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Privacy & Cookie Policy

 

Last Updated: August 2nd, 2023

The Privacy and Cookie Policy (“Privacy Policy”) describes the privacy practices of Acme Smoked Fish Holding Corp. and its subsidiaries and affiliates (collectively, “Acme”, “we”, “us”, and/or “our”).

The purpose of this Privacy Policy is to inform you of:

  • The information, including personal information, we may collect from you when you visit our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, respond to our emails, place orders via mail or fax or any other method, use our products or services (collectively, the “Services”),
  • Why we gather information from you,
  • How we collect information from you,
  • How we use information we collect from you (including with whom we may share it),
  • How we secure your personal information, and
  • The choices you have regarding our use of, and your access to and correction and deletion of, personal information you have provided.

 We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States, and we are responsible as controller of that personal information for the purposes of those laws.

By creating an account, providing information to us (by any means, whether in correspondence, via our Services, or otherwise), or continuing to use our Services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR PRACTICES, YOU MAY NOT USE OUR SERVICES. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME AND YOUR CONTINUED USE OF OUR SITE CONSTITUTES YOUR ACCEPTANCE OF THOSE CHANGES. WE ENCOURAGE YOU TO REVIEW THIS PRIVACY POLICY PERIODICALLY.

The Types Information We Gather

 As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual.  We may collect and use the following categories of personal information:

  • Identifiers (e.g., a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers);
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number;
  • Characteristics of protected classifications under California or federal law;
  • Commercial information including which of our products or services you purchased from us;
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
  • Photos of you interacting with our products in connection with Company marketing campaigns; and
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Acme does not process, collect, or store payment information for orders placed through the Service. All payments are processed through third-party vendors such as Athorize.net, Magento, Klaviyo, and ShipStation. For orders submitted through the Service, you will be notified during the payment process when you are accessing services performed by third-party vendors and/or when you are leaving our Services. If you have concerns about your personal and/or payment information and would like to know which specific vendors have processed your information, please contact: legal@acmesmokedfish.com and 718-383-8585.

The Sources of Information We Collect Include:

We may generally collect information directly from you when you:

  • Use our Services,
  • Place an order or receive an order, or
  • Engage in other activities, services, products and resources we make accessible to our customers, members or users.

In the course of using our Services, you may choose to provide us with personal information to help us serve your needs. For example, you may send us electronic mail (through a mailer or a web form) to request information, you may sign up for a mailing list, or you may send us your address so we may send you an application or other material. Any personal information you send us will be used only for the purpose indicated. Requests for information will be directed to the appropriate staff to respond to the request, and may be recorded to help us update our site to better respond to similar requests. We will not sell, exchange or otherwise distribute your personal information without your consent, except to the extent required by law. Each webpage in connection with the Services, which requests information, discloses the purpose of that information. If you do not wish to have the information used in that manner, you are not required to provide it.

We may also collect information through automated means. There are three methods Acme uses to collect information that in connection with our Services: network traffic logs, web visit logs, and cookies.

  • Network Traffic Logs - In the course of ensuring network security and consistent service for all users, Acme employs software programs to do such things as monitor network traffic, identify unauthorized access or access to nonpublic information, detect computer viruses and other software that might damage Acme computers or the network, and monitor and tune the performance of the Acme network. In the course of such monitoring, these programs may detect such information as E-mail headers, addresses from network packets, and other information. Information from these activities is used only for the purpose of maintaining the security and performance of Acme networks and computer systems. Personal information collected from these activities is not released to external parties without your consent unless required by law.
  • Web Visit Logs - Acme Services routinely collect and store information from online visitors to help manage those sites and improve service. This information includes the pages visited in connection with the Services, the date and time of the visit, the internet address (URL or IP address) of the referring site, the domain name and IP address from which the access occurred, the version of browser used, the capabilities of the browser, and search terms used on our search engines. Our Services make no attempt to identify individual visitors from this information. Any personal information collected from web visit logs is not released to external parties without your consent unless required by law.
  • Cookies - Cookies are pieces of information stored by your web browser on behalf of a web site and returned to the web site on request. Our Services may use cookies to carry data about your current session in connection with the Services from one web page to the next, and to identify you to our Service related website between visits.
    • Essential Cookies - Some cookies are necessary to allow you to browse our Service related website, use its features, and access secure areas. The use of these cookies is essential for the website to work.
    • Performance and Functionality - These cookies are used to enhance the performance and functionality of our Services. For example, we may use these cookies so that we recognize you on our Service related website and remember your previously selected preferences. These could include what language you prefer and your geographic location. These cookies are nonessential to the use of our website, however, without these cookies, certain functionality may become unavailable. A mix of first-party and third-party cookies are used.
    • Analytics and Customization - We use these cookies and technologies to analyze how the Services related website is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Services. For example, we use Google Analytics to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here.
    • If you prefer not to receive cookies, you may turn them off in your browser, or may set your browser to ask you before accepting a new cookie. Some pages may not function properly if the cookies are turned off. Unless otherwise notified, we will not store data, other than for these two purposes, in cookies. Cookies remain on your computer, and accordingly we neither store cookies on our computers nor forward them to any external parties. Unless otherwise notified, we do not use cookies to track your movement among different web sites and do not exchange cookies with other entities. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.

