Additional Privacy Notice for California Residents

A. Notice at Collection

1. Collection of Personal Information

We may collect the following categories of personal information from you:

Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
California Consumer Records Statute Personal Information: Categories of personal information described in the California Consumer Records Statute Cal. Civ. Code Section 1798.80(e), which may include, but are not limited to, your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected Classification Characteristics: Characteristics of protected classifications under California or federal law such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) etc.
Commercial Information: Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric Information: Biometric information such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke or other physical patterns.
Internet or other Electronic Network Activity Information: Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
Geolocation Data: Geolocation data such as physical location or movements.
Sensory Data: Sensory data such as audio, electronic, visual, thermal, olfactory or similar information.
Professional or Employment-related Information: Professional or employment-related information such as current or past job history or performance evaluations etc.
Inferences drawn from the categories of information stated above.

In the preceding twelve (12) months, we have collected the following categories of personal information from consumers although all items listed as examples under a particular category may not have been collected.

Category A: Identifiers
Category B: California Consumer Records Statute Personal Information
Category C: Protected Classification Characteristics
Category D: Commercial Information
Category E: Biometric Information
Category F: Internet or Other Electronic Network Activity Information
Category I: Professional or Employment Related Information
Category J: Inferences drawn from the categories of information stated above.

2. Use of Personal Information

We may use your personal information for the following business purposes:

To communicate with you;
To evaluate your eligibility for, and to provide you with, certain products and services;
To facilitate payment;
To create, maintain, customize, and secure your account with us.
To conduct research and analytics, and to customize content and improve our services and business, including by developing new services and products;
To deliver interest-based, targeted and other advertising to you (with your consent, where required by law);
To permit third parties to market and advertise to you (with your consent where required by law);
To protect our rights and meet our legal obligations; and
Other uses that advance our legitimate commercial or economic interests.

3. Disclosure of Personal Information

We may disclose your personal information to a third party for one or more of the above-referred business purposes. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for one or more of the above-referred business purposes (see above for further descriptions/examples of the categories), although all items listed as examples under a particular category may not have been disclosed:

Category A: Identifiers
Category B: California Customer Records Personal Information
Category C: Protected Classification Characteristics
Category D: Commercial Information
Category E: Biometric Information
Category F: Internet or Other Electronic Network Activity Information
Category I: Professional or Employment-related Information
Category J: Inferences drawn from other personal information

We disclose your personal information for one or more of the above-referred business purposes to the following categories of third parties:

Our affiliates;
Our service providers;
Third parties to whom you authorize us, directly or indirectly, to disclose your personal information in connection with products or services we provide to you (including by accepting cookies during your interaction with the Site);
Government or regulatory authorities.

We do not sell any personal information for monetary consideration. However, we do share personal information such as certain identifiers, internet or other electronic network activity etc. with third parties such as website analytics and data analytics companies as part of a mutually beneficial business relationship in exchange for non-monetary consideration such as an enhanced ability to serve you content that is of interest to you. You have the right to opt-out of such disclosure as set forth in Section B below under “Your Rights” because the California Consumer Privacy Act (“CCPA”) contains broad definitions of “sale” and “personal information”, which may deem such common flow of information in the digital analytics ecosystem to be a sale. In the preceding twelve (12) months, we have not sold any personal information except for disclosure to third parties as mentioned in this paragraph (to the extent that may be considered a “sale” under the CCPA as described above.).

While it is not possible to provide the specific length of time that we intend to retain each category of information described above, we will not retain your personal information for longer than is reasonably necessary for the disclosed purposes.

B. Notice of Rights under CCPA

Under the CCPA, California residents have certain rights regarding the personal information that businesses collect from them.

Right to Opt-out of Sale of Personal Information

While we do not sell personal information in exchange for any monetary consideration, as stated above under Section A.3., we do share personal information such as certain identifiers and internet or other electronic network activity etc. with third parties such as website analytics and data analytics companies as part of a mutually beneficial business relationship in exchange for non-monetary consideration such as an enhanced ability to serve you content that is of interest to you. To the extent such sharing of information may be considered a ‘sale’ under the CCPA Cal. Civ. Code 1798.140(t)(1), you have the right to opt-out of the sale of your personal information (subject to certain exceptions).

To opt-out of the sale of your personal information, please visit “DO NOT SELL MY PERSONAL INFORMATION” to make a request.

Right to Access

You have the right to request disclosure about what categories of personal information we have sold or disclosed for a business purpose about you and the categories of third parties to whom the personal information was sold or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request.

The categories of personal information that we have collected about you.
The categories of sources from which we collected the personal information.
The business or commercial purpose for collecting or selling the personal information.
The categories of third parties with whom we shared personal information.
The specific pieces of personal information we have collected about you.
The categories of personal information that we disclosed about you for a business purpose.
The categories of personal information that we sold about you, as well as the categories of third parties to whom we sold the information.

If you would like to exercise your right to request disclosure, please send an email to privacy@curiaglobal.com or call us at 877.275.2674 or you may use the form provided here. Our privacy team will examine your request and respond to you as quickly as possible.

Right to Request Deletion

You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfil a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.

If you would like to exercise your right to delete, please send an email to privacy@curiaglobal.com or call us at 877.275.2674 or or you may use the form provided here. Our privacy team will examine your request and respond to you as quickly as possible.

Right to Request Correction of Inaccurate Personal Information

You have the right to request that we correct inaccurate personal information. Please note that we are obligated to use commercially reasonable efforts to correct inaccurate information. IIf you would like to exercise your right to request correction, please send an email to privacy@curiaglobal.com or call us at 877.275.2674 or you may use the form provided here.

Right to Non-Discrimination

We will not discriminate against you (e.g., through denying goods or services, charging different prices, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

How do we handle your requests?

We will endeavor to respond to a verifiable consumer request within the required timeframes. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

C. Changes to this Additional Privacy Notice

This Additional Privacy Notice for California Residents may be amended and/or updated from time to time .We reserve the right to make such amendments at our discretion and at any time. When we make changes to this privacy notice, we will notify you by posting the updated notice in this space.

Last Updated: July 5, 2021