Effective date: 9/30/2024

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        This Notice, which is incorporated into our Privacy Policy provides additional information for residents of California and describes their rights and choices under the California Consumer Privacy Act as amended by the California Privacy Rights Act effective January 1, 2023 (“CCPA”).

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        Our Privacy Policy describes the information that we collect, the business purposes for using information and how we disclose information.

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        CCPA Rights

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        The CCPA provides California residents with the following rights regarding their personal information. 

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        A.  Information Access and Portability Rights

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        California residents have the right to request that we disclose certain information upon request about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12 month period.  Once we receive and confirm your verifiable request, we will disclose to you:

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• The categories of personal information we collected about you, the sources of the information, our business or commercial purpose for collecting the information and whether the information was disclosed for a business purpose, shared or sold.

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• The categories of information we disclosed for a business purpose and the categories of information we sold or shared during the prior 12 months along with the categories of recipients of such information.

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• The specific pieces of personal information we collected about you during the prior 12 months, or, at your option, since January 1, 2022. For your security we will require that you provide information about yourself so that we can verify your identity before we can provide specific information to you. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

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        B. Information Deletion Rights

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        California residents have the right to request that we delete any of your personal information that we collected from them and retained, subject to certain exceptions. For your security we will require that you provide information about yourself so that we can verify your identity before we can delete information about you. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You may make deletion requests at any time. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

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• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities and to help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.

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• Debug products to identify and repair errors that impair existing intended functionality.

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• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

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• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.

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• Comply with a legal obligation.

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• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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        C.  Information Correction Rights

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        California residents have the right to request that we correct information that we hold which is inaccurate.  For your security we will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections.  In some cases, for instance if you have an account with us, you can update your information by logging into your account.  You can make information correction requests at any time.

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        D. Opt-Out Rights

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• Do Not Sell My Personal Information.  California law provides that if you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information and that we not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. We do not sell your information.

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• Do Not Share My Personal Information.  California law provides that you have the right to opt out of having your personal information shared with others for cross-context or behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us to select advertisements to show you. We do not share information for cross-context or behavioral advertising purposes.

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• Limit Processing of Sensitive Personal Information.  California law provides that you have the right to tell us not to process or disclose Sensitive Personal Information for any purpose other than allowed by law.  We only process Sensitive Personal Information for the purposes permitted by law.

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        Exercising Your CCPA Rights

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        A. Making CCPA Requests.

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• Access, Correction and Deletion.  To exercise the access, correction, and deletion rights, California residents may contact us by calling us toll free at (866) 204-0769 or emailing us at PrivacyPolicy@fullerthaler.com.  We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. Any disclosures we provide will only cover the 12-month period preceding receipt of your request, but you may request that we expand the 12-month period to cover information collected since January 1, 2022, and we will honor that expanded request unless doing so would involve a disproportionate effort.  We will acknowledge receipt of your request within 10 business days and will endeavor to respond within 45 days of receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

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• Opt-Out Rights.  Because we do not sell your information, share your information for cross-context behavioral marketing, or process/disclose your sensitive information outside of permitted purposes, you do not need to opt out of these activities. 

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        Using an Authorized Agent 

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        You may submit a request through someone holding a formal Power of Attorney.  Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized.  We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

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        Non-Discrimination

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        We will not discriminate against you as a result of your exercise of any of these rights unless permitted by the CCPA.

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        Retention of Personal Information

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        We will store personal information in a form which permits us to identify consumers, for as long as necessary for the purpose for which the personal information is processed.  We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the CCPA for a period of 2 years.