Steelers Privacy Policy

Steelers Privacy Policy

LAST UPDATED: May 1, 2020

Contents

  1. Personal Information We Collect through Our Services
  2. Personal Information We Collect Using Cookies and Tracking Technologies
  3. Personal Information We Collect from Other Sources
  4. Our Mobile App
  5. How We Use Personal Information
  6. Why and With Whom We Share Personal Information
  7. How You Can Restrict Tracking Technologies and Personalized Advertising
  8. How You Can Opt-Out of Marketing Communications
  9. Social Media Activities and Links to Other Websites
  10. Protection of Personal Information
  11. How Long We Retain Personal Information
  12. Children's Online Privacy
  13. International Users
  14. Changes to this Privacy Policy
  15. How to Access and Manage Your Information
  16. How You Can Contact Us
  17. Notices and Rights for California Residents
  18. California Consumer Privacy Act
  19. Notice at Collection of Personal Information
  20. Notice of Right to Opt-Out of Sale of Personal Information
  21. Right to Know about Personal Information We Collect, Disclose, or Sell
  22. Right to Deletion of Personal Information
  23. Right to Designate an Authorized Agent
  24. Personal Information of California Minors
  25. How to Make a Verifiable California Consumer Request
  26. How We Will Respond to a California Consumer Request
  27. Protection from Discrimination for Exercising California Consumer Rights
  28. Financial Incentive Programs
  29. California "Shine the Light" Law

What this Privacy Policy Covers

The Pittsburgh Steelers (the "Steelers", "we", "our", or "us") have adopted this Privacy Policy to guide how we collect, use, and disclose personal information. This Privacy Policy applies to personal information we collect when our fans and visitors ("you" or "your") use our websites and mobile application, attend games or special events, shop, or communicate with us (individually and collectively referred to as our "Services"), and personal information we may obtain from other sources. By using our Services, you agree that you have read and understood the terms of this Privacy Policy.

The term "personal information" in this Privacy Policy refers to:

  • Information that identifies you directly, such as your name, street or email address, birth date, and payment card information;
  • Information that may be identified with you indirectly, such as your device IP address, mobile device ID, geolocation data, and data from cookies and other internet technologies; and 
  • Other information associated with you, such as your interests, job, personal characteristics, and preferences.

This Privacy Policy does not restrict in any way our use or sharing of information that has been aggregated in a way that no longer identifies you or can be linked to you.

If you provide personal information to us via social media platforms and other sites operated by third party providers, the third party's privacy policy will govern how the third party collects and uses your information.

Personal Information We Collect through Our Services

We collect personal information from you when you use our Services, including;

  • Visiting our website at: www.steelers.com, operated in cooperation with the National Football League ("NFL"); www.shop.steelers.com; and www.heinzfield.com (individually and collectively referred to as our "Websites");
  • Using The Steelers' Official mobile application ("Mobile App");
  • Attending our games, shopping at our retail locations, participating in special Steelers' events and activities, entering a contest or sweepstakes, and responding to our fan surveys and polls;
  • Communicating with us by posting online, email, social media, postal mail, telephone, text, and in-person;
  • Using other online, mobile, or in-person services that link to or post this Privacy Policy.

The categories and examples of the specific types of personal information we collect when you use our Services are described below.

Transactions and Billing: When you conduct a transaction with the Steelers, such as purchasing game or special events tickets, purchasing merchandise online or at one of our Steelers Pro Shop stores, or registering for an event or activity such as a training camp or Family Fest, we collect and use your name, postal address, telephone number, email address, credit or debit card information and other billing information needed to process your payment or invoice the charges and complete your transaction.

Mobile App: You can set up a fan profile on our Mobile App and log in to take advantage of certain services such as contests, games, and exclusive content. You will be asked to provide your name, email address, and a password. For some features, we may ask for additional information, such as your postal address, telephone number, or birth date, which you may provide at your option. You can edit your profile at any time.

Steelers Email Alerts: To receive free Steelers email alerts with team news, promotions, and merchandise offers, you can sign up on our Websites, Mobile App, at events, and other Steelers locations. On our email sign up page https://nfl.csharmony.epsilon.com/pc/clubs/steelers/Account/Register, you will be asked for your name, email address, city, state, and country. You may also choose to tell us your birth date, favorite player, and other information. You may cancel your free email subscription at any time by following the opt-out instructions provided at the bottom of any Steelers email message.

Games, Contests, Raffles, and Sweepstakes: We ask for your name, email address, telephone number, postal address and birth date when you register for Steelers-sponsored contests, games, raffles, sweepstakes, or similar offers (collectively, "Contests"). Your birth date confirms your eligibility to participate in the activity, and your contact information will be used to notify you if you are a potential winner. The rules of each Contest will provide details about how your personal information will be used and whether your personal information will be shared with the Contest sponsor.

