Last revised: August 31, 2023

Privacy Policy

Overview

In this Privacy Policy, the words “we,” “us,” “our,” means Car Capital Servicing, LC , and its respective affiliates, successors, assigns, representatives, and service providers (together “Car Capital”). The words “you” and “your” mean any visitor or user of a website (each, a “Site” or the “Sites”) we administer and make available for your online interactions with us. The Sites covered by this Privacy Policy include carcapital.com and other websites we administer and expressly provide for your use in interacting with Car Capital.

We maintain this Site and provide services through it for your information and communication purposes, as well as for purposes associated with matching you with a dealer who can provide you financing for a vehicle (the “Service” or “Services”). Our Site and Services are intended for use only by United States residents, while located in the United States. If you are not a United States resident, or are located in a country other than the United States, you may not use our Site and Services.

We respect your privacy and are committed to protecting it through compliance with this Privacy Policy. This Privacy Policy describes the types of information we may collect from and about you when you visit our Site. This Privacy Policy also describes our practices for collecting, using, protecting, and disclosing that information.

This Privacy Policy applies to:

·       Information we collect when you visit or use this Site;

·       Information we collect when you submit and exchange electronic messages with us through the Site;

·       Information we collect when you interact with our advertising and applications on third-party websites and services, if those applications and advertising include links to this Privacy Policy.

This Privacy Policy does not apply to information collected by any third party.

Additional privacy rights and notices will apply if you are a resident of California or other specific states. See the section below called State Privacy Rights for more information about your rights under California law and other specific states.

A different privacy policy will apply if you request or receive a financial product or service from us by using this Site or otherwise. See our Financial Privacy Policy for more information about how we collect and disclose nonpublic personal information about consumers who request or receive a financial product or service from us.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Site. By accessing or using this Site, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see the section below called Changes to this Privacy Policy), so please check this Privacy Policy periodically for updates. If we change the Privacy Policy on this Site and you continue to use it, you agree that your continued use of the Site will mean that you have accepted all changes in the updated Privacy Policy.

If you breach or violate the rules, restrictions, limitations, terms and/or conditions that apply to the Site and the Services, whether listed in the Privacy Policy, posted at any point on the Site or in connection with the Services, or otherwise communicated to you, Car Capital may terminate, discontinue, suspend and/or restrict your ability to access, visit, and/or use the Site and its Services, with or without notice. Car Capital may further restrict or refuse to provide you with any future access and/or use of the Service. Finally, Car Capital reserves the right to take any technical, legal and/or other actions that it deems necessary and/or appropriate, with or without notice.

SECTION 1

Age of Site Users and Visitors

By using this Site, you represent that you are at least the age of majority in your state of residence (or in the District of Columbia, if you reside there). Our Site and Services are not intended for use by children, especially those under age 18. No one under the age of 18 is allowed to use the Site and its Services. We do not knowingly collect personal information from children under the age of 18. If we obtain knowledge that we have personally identifiable information about a child under 18 in retrievable form in our files, we will delete that information from our existing files[JC1] . If you believe we might have information from or about a child under 18, please notify us as soon as possible by using any of the options in the section below called Contact Information To Ask Questions Or Exercise Rights.

SECTION 2

Information We Collect About You and How We Collect It

We collect several types of information from and about visitors and users of our Site, including:

·       Information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, Social Security number, and driver’s license number (“personal information”); and

·       Information about your internet connection, the equipment and devices you use to access our Site, the dates and times you use the Site, and other Site usage details.

We collect this information:

·       Directly from you when you provide it to us through the Site;

·       Automatically as you navigate through the Site, including Site usage details, Internet Protocol (IP) addresses, and information collected through cookies and other tracking technologies; and

·       From third parties, for example, our business partners and service providers.

SECTION 3

Information You Provide To Us

The information we collect on or through our Site includes:

·       Personal information you choose to provide to us when filling in forms on the Site to request or obtain our Services or otherwise interact with us, which may include your name, postal address, email address, date of birth, phone number, and income information;

·       Information we may request from you if you enter a contest or promotion we sponsor or when you report a problem with our Site;

·       Records and copies of your correspondence (including email addresses), if you contact us; and

·       Details of transactions and search queries you may carry out through the Site.

