Privacy Policy

Effective date: January 21, 2020

WayForward Technologies, Inc. ("us", "we", “WayForward”, or alternative first person reference) wants to thank you for your interest in connection with our interactive entertainment product entitled, Miraculous Crush (the “Game”) available in the Apple App Store and the Google Play Store (the “Digital Storefronts”).  If you are here, you have either been directed here through our Game, the applicable Digital Storefront or through our website(s): https://wayforward.com/ or https://family.wayforward.com (the “Website(s)”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services, as defined below, your rights to your data under US and International Law, including but not limited to the EU Directive 2002/58/EC and the EU General Data Protection Regulation (“GDPR”), the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM”), the US Children’s Online Privacy Protection Act (“COPPA”), and the California Consumer Privacy Act (“CCPA”), and the choices you have associated with that data. For individuals located in Brazil, we also seek to follow the Lei Geral de Proteção de Dados (commonly referred to as the “LGPD”). This privacy policy applies to the Website(s), any and all of our Games (including, without limitation, enhancements thereto or future DLC), our content, applications, services, patches, updates, or tools (each individually a “Service” and collectively the "Services") where this Privacy Policy is referenced, regardless of how you access or use them, including through mobile devices. This Privacy Policy does not apply to any third party websites, services or applications, even if they are accessible through our Services.

We use your data to provide and improve the Services. This Privacy Policy is solely intended to inform you of our data collection practices and your rights to any of your data that we may collect. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible here: wayforward.com/terms-of-service.

This Privacy Policy describes:

• The information we collect, how we collect such information and the purposes of our collection;
• How we use and with whom we share such information;
• How you can access and update your information; and
• How we protect the information we store about you.

Disclosure to California Residents: In our efforts to comply with applicable regulation, we ask and advise that California residents review the “CCPA Disclosure” at the end of this document.

Disclosure to Residents of Brazil: The LGPD grants residents of Brazil certain rights about the processing of their personal information and we ask and advise that residents of Brazil review the rights outlined in the “Your Rights” section of this Privacy Policy.

Definitions

Personal Data

Personal Data means information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, by reference to an identifier such as a name, a device identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Usage Data

Usage Data is data collected automatically either generated by the use of the Services or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s Device, as defined below.

Data Controller and Data Protection Officer

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data. Where we have a legal obligation to do so, we have appointed data protection officers (DPOs) to be responsible for our privacy program. You can contact our DPO via the Contact Us information detailed below in this Privacy Policy.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various third party Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is you - the individual using our Services! The User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection And Use

We collect different types of information for various purposes to provide and improve our Services to you.

Information We Collect

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you, or for updates (for example, if you request customer support or log in to our Game using your social media account) ("Personal Data").  We may also store customer support correspondence and any information contained within.

Personal Data may include, but is not limited to, your name, Facebook, Google or Apple log in information and associated profile picture, and e-mail address. Personal Data also includes the unique identifier (“Device Identifier”) that is associated, on a persistent or on-going basis, with your computer, mobile phone or other device (any, a “Device”) you use to access the Services. This information may also be used to publicly identify you as part of social features of the Services, which may include public leaderboards and other similar features, or privately in-Game through avatars. The applicable Digital Storefront may also retain credit card or other billing information to enable you to purchase items through our Game without having to re-enter such information each time. Please note that purchases from third parties may also be subject to additional policies.

With your consent, we may also use your Personal Data to provide you with advertisements, marketing or promotional materials and other information that may be of interest to you. You may opt out at any time by emailing support@wayforward.com or accessing your privacy settings in-Game.

Tracking, Cookies and Usage Data

We, or our third party service providers operating through our Website(s) or Game (such as analytics providers like Google Analytics) may also may also collect usage information concerning your access and use of the Services, or use cookies or similar tracking technologies to track your activity in connection with our Services and hold certain information. This may include information such as gameplay data, progression and metrics, in-Game purchases, your computer's Internet Protocol address (e.g. IP address) or operating system, browser type or version, the domain name of the Internet service provider you are using, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, the content viewed on those pages, the advertisements you have been shown and/or click, unique Device Identifiers and other diagnostic data.

