigate or curtail malicious, fraudulent, or illegal
actions directed at us and to prosecute those responsible
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To perform services for our business needs such as maintaining
accounts, providing customer service, providing financing, verifying customer
information, processing payments, providing analytics services, storage, and
to fulfill orders
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To collect or process sensitive personal information where such
information is not being used to infer characteristics about you but may be
used to provide a specific good or service based on the sensitive information
you provided
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Service Providers who assist us in offering a product or
service to you
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Law enforcement, or other legal authorities
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Government entities
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Service providers who assist our business in operations, such
as cloud storage providers, cybersecurity providers, operating and management
companies
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Account
log-in, financial account, password, or credentials allowing access to an
account
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☒
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☒
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To enhance your experience on our website in real time, so long
as we do not disclose your information to a third party
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To perform services for our business needs such as maintaining
accounts, providing customer service, providing financing, verifying customer
information, processing payments, providing analytics services, storage, and
to fulfill orders
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To ensure the quality or safety of a product, service, or
device
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To collect or process sensitive personal information where such
information is not being used to infer characteristics about you but may be
used to provide a specific good or service based on the sensitive information
you provided
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Service Providers who assist us in offering a product or
service to you
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Law enforcement, or other legal authorities
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Government entities
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Service providers who assist our business in operations, such
as cloud storage providers, cybersecurity providers, operating and management
companies
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We do not collect: precise geolocation; racial or ethnic origin,
religious or philosophical beliefs, or union membership; contents of a
consumer’s mail, email, and text messages (unless we are the intended recipient
of the communication); genetic data; biometric information for the purpose of unique
identification; health information; information concerning sex life or sexual
orientation.
The categories identified as collected in the tables above
were collected from the following categories of sources:
- You directly
- Credit Reporting Agencies
- Appraisers
- Insurance Companies
- Employers
- Real Estate Brokers
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
What we Sell or Share and Right to Opt-Out
We have not and do not sell any of your personal information or
share with third parties for cross-context behavioral advertising (including
any sensitive personal information). We do not have actual knowledge that
we sell the personal information of minors under 16 years of age.
Your Right to Know
You have the
right to request that we disclose any of the following:
- the categories of personal information we have collected about you
- the categories of sources from which the personal information is collected
- the business or commercial purpose for collecting, selling, or sharing with third parties for cross context behavioral advertising (e.g. targeted advertising)
- the categories of third parties to whom we disclose personal information
- the specific pieces of personal information we have collected about you
You can do
this through a verified consumer request. That process is described below in
the section, “Submitting a Verified Consumer Request.”
Your Right to Request Correction of Inaccurate Personal Information
You have the
right to request correction of inaccurate personal information maintained by
us. We may request documentation from you to determine the accuracy of the
information. If you provide us documentation either upon our request or through
your own initiative, that documentation will only be used for the purpose of
correcting your personal information and complying with our recordkeeping
requirements. We may deny your request if we have previously denied your same
request to correct an alleged inaccuracy in the past six (6) months, unless you
provide new or additional documentation that the information at issue is
inaccurate.
As an
alternative to correction, we may delete the inaccurate information if it does
not negatively impact you or if you consent to this deletion. We reserve the
right to deny this request if allowed under law, or if we determine that the
contested information is more likely than not accurate, based on the totality
of circumstances. You can submit a correction request through a verified
consumer request. That process is described below in the section, “Submitting a
Verified Consumer Request.”
Your Right to Request Deletion of Your Personal Information
You have
the right to request that we delete any of your personal information collected
by us, subject to certain exceptions. You can do this through a verified
consumer request. That process is described below in the section, “Submitting a
Verified Consumer Request.”
There may
be scenarios where we deny your deletion request. If that occurs, we will
provide you with an explanation as to why we could not delete all or some of
your personal information.
Submitting a Verified Consumer Request
You have the right to submit
verified consumer requests to know information, to correct information, or for
deletion.
You may submit a request to know
information, to correct information, or for deletion by providing your name,
address, and email address, along with description of the type of request you
are seeking, by emailing us at sptlegal@starwood.com,
by writing us at 2340 Collins Ave., Suite 700, Miami Beach, Florida 33139, or
by calling us toll free at 1-833-431-1245. Your request will be verified by
matching the information you provide to information that we have collected.
The response to a request to know
will provide all personal information collected and maintained about you since
January 1, 2022, unless doing so proves impossible or would involve
disproportionate effort. Please note that we are not required to provide
personal information to you more than twice in a 12-month period. We cannot
respond to your request or provide you with personal information if we cannot
verify your identity or authority to make the request. We will only use
personal information provided in a verifiable consumer request to verify the
requestor’s identity or authority to make the request.
If you submit a request that is
not through one of these designated methods or is deficient in some manner
unrelated to verification, we will provide you with information on how to
submit the request or remedy any deficiencies.
Once we receive your verifiable
consumer request, we will confirm receipt of the request within 10 business
days. We will respond to your request within 45 calendar days, if we are able
to verify your identity. Requests for deletion will require a separate
confirmation that you want your information deleted.
Requests to Know or Delete for
Child Under the Age of 13: We do not knowingly collect information of minors
under the age of 13.
Using an Authorized Agent to Submit a Request
Only you, or a natural person or
a business entity registered with the Secretary of State to conduct business in
California that you have authorized to act on your behalf, may make a
verifiable consumer request related to your personal information. If you use an
authorized agent, you may provide a power of attorney executed pursuant to
California Probate Code sections 4000 to 4465. If a power of attorney that
meets the above provisions is not submitted, you will be required to provide
the authorized agent signed permission to submit a request, verify your
identity directly with us, and directly confirm with us that you provided the
authorized agent permission to submit the request.
If you’re an authorized agent
making a request, you must email us at sptlegal@starwood.com
or write us by post at 2340 Collins Ave., Suite 700, Miami Beach, Florida 33139
and:
- Provide the power
of attorney provided to you by the consumer pursuant to Probate Code
sections 4000 to 4465; or
- Provide proof of signed
permission along with a copy of your ID and have the consumer
e-mail us or write us at the same address listed above to directly confirm
with us that they provided you permission to submit the request.
Your Right to Non-Discrimination for the Exercise of a Privacy Right
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.
Other California Privacy Rights
We do not respond to Web browser
“do not track” signals or other mechanisms.
Changes to Our Privacy Notice
We reserve the right to amend
this privacy notice at our discretion and at any time. When we make changes to
this privacy notice, we will post the updated notice on the Website and update
the notice’s effective date. Your continued use of our Website following the
posting of changes constitutes your acceptance of such changes.
Contact for More Information
If you have any questions or
comments about this notice, the ways in which we collect and use your
information, your choices and rights regarding such use, or wish to exercise
your rights under California law, please do not hesitate to contact us at:
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