You also may provide information to be published or displayed ("posted") on public areas of the Site or to be transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

SECTION 4

Information We Collect Through Automatic Data Collection Technologies

As you use and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, such as details of your Site visits (including traffic data, location data, logs, and other communication data and the resources you access and use on the Site), and information about your device and Internet connection (including your IP address, operating system, and browser type).

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See the sections below called Cookies and Other Tracking Technologies and Choices About How We Use and Disclose Your Information for information on how you can opt out of behavioral tracking and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties.

We use commonly use information-gathering tools, such as cookies (discussed in the Cookies and Other Tracking Technologies section), to collect information as users navigate our Site and request or obtain our Services.

·       Usage Information: We collect certain information automatically through your use of the Site, such as which of our web pages you access, the frequency of access, and what you click on while on our Site.

·       Location Information: We may collect information about your actual location which may be determined from: IP address, GPS, and other sensors that may reveal information on nearby devices, Wi-Fi access points, and cell towers.

·       Device Information: We may collect information about the device you are using such as: hardware model, operating system, application version number, browser, and IP addresses.

·       Mobile Device Information: In addition to the Device Information listed above, when you access our Site or Services via a browser on your mobile device, we may also collect mobile network information including phone number, the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.

SECTION 5

Cookies and Other Tracking Technologies

·       Session Cookies: A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use session cookies to make it easier for you to navigate our Site.

·       Persistent Cookies: We use persistent cookies that remain on your hard drive for an extended period of time. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our Site. You can remove persistent cookies by following directions provided in your Internet browser’s instructions.

·       Tracking Pixels (Web Beacons):  We may use a software technology called tracking pixels (also known as web beacons or clear gifs) that help us better manage content on our Site by informing us what content is most effective. Tracking pixels are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.

·       Other Tracking Technologies:  We may also use other website or mobile tracking technologies, such as device fingerprinting, to identify you and keep track of your preferences, prevent fraudulent activity or improve Site security, assess the performance of the Site, and deliver content to you based on your interests on our Site and third-party sites.

Some content or applications on the Site may be provided by third parties, including analytics companies and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personally identifiable information or they may collect information, including personally identifiable information, about your online activities over time and across different websites and other online services.

We may, from time to time, contract with third-party service providers to advertise on our behalf, by using the Internet, email, and direct mail, if we think customers may be interested in our products or services. To advertise on our behalf, these third parties may collect information about visitors to our Site by using JavaScript software code and “cookies.” Our service providers may then connect the information they collect from our Site using “cookies” to other sources of information, which may include your name and mailing address, for the purpose of sending you direct mail promotions.

By using this Site, you consent to these activities, including information collection by our service providers.

If you do not wish for cookies to be placed on your computer, most web browsers permit you to prevent that from taking place. Additionally, information about opting out of cookie-based advertising can be found via the following links:

·       http://optout.networkadvertising.org/#!/

·       https://www.neustar.biz/privacy/opt-out

However, please keep in mind that cookies and similar technologies are an important part of how the Site works. Removing, rejecting, or limiting the use of cookies or other similar technologies may affect the availability and functionality of the Site.

We do not currently process or comply with any browser’s “do not track” signal at this time, due to the limits of current technologies, standards and solutions.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising.

SECTION 6

Third-Party Services

In general, the third-party service providers we use will collect, use and disclose your information only to the extent necessary to allow them to perform services for us and on our behalf. However, certain third-party service providers have their own privacy policies related to the information we are required to provide to them for your credit-related purposes. For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers. Additionally, the use of third-party cookies is subject to the privacy policies of these third parties and Car Capital has no liability relating to the use of the third-party cookies. If you do not want these services, you may be able to opt out by visiting http://www.aboutads.info and/or www.networkadvertising.org.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms of Use.

