Privacy Policy

10. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it. The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.” If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice for more information on our collection and use of your Personal Information in that capacity.

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, date of birth, Social Security number, state identification card number (healthcare license and certification numbers))
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (as well as the categories listed in “Identifiers” category above)
• Commercial information (records of products or services purchased, obtained or considered)
• Internet or other electronic network activity information (information regarding consumer’s interaction with website, application or advertisement)
• Geolocation data
• Professional or employment-related information (including employment history)
• Education information
• Sensitive Personal Information (Personal Information that reveals a consumer’s Social Security number; account log-in and password)

We collect Personal Information directly from California residents and from advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, employers, and third parties from whom you make purchases or engage with through the Sites and Services. We do not collect all categories of Personal Information from each source. In addition to the purposes stated above in the section “How We Use Your Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services
• Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service that is owned, manufactured, manufactured for, or controlled by us
• Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Sale, Sharing, and Disclosure of Personal Information

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

Categories of Personal Information	Categories of Third Parties
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)IP addressInternet or other electronic network activity information (information regarding consumer’s interaction with website, application or advertisement)Geolocation data	Data analytics providers; advertising networks; application monitoring providers

We sold or shared Personal Information to third parties to advance our commercial and economic interests.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information:

Categories of Personal Information	Categories of Recipients
Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address) Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device) Commercial information (records of products or services purchased, obtained or considered	Data storage providers; marketing vendors
State identification card number (healthcare license and certification numbers)	Government entities / licensing authorities
Name Credit/debit card number	Payment processors

We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Your Rights If you are a California resident, you have the following rights with respect to your Personal Information:

1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
3. The right to correct inaccurate Personal Information that we maintain about you;
4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct You may submit a request to know, delete, and/or correct by calling us toll free at 1-888-404-7996 or by emailing support@propelus.com. If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident. Our Process for Verifying a Request to Know, Delete, and/or Correct We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information. You may submit a request to opt out of sales or sharing by calling us toll free at 1-888-404-7996 or by emailing support@propelus.com. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “Opt-Out Preference Signals” section above for more information.

Notice of Financial Incentive

From time to time, you may have the opportunity to provide Personal Information in exchange for discounts and price differences. For example, we provide discounts and price differences in exchange for you subscribing to our mailing list. Categories of Personal Information that we may collect when you subscribe to receive discounts and price differences include your email address. How to Opt In and Right to Withdraw Signing up for discounts and price differences is optional. By providing your email address during the discount sign-up process, you affirmatively opt in to receiving the financial incentive and to joining our mailing list. You have the right to withdraw from the financial incentive at any time. If you opt out of receiving a financial incentive, we will not reduce the value of any financial incentives you previously received from us. If you wish to withdraw from receiving the financial incentive, you may submit such a request at any time by emailing us at support@propelus.com. How the Financial Incentive is Reasonably Related to the Value of Your Personal Information The financial incentive or price difference is reasonably related to the value provided by your Personal Information. We take into consideration, without limitation, the anticipated revenue generated from such information, the anticipated expenses which we might incur in the collection, storage, and use of such information, and the anticipated expenses which we might incur related to the offer, provision, and imposition of any financial incentive or price difference. Based on this analysis, the value of your Personal Information that allows us to make these offers and financial incentives is the value of the offer itself.

Shine the Light Law

We do not disclose personal information obtained through our Sites or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.