Do Not Track

We do not track users across the web and therefore do not respond to web browser “do not track” signals.

to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

How We Use/Share The Information We Collect

Acme gathers information, including personal information, mainly to communicate with you and to process your orders. However, Acme also uses such information to help improve our products and customer service, and to provide an enhanced and more personalized shopping experience. This processing: is necessary to perform a contract with you or take steps to enter into a contract at your request; is necessary for us to comply with a relevant legal obligation; is in our legitimate interests (subject to your interests and fundamental rights) and notably our legitimate interest in using applicable data to conduct and develop our business activities; or you have consented to the processing.

Acme does not sell customer information to third-parties. Acme does not share customer information with any third-parties other than the vendors identified in this Privacy Policy for the purpose of performing the Services and processing and fulfilling customer orders.

We use information we collect to communicate with you, to process your orders, to improve our products and services (such as by responding to your feedback), and to conduct internal research (such as statistics on favorite -- i.e., most ordered -- products). We may also use your information, as necessary or appropriate in our view, to operate the Service, respond to your inquiries, and process orders.

Electronic Communication

We may use your personal information to send you updates (by email, text message, telephone or post) about our products or Services, including exclusive offers, promotions or new products or services.

We want to communicate with you only to the extent you want to hear from us. Any promotional email we send to you will include an “unsubscribe” link to use or a link to opt-out of receiving further promotional emails from the sender.

If you wish to set your preferences concerning promotional communications, please let us know by contacting us as noted below in the “How to Contact Us” section and identify your preferences regarding promotional communications. Your instructions will be processed as soon as reasonably practicable and in accordance with law.

Disclosures of Personal Information

We routinely share personal information with:

  • Our affiliates;
  • Service providers we use to help deliver our products and Services to you, such as payment service providers, warehouses and delivery companies;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
  • Third parties approved by you, including third-party payment providers;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

In certain situations, we may be required to disclose personal information in response to lawful requests from public authorities, including to comply with national security or law enforcement requirements. We reserve the right to disclose information we collect from you, or that you provide to us, as required by law, in response to legal process and law enforcement requests, when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request, and to protect the rights or property of Acme, its users, customers, recipients, and vendors.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Maintenance and Retention of Information

We may retain your personal information in accordance with our data retention policies and for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements, or until you request us to stop using it. We may, however, keep some of your personal information to ensure that we comply with your request not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased, even if it includes your personal data, until such time as you are no longer our customer. If you have questions about our data retention policies, or would like a copy of such policies, please contact us as noted below. Different retention periods apply for different types of personal information.  To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

Keeping Your Personal Information Secure.

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. However, while we strive to protect your privacy, due to many reasons, including the inherent security flaws in the internet, we cannot guarantee the security of any information you disclose to us and, as such, you agree that your disclosure of such information is at your own risk.

Portions of the Service (such as our Member registration and Address Book) may require registration and log-in processes in which you will select a user ID and password (collectively, the "Password"). Passwords provided to you by us are the confidential property of Acme and may be used by you solely for your individual use of the Service (and otherwise as specified by us). You are responsible for maintaining the confidentiality of any Password and for all activities that occur using your Password, whether or not authorized by you. You agree to immediately notify us of any unauthorized use of your Password or accounts.

Privacy Requests

Acme respects your control over your information and, upon request, we will confirm whether we hold or are processing information that we have collected from you. You also have the right to amend or update inaccurate or incomplete personal information (including the right to obtain a copy of the corrected information), request deletion of your personal information, or request that we no longer use it. If you would like to update or correct information previously provided to us, please contact us as indicated below in the “How to Contact Us” section. Upon your written request, we will provide you with information about whether we hold any of your personal information and will confirmation that the data has been corrected or deleted. We will respond to your request within the allotted time frame and will notify you if an extension is needed. If you are a resident of California, Colorado, Connecticut, Iowa, Virginia, or Utah please go to our Privacy Notice Addendum to learn about additional rights you may have under applicable data protection laws.