When you click on links on our website, they may direct you away from our Site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

SECTION 7

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

·       To present our Site, its contents and the Services to you;

·       To provide you with information, products, or Services that you request from us or to contact you about our Services that may be of interest to you;

·       To fulfill any other purpose for which you provide any personal information;

·       To provide you with notices and information about your accounts with us or to carry out our duties and enforce our rights arising from any contracts between you and us;

·       To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses

·       To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site and via email or text message (with your consent, where required by law);

·       For testing, research, analysis, and product development, including to develop and improve our Site, products, and services;

·       To notify you about changes to our Site and any products or services we offer or provide through it;

·       To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business;

·       In any other way we may describe when you provide the information; and

·       For any other purpose with your consent.

SECTION 8

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

·       To our affiliates;

·       To contractors, service providers, and other third parties we use to support our business;

·       To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users and consumers are among the assets transferred;

·       To fulfill the purpose for which you provide any personal information;

·       For any other purpose we disclose when you provide the information; and

·       With your consent.

We may also disclose your personal information:

·       To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

·       To enforce or apply the terms of this Privacy Policy, our Terms of Use, and other agreements between you and us, including for billing and collection purposes; and

·       If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Car Capital, our service providers, our customers, other visitors and users of the Site, and others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction.

Please review our Financial Privacy Policy for information about how we disclose nonpublic personal information about consumers who request or receive a financial product or service from us.

SECTION 9

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

·       Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Site may then be inaccessible or not function properly.

·       Promotional Offers from Us. If we send you a promotional email, you may use the Unsubscribe link and ask to be omitted from future email distributions. If we send you a promotional text message, you may send a text reply that says “Stop” or “Cancel” and instruct us not to send these types of promotional text messages. To opt-out of receiving direct mail from us, you may:

o   send an email to us at complaints@carcapitalcorp.com ;  

o   call us at 844.350.4455; or

o   send a written request to 1301 Municipal Way, Suite 100, Grapevine, TX 76051.[JC2] 

We will honor those requests, but it may take 60 days for such mailings to end.

SECTION 10

Security

We take reasonable precautions to secure your personal information and protect it from being inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide us with your personal information, the information is encrypted in transit using secure socket layer / transport layer technology (SSL/TLS) and encrypted with AES-256 encryption when stored in our databases.[JC3] 

Your information may be transferred to, and maintained on, servers and databases located outside of your state or outside of the United States, where the privacy laws may not be as protective as your jurisdiction. We may transfer your information to and from any governmental jurisdiction and process it in the United States or elsewhere.

No system of electronic security is impenetrable. We cannot guarantee the security of the information that you send to us or the security of our servers, networks, or databases. By using the Site and our Services, you agree to assume all risk in connection with the information sent to us or collected by us when you access, visit, and/or use the Site and our Services. This includes, without limitation, any personally identifiable information that you provide to us. We are not responsible for any loss of such information or the consequences resulting from any loss of such information.

In the event you choose to store information, such as your personally identifiable information, we are not responsible for any loss of such information or the consequences resulting from any loss of such information. If you lose a computer, mobile or other device or have it stolen, that contains your personally identifiable information or other information, it is up to you to take all the steps necessary to protect yourself.

In the unlikely event that we believe the security of your information in our possession or control may have been compromised, we may seek to notify you if notification is required under the law of your state. If notification is appropriate, we may notify you via your computer, mobile or other device.

SECTION 11

Assistance to Victims of Identity Theft

If you suspect that someone has had unauthorized access to the information you provided to Car Capital, or any accounts with Car Capital, or access to your personally identifiable information, you should report this crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free: 1-877-IDTheft (1-877-438-4338). Or, to enter information about your complaint into a secure FTC online database, visit www.consumer.gov/idtheft. The site also provides links to consumer education materials.

SECTION 12

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Changes, additions, updates, and modifications will take effect immediately upon their posting on the Site. You are responsible for periodically visiting the Site and this Privacy Policy to check for any changes. The date of the most recent revision will appear at the beginning of the Privacy Policy.