Cookies are files with a small amount of data which are sent to your browser from a website and stored on your Device. Tracking technologies also used may be log files, beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies that may be present on our Website(s) as well as their uses:

• Session Cookies. To operate our Service.
• Preference Cookies. To remember your preferences and various settings.
• Security Cookies. For security purposes.

Use of Data

We use your Personal Data to provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes to:

• Provide and maintain our Services;
• Notify you about updates or changes to our Services, this Privacy Policy or any applicable Terms of Service;
• Facilitate in-app purchases;
• Store in-Game progress;
• Allow you to participate in interactive features of our Services when you choose to do so and to the extent applicable (such as in-Game leaderboards);
• Provide customer support; and
• Prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities.

We also use your Personal Data to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes to:

• Track user retention and aggregated gameplay information, as well as gather analysis or other valuable information, to improve overall User experience, gameplay and delivery with regard to our Games and Services;
• Monitor the usage of our Services;
• Deliver and target non-behavioral or non-personalized advertising;
• Detect, prevent and address technical issues; and
• Enforce any Terms of Service with respect to our Games and Services, to the extent applicable.

With your consent, we may use your personal information to:

• Deliver and target behavioral or personalized advertising and provide you with general information about other goods or services, unless you have opted not to receive such information;
• Provide you with marketing from third parties;
• Provide you with updates concerning our Games or future titles; and
• Contact you in connection with prior customer support or Services you have experienced.

You have the right to withdraw your consent at any time.

Retention of Data

All data we collect is stored on our third party Service Provider Firebase. For more information about their security policies, please review Firebase’s privacy policy at: https://firebase.google.com/support/privacy.

WayForward will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

WayForward will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally or contractually obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

WayForward will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information. The transfer of such data is typically for the purpose of fulfilling our contract with you, as specified above. Therefore, any request to delete or modify such Personal Data may result in the termination or interruption of our Services with respect to your usage of such Services.

Disclosure Of Data

Disclosure for Law Enforcement

Under certain circumstances, WayForward may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

WayForward may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation;
• Protect and defend the rights or property of WayForward;
• Prevent or investigate possible wrongdoing in connection with the Services;
• Protect the personal safety of Users of the Services or the public; or
• Protect against legal liability.

Change of Control

If we are subject to a merger or acquisition with/by another company, we may transfer all of your information, including Personal Data, to the successor organization in such transition. If we intend to handle your Personal Data for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your Personal Data for the new purposes.

Security Of Data

We protect your Personal Data using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use may include firewalls and data encryption, access controls, and information access authorization controls. The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals

California Do Not Track Disclosure
In September 2013, California enacted amendments to the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) which require operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the websites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and websites has not yet been widely adopted. Currently, we support, and honor DNT signals that we may receive. For more information about Do Not Track, please visit: www.allaboutdnt.org.

Your Rights

WayForward aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You may update, correct, or provide additional information to your Personal Data by resubmitting your information or contacting us directly. If you are correcting information provided to a third party (such as those identified in the “Service Providers” section below) please correct your information via the methods and direction provided by the third party.

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us via any of the contact options provided at the end of this Privacy Policy. Please note that we may ask you to verify your identity before responding to such requests.

You have the right to:

• Know what personal information we maintain about you;
• Receive a copy of your personal information in a structured, commonly used and machine-readable or commonly used electronic format on request;
• Update and modify personal information which may be incorrect or incomplete;
• Object to our processing of your personal information when collection is based on a legitimate interest; and
• Delete or restrict how we use your personal information, but this right is determined by applicable law and may impact your access to some of our Services.

How to Control Your Information

Under the EU General Data Protection Regulation, individuals residing in the EU and other territories that have adopted GDPR compliance or comparable regulation have a right to:

• Access their User data;
• Correct the data they have provided to us;
• Have information provided to them in a portable format;
• Request the deletion of the data we have collected;
• Restrict processing; and
• Object to processing or the legal basis on which we rely to process their data.