Where Your Personal Information is Held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Disclosures of Personal Information”).

A Note to Users Outside of the United States

Acme is headquartered in the United States and utilizes service providers in the United States. The Services are not intended for visitors outside the United States. If you are a non-U.S. user of the Services, by visiting our website or providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. If you choose to access our Services outside the United States, Acme and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Where the laws of your country allow you to do so, by using the Services or by providing your data, you consent and authorize Acme to transfer, store, and use all such personal information in the United States of America (and any other country where we operate) which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that personal information by us on our servers located in the United States of America, as described in this Privacy Policy. If you do not want your personal information transferred to the United States of America and any other country where we operate, please do not submit any information to us or use the Services.

Children and our Site

Our Services are not directed to children, and you may not use our Services if you are under the age of 18. If you are under 18, do not use our Services, access our website, or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use.

If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under 13, please see our “How to Contact Us” Section below. Please visit the FTC's website at www.ftc.gov for tips on protecting children's privacy online.

Third Party Websites

If, in your interactions with our Services, you are linked or directed to, or click on, a third party website, we cannot control what information you may provide to that party or on that website, and we are not responsible for how that party may use or disclose any information you may provide to them. This is not as an endorsement by us of any third party website, content that may be offered on such third party website, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third party website, product or service offerings. As such, we urge that you exercise caution before providing them with your personal information and to review the third party’s privacy policy for information on its data processing practice.

You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.

How To Contact Us

To update your information, inquire as to what information of yours, if any, we are maintaining, request deletion or removal of your information, or for any other privacy related inquiries, please contact us by email at [info@acmesmokedfish.com], by telephone at 718-383-8585, or in writing at:

Acme Smoked Fish Holding Corp.

30-56 Gem Street

Brooklyn, NY 11222

Alternatively, you can submit a request on our online form linked here

Changes to this Privacy Policy

This Privacy Policy was published on the date “Last Updated” above. Acme may change this Privacy Policy from time to time in the future. Any changes will be posted here and reflect the date of such changes on the first page of this Privacy Policy. We advise you to check back frequently to see any updates or changes. By using our website and the Service, after such changes take effect, you agree to be legally bound and to abide by the revised Privacy Policy and Terms of Use, of which this Policy is a part.

Privacy Notice Addendum

This Privacy Notice Addendum (“Notice”) supplements the information contained in Acme Smoked Fish Holding Corp. and its subsidiaries and affiliates Privacy and Cookie Policy and applies solely to all visitors, users, and others who reside in the State of California, Colorado, Connecticut, Iowa, Utah, or Virginia ("consumers" or "you"). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act of 2021, the Connecticut Data Privacy Act of 2022, the Iowa Consumer Data Protection Act of 2023, the Utah Consumer Privacy Act of 2022, the Virginia Consumer Data Protection Act of 2023, and certain other privacy and data protection laws, as applicable (collectively, the " Statutes"). Any terms defined in the Statutes will have the same meaning when used in this Notice.

As further set forth in our Privacy Policy, we may collect certain information that is (i) linked or reasonably linkable to an identified or identifiable individual or natural person, or (ii) that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household, or (iii) as further defined in the Statutes as “Personal Data” or “Personal Information.”

1.           Your Rights Under the CCPA and CPRA. You may have the right under the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.

Personal Information Sold, Shared, Disclosed, or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

  • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
  • The categories of personal information that we disclosed about you for a business purpose.

We do not sell or share your personal information for monetary or other valuable consideration.

Right to Limit Use and Disclosure of Sensitive Personal Information.

You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services.

We do not collect sensitive personal information.

Right to Correction

You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Right to Deletion

Subject to certain exceptions set out by statute, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

 

2.           Personal Information We Sold or Disclosed for a Business Purpose.

In the preceding 12 months, we have not sold to any third parties any category of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

  • Identifiers (e.g., a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers);
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number;
  • Characteristics of protected classifications under California or federal law;
  • Commercial information including which of our products or services you purchased from us;
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
  • Photos of you interacting with our products in connection with Company marketing campaigns; and
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

3.           Your Rights Under the Colorado Privacy Act.

The Colorado Privacy Act provides consumers who are Colorado residents with specific rights regarding their Personal Data. This section describes your rights under the Colorado Privacy Act and explains how to exercise those rights.

