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California Privacy Notice

Your California Privacy Rights
If you are a resident of California, your right to submit certain requests relating to your personal information is described below. Please note that when submitting a request, you will be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the process described below.

Right to Opt Out of the Sale of Your Personal Information
California residents have the right to opt out of the sale of their personal information. However, since we do not sell Personal Information, there is no need to submit such a request to us. If you have any questions, please reach out to us by email at privacy@treace.net or by calling us at 1-877-360-3232.

Right to Request More Information
If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:

  1. The categories of personal information we have collected about you;
  2. The categories of sources from which the personal information was collected;
  3. Our business or commercial purposes for collecting your personal information;
  4. The categories of third parties with which we share your personal information;
  5. The categories of personal information that we disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information;
  6. The specific pieces of personal information we have collected about you;
  7. A list of all third parties to whom we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes.

You may submit a request for the information above via email to privacy@treace.net or by calling us at 1-877-360-3232. In connection with submission of your request, we will take steps to verify your identity as outlined below, and you will need to verify your identity before action is taken.

Please note that due to the different requirements of the applicable laws, our response times may vary depending on the specific type(s) of information sought. We respond to all verifiable requests for information as soon as we reasonably can and no later than legally required.

Right to Request Deletion of Your Personal Information

California residents also have the right to request that we delete your Personal Information collected or maintained by us. Once we receive your request, we will let you know what, if any, Personal Information we can delete from our records, and we will direct any Service Providers (such as Google Analytics) that may have collected personal information about you through our websites to delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct Service Providers to delete your Personal Information from their records. For example, if we need to: (1) retain your Personal Information to complete a transaction or provide services; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug or repair errors; or (5) comply with a legal obligation. You may submit a request to delete your personal information by via email to privacy@treace.net or calling us at 1-877-360-3232. In connection with submission of your request, we will take steps to verify your identity as outlined below, and you will need to verify your identity before action is taken.

Verification of Requests for Further Information or to Delete Personal Information
Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates, and to prevent unauthorized access or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of personal information provided to verify your identity, the nature of our business relationship with you, and available technology for verification.

We will generally try to avoid requesting additional information from you for the purpose of verification, but we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by law.

The following generally describes the verification processes we use:

  • Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity, but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
  • Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
    • For requests to know categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
    • For requests to know specific pieces of personal information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records.
    • For requests to delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.

If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.

Right to Non-Discrimination for the Exercise of Your Privacy Rights
If you choose to exercise any of the privacy rights conferred by the California Consumer Privacy Act of 2018, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing our services to you, charge you different prices or provide a different level or quality of services to you unless those differences are related to the value of your personal information.

 

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