Please note that we may ask you to verify your identity before responding to such requests.

You may send an e-mail to suppport@wayforward.com with your request to exercise any of the rights identified above. Place the reason for your request (e.g. “Delete my Data” or “Correct my Data”) in the subject line and include your first name, last name, and e-mail address in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes.

We are unable to delete data controlled solely by third parties; for example, if you purchase one of our Games through the Digital Storefronts, we won’t be able to delete the data collected by the applicable Digital Storefront in connection with your purchase or your Digital Storefront account. Similarly, if you access any our of Services through third party social media or service platforms, such as Facebook, or if you are routed to a third party Service Provider’s website through our Services, you will need to make any deletion requests to those respective third parties separately.

Opt Out Options

Opting out of Promotional Communications

You can choose to opt out of receiving promotional e-mails and product updates from WayForward by clicking on the “unsubscribe” link where applicable. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, usually within five (5) business days depending on the applicable platform.

Opt Out Limitations

Please note that if you opt-out of our promotional communications or other forms of communication, we may still e-mail or communicate with you from time to time if we need to provide you with information and updates concerning this Privacy Policy or any applicable Terms of Service, respond to any customer service or technical support inquiry, or for other legitimate non-marketing reasons.

Individuals Located in Brazil

The LGPD grants you certain rights about the processing of your personal information.  In addition to any applicable rights mentioned above, eligible residents of Brazil also have the right: (i) to the anonymization, blocking, or elimination of your personal information, if you believe we are processing your personal information in an unnecessary, exceeding or non-compliant manner with the LGPD; (ii) to request the portability of your personal information; (iii) to request information about the entities with which we have shared your personal information; and (iv) to request information about the possibility and consequences of denying consent.  While our processing of personal information generally does not include automated decision-making, you are also entitled to a review of our decisions that are made solely based on automated processing of personal information that affect your interests.  Notwithstanding any other references to the contrary within this Privacy Policy, in accordance with the LGPD, we will respond to your request within fifteen (15) days after receipt and we will provide any requested information free of charge to you.  You may also file a complaint with the National Data Protection Authority in Brazil, the Autoridade Nacional de Proteção de Dados (“ANPD”) for alleged violations of the LGPD, in addition to or alternatively to seeking judicial redress.

Service Providers

We may employ third party companies and individuals to monitor the use of our Services, facilitate our Services ("Service Providers"), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Services are used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We do not actively share Personal Data with third party advertisers unless you give us your consent. We may share (i) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (ii) anonymous information; and (iii) certain technical information to develop and deliver advertising in our Game(s).

With your consent, we may also allow advertisers to collect certain types of Personal Data in-Game and they may share it with us. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your User experience by ensuring that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and to undertake web, mobile or game analytics (i.e. to analyze traffic and other User activity to improve your experience).

We may disclose aggregated and anonymous information to describe the Services to prospective partners, advertisers, and other third parties, and for other lawful purposes. We may use aggregate, non-personally identifiable information for our own internal promotion or marketing purposes and we may share such aggregate non-personally identifiable information with others for marketing purposes.

Web Services, Payment Processing, Analytics and Advertising

Google Analytics

Google Analytics is an analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en_US

We may also make use of the following third-party Service Providers with links to their respective privacy policies as follows:

Links To Other Websites

Our Services may also contain advertisements or links from companies other than WayForward that may link to websites that are not operated by us. If you click on such third party links or advertisements, you will be directed to that third party's website.  We strongly advise you to review the Privacy Policy of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services. If you have any questions about how these other websites use your information, you should review their policies and contact them directly. In certain instances, you may need to opt in or opt out of advertising directly through our partners. Please refer to the table provided above for a list of our third party Service Providers.

Children's Privacy

Our Games are family friendly and we encourage parents and guardians to use our Games with their children ages 9 and above. However, we take children’s privacy very seriously, and we do not directly or knowingly collect any Personal Data from Users deemed to be children under their respective national laws through our Website, nor do we collect any Personal Data from Users under the age of 16 through our Games. We strive to comply with the Children’s Online Privacy Protection Act of 1998, the US law that protects the privacy and information of children. We strongly encourage parents and guardians to learn more about this important regulation. For more information, you can visit: https://epic.org/privacy/kids/#introduction.