Right to Opt-Out

You have the right to opt out of the processing of Personal Data concerning you for the purposes of:

  • Targeted Advertising;
  • The Sale of Personal Data; or
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Right of Access

You have the right to confirm whether we are processing Personal Data concerning you and 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.

Right to Deletion

You have the right to delete Personal Data concerning you.

Right to Data Portability

When exercising the right to access Personal Data, you have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

You may exercise this right no more than two times per calendar year.

Right to Appeal

We hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

The Colorado Privacy Act also gives you right to contact the Colorado Attorney General if you have concerns about the results of your appeal.

 

4.           Your Rights Under the Connecticut Data Privacy Act of 2022.

The Connecticut Data Privacy Act of 2022 provides consumers who are Connecticut residents with specific rights regarding their Personal Information. This section describes your rights under the Connecticut Data Privacy Act of 2022 and explains how to exercise those rights.

Right to Access

You have the right to confirm whether or not we are processing your Personal Data and access such 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.

Right to Deletion

You have the right to request that we delete Personal Data provided by, or obtained about, you.

Right to Data Portability

You have the right to obtain a copy of your Personal Data processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.

Right to Opt-Out

You have the right to opt out of the processing of the Personal Data for purposes of:

  • Targeted advertising;
  • The sale of personal data; or
  • Profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.

Right to Appeal

We hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

 

5.           Your Rights Under the Iowa Consumer Data Protection Act of 2023.

The Iowa Consumer Data Protection Act of 2023 provides consumers who are Iowa residents with specific rights regarding their Personal Information. This section describes your rights under the Iowa Consumer Data Protection Act of 2023 and explains how to exercise those rights.

Right to Access

You have the right to confirm whether we are processing your Personal Data and to access such Personal Data.

You may exercise this right no more than twice annually.

Right to Delete

You have the right to request we delete Personal Data provided by you.

Right to Data Portability

You have the right obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically practicable, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.

Right to Opt-Out

You have the right to opt out of the sale of Personal Data.

We do not sell your Personal Data.

Right to Appeal

We hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

The Iowa Consumer Data Protection Act of 2023 also gives you right to contact the Iowa Attorney General if you have concerns about the results of your appeal.

 

6.           Your Rights Under the Utah Consumer Privacy Act of 2022.

The Utah Consumer Privacy Act of 2022 provides consumers who are Utah residents with specific rights regarding their Personal Information. This section describes your rights under the Utah Consumer Privacy Act of 2022 and explains how to exercise those rights.

Right to Access

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

Right to Delete

You have the right to delete your Personal Data that you provided to us.

Right to Data Portability

You have the right to obtain a copy of your Personal Data that you previously provided to us, in a format that:

  • To the extent technically feasible, is portable;
  • To the extent practicable, is readily usable; and
  • Allows you to transmit the data to another controller without impediment, where the processing is carried out by automated means.

Right to Opt-Out

You have the right to opt-out of the processing of your Personal data for purposes of:

  • Targeted advertising; or
  • The sale of personal data.

 

7.           Your Rights Under the Virginia Consumer Data Protection Act of 2023.

The Virginia Consumer Data Protection Act of 2023 provides consumers who are Virginia residents with specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights under the Virginia Consumer Data Protection Act of 2023.

Right to Access

You have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.

You may exercise this right no more than twice annually.

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.

Right to Delete

You have the right to request we delete Personal Data provided by or obtained about you.

Right to Data Portability

You have the right to obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.

Right to Opt-Out

You have the right to opt out of the processing of the Personal Data for purposes of:

  • Targeted advertising;
  • The sale of personal data; or
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Right to Appeal

We hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

The Virginia Consumer Data Protection Act of 2023 also gives you right to contact the Virginia Attorney General if you have concerns about the results of your appeal.

 

8.           How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

  • Call us, toll-free, at 1-800-221-0795; or
  • Contact us by email or mail (see “How To Contact Us” below).

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by email/phone/in writing, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

You may use a representative, called an "authorized agent," to submit a request to us. An authorized agent means a natural person, or a business entity registered with the California Secretary of State, that you have authorized to act on your behalf. In order to protect your privacy, Company requires you to confirm that you have provided the authorized agent permission to submit the request and you must provide the authorized agent with signed permission. "Signed" means that the written attestation, declaration, or permission has either been physically signed or provided electronically pursuant to the Uniform Electronic Transactions Act. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required. Company may deny a request from an authorized agent that does not submit proof that they have been authorized to act on your behalf. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

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