SECTION 13

Contact Information To Ask Questions Or Exercise Rights

If you would like to know, access, correct, amend, delete or request any personal information we have about you, or register a complaint, or appeal our decisions related to your requests, or you simply have questions or want more information about this Privacy Policy, you may contact us at complaints@carcapitalcorp.com or by mail at:

1301 Municipal Way

Suite 100

Grapevine, TX 76051

If there are specific rights you want to invoke or exercise under any applicable law, please include these details in your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm that the personal information relates to you. Please do not include sensitive personal information, such as your date of birth or Social Security number, when you initially ask questions or make requests of us, and review our Security section above for more details. We will use personal information provided in the request only to verify the requestor’s identity or authority to make it.

Section 14

State Privacy Rights

Residents of Colorado, Connecticut, Virginia, and Utah

If you are a resident of Colorado, Connecticut, Virginia, or Utah, you have rights to:

•   Confirm whether we process your personal information.

•   Access and delete certain personal information.

•   Data portability.

•   Opt-out of personal data processing for targeted advertising and sales.

If you are a resident of Colorado, Connecticut, or Virginia, you have the additional rights to:

•   Correct inaccuracies in your personal information, taking into account the information’s nature and processing purpose.

•   Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Residents of Colorado, Connecticut, Virginia, or Utah who wish to exercise any of the above rights must submit a request via mail to 1301 Municipal Way, Suite 100, Grapevine, TX 76051. To appeal a decision regarding a consumer rights request you may mail us a request to appeal at 1301 Municipal Way, Suite 100, Grapevine, TX 76051.

Your California Privacy Rights

Effective Date: August 31, 2023

Last Reviewed: August 30, 2023

This Privacy Policy for California Residents (“California Privacy Policy”) supplements the information contained in our general Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined by the CCPA have the same meaning when used in this California Privacy Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”).

Personal information does not include:

·       Publicly available information from government records;

·       Deidentified or aggregated consumer information; and

·       Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A name, postal address, Internet Protocol address, and email address.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, postal address, Internet Protocol address, and email address. Some personal information included in this category may overlap with other categories.

Yes

C. Commercial information.

Records of personal property, products or services purchased, obtained, or considered with us.

Yes

D. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Yes

E. Geolocation data.

Physical location or movements.

Yes

F. Professional or employment-related information.

Current or past job history or performance evaluations.

Yes

We obtain the categories of personal information listed above from the following categories of sources:

·       Directly from you. For example, from forms you complete or products and services you purchase.

·       Indirectly from you. For example, from observing your actions on our Site.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

·       To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new orders or process transactions.

·       To provide, support, personalize, and develop our Site, products, and services.

·       To create, maintain, customize, and secure your account with us.

·       To process your requests, purchases, transactions, and payments and prevent transactional fraud.

·       To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

·       To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site and via email or text message (with your consent, where required by law).

·       To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.

·       For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.

·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·       As described to you when collecting your personal information or as otherwise set forth in the CCPA.

·       To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users and consumers are among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We make these business purpose disclosures only under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category

Business Purpose Disclosures to Third-Party Recipients

A: Identifiers.

Yes, to our service providers.

B: California Customer Records personal information categories.

Yes, to our service providers.

C. Protected classification characteristics under California or federal law.

Yes, to our service providers.

D: Internet or other similar network activity.

Yes, to our service providers. 

E. Geolocation data.

Yes, to our service providers. 

F. Professional or employment-related information.

Yes, to our service providers. 

G. Commercial information

Yes, to our service providers. 

We do not sell personal information and have not sold personal information to third parties in the preceding twelve (12) months.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

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 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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;

·       If we disclosed your personal information for a business purpose, a list that describes the disclosures we made for a business purpose, identifying the personal information categories that each category of recipient obtained; and

·       The specific pieces of personal information we collected about you (also called a data portability request).[JC4] 

Right to Delete

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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

·       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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 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 et. seq.).

·       Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

·       Comply with a legal obligation.

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

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.[JC5] 

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Emailing us at:  complaints@carcapitalcorp.com ; or

Writing us at:  1301 Municipal Way, Suite 100, Grapevine, TX 76051

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

·       Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

·       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.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us using the contact information included in the section above called Exercising Your Rights to Know or Delete.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. 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.

·       Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 [JC1]Need to be able to do this.

 [JC2]All of this needs to be functional

 [JC3]Is this true?

 [JC4]We have to be able to do this

 [JC5]Need to be able to do