If you are underage and using our Services, please have a parent or guardian nearby to provide any Personal Data we may request, including your Facebook, Google or Apple log in information to log into our Game. Users must verify that they are at least 16 years of age before providing this information.

If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

That being said, we understand that children may use our Services without directly providing personal information. We may allow third parties to place and read their own cookies, web beacons, and similar technologies to collect information through our Services, including helping with analytics. You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser (typically in the "help" section). If you choose to refuse, disable, or delete these technologies, some of the functionality of our Services may no longer be available to you or your child.

We may also aggregate your or your child's information with information about other Users in a way that does not directly identify you or your child.

We also may share aggregated or de-identified information with third parties, including to help us develop, analyze and improve content and Services. It is possible that the third parties may use this aggregated or de-identified information to develop their own products and service offerings.

Information Regarding Parental Consent, Access, and Deletion

You have control over your Personal Data as stated above, under the section called “Your Rights”. This information applies to Personal Data adults, parents or guardians may provide when accessing the Services. However, we do not collect any additional Personal Data from children or Users under 16 in connection with our Services. As we do not collect Personal Data from children, we are not able to identify your child and therefore are not able to fulfill modification, access, correction, deletion, or portability requests set forth above for your child’s Personal information.

If WayForward ever does in the future collect, use or disclose Personal Data from your child, we will endeavor to obtain a parent or legal guardian's consent before doing so or otherwise comply with law. We will not keep this Personal Data for longer than necessary. Parents or legal guardians may also contact us to ask if we have collected their child's personal account information, to review that information, if any, and request that we stop collecting this information and have it deleted. Such requests are subject to us verifying to our satisfaction that the requester is in fact the child's parent or legal guardian.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via e-mail and/or a prominent notice on our Services, prior to the change becoming effective and update the "Effective Date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• Reach our Data Protection Officer by e-mail: voldi@wayforward.com
• By visiting this page on our Website: www.wayforward.com
• By phone number: 1+ (661) 420-4757
• Or by mail at:        WayForward Technologies, Inc.

Attn:  Data Protection Officer

28738 The Old Road

Valencia, CA 91355

California Consumer Data Rights

WayForward Technologies, Inc. complies with the California Consumer Privacy Act of 2018 (CCPA), effective January 1, 2020. This landmark piece of legislation secures new privacy rights for California consumers.

Categories of Data We Collect and Their Uses

In addition to the details provided in our Privacy Policy, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or Device (“Personal Information”). In particular, we have collected the following categories of Personal Information from Users within the last twelve (12) months:

Personal Information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from our Users. For example, from customers who sign up for our Services, engage us for customer support or provide customer feedback.
• Indirectly from our Users. For example, through information we collect from our Users in the course of providing customer support to them.
• Directly and indirectly from activity on our Websites or through the Services. For example, from APIs and cookies (described above) embedded in our Websites, as applicable, and other information related to improving our products.
• From third parties that interact with us in connection with the Services we perform.

All such Personal Information is used as otherwise described above in our Privacy Policy. 

Sharing Personal Information

We may disclose your Personal Information to our affiliates, Service Providers, or third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you for business purposes.  When we disclose Personal Information for a business purpose, we enter 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.

Your Rights and Choices

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you;
• The categories of sources for the Personal Information we collected about you;
• Our business or commercial purpose for collecting that Personal Information;
• The categories of third parties with whom we share that Personal Information; and
• The specific pieces of Personal Information we collected about you (also called a “data portability” request).

If we sell your Personal Information for a business purpose, we will also disclose to you:

• The Personal Information that each category of recipient purchased; and
• Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

• Complete any transaction for which we collected the Personal Information, provide a product 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;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products, including our Website(s) and Games, and to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at (661) 420-4757 
• Sending us a letter at:        WayForward Technologies, Inc.

Attn:  Data Protection Officer

28738 The Old Road

Valencia, CA 91355

Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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