Gamedays and Events: Using our Mobile App, we collect attendee information at Heinz Field on game days and special events such as Steelers Training Camps and family activities and retain this information in your fan profile. The NFL conducts post-game surveys of ticket holders who agree to provide their email address.

Ticket Holders: We collect names, mailing and email addresses, telephone numbers, and similar personal information about our Season Ticket Holders, Suite Holders, Club Seat Holders and those on our ticket waiting list through the Steelers ticket office, both digitally and on paper. This information is included in our fan profiles.

Information You Post Online: The Steelers may provide fans with ways to post publicly accessible comments, questions, and images on our Websites. You may be asked to submit your name, email address, and city, state and country before submitting a post. You should be aware that any personal information you choose to post in this way is public and may be read, collected and used by others and may remain on the public forum indefinitely. We have no responsibility to publish or edit any of your submissions; however we will make a reasonable effort to remove a posting upon your request. (Please see, "How to Contact Us.") We encourage you to exercise caution before disclosing personal information or images in online posts. For more information, see our Terms of Use.

Fan Polls and Surveys: Participation in our fan polls and surveys is voluntary. If you choose to participate, we may retain information from your responses in your fan profile; but only the aggregate poll results are publicized.

Information We Collect Using Cookies and Tracking Technologies

When you use our Websites and Mobile App, data about your usage of these Services is automatically collected by the Steelers, the NFL (on www.steelers.com), and our authorized service providers by placing internet and mobile analytics tools such as cookies, web beacons, tags, and similar tools on your computer or smartphone browser. Some of these data are used only during your current session; other data are logged, stored and may be combined with other information about you. The types of data collected using these technologies may include: 

  • Your Internet Protocol (IP) address, which is the number automatically assigned to your computer when you access the Internet and may indicate your general geographic location;
  • Data needed to recognize your Steelers' fan account user name and password and connect you to your profile;
  • Geolocation data collected when you visit our Websites or use the Mobile App;
  • Other unique identifiers, including mobile device identification numbers;
  • Your browser type and operating system;
  • Sites you visited before and after visiting the Services;
  • Pages you view and links you click on within the Services; 
  • Activity log data; and
  • Information about your interactions with email messages, such as the links clicked; on and whether messages were received, opened, or forwarded.

The Steelers, the NFL, and our authorized business partners use the information derived from these technologies for data analytics and personalized advertising purposes. For information about restricting this form of data collection, see "How You Can Restrict Tracking Technologies and Personalized Advertising."

Information We Collect from Other Sources

We may obtain personal information about you from third party sources and may combine data from these sources with other information we have about you to update, expand and analyze our records, identify new customers, and provide products and services that are tailored to your interests. These sources include:

  • The NFL, other NFL member clubs, Contest and event sponsors, and other marketing partners that share information with us;
  • Public and commercially available databases, including marketing research and data analytics resources from which we may receive demographic information (e.g., age, sex, household income, job industry and job title) from these sources; and
  • Third-Party Social Media Service that you use to sign into your Steelers account or to send us messages and content may also transmit information to us from your social media accounts, and you are authorizing us to collect, store, and use the information we receive from Third-Party Social Media Services in accordance with this Privacy Policy.

Our Mobile App

When you download and use The Steelers' Official Mobile App, we use mobile analytics software provided by third parties to collect information about the type of device you use, its operating system, your geolocation, and browsing and usage data such as how and how often you use the Mobile App and from where you downloaded the Mobile App. Certain features of the Mobile App require that you set up a fan profile, with a username and password, to use the feature. You must be at least 16 years of age to create a fan profile and participate in select Mobile App features. When you log in to your Mobile App profile, we will be able to identify you. The Mobile App services provider will also have access to your specific geolocation, device identification, and Mobile App usage information.

We use location-based information to verify your location and send location-based content to you. We may share your geolocation data with third party ad servers that send advertisements for merchants (such as restaurants) in your area. We also may work with third party providers who use technologies such as geofencing and beacons to identify fans attending a game, and contact fans via an in-app feature in order to serve unique content to enhance your gameday or event experience. These service providers are permitted to use your information only for the purpose of acting on our behalf. You can opt-out of location-based services at any time by editing your location settings on your device or by emailing us using the form provided at https://www.steelers.com/legal/contact-us/. For additional information, see "How You Can Restrict Tracking Technologies and Personalized Advertising."

How We Use Personal Information

We may use your personal information to:

  • Provide the Services you request including: confirming and fulfilling an order you placed; completing a transaction; administering your Services accounts and memberships; registering you for an event or activity; providing customer service to you; responding to your questions, suggestions and complaints; and enabling your participation in Contests and community dialogue features;
  • Contact you about ticketing, purchases, registrations, membership matters, or a prize you have won;
  • Maintain and update the fan profiles, databases and records we keep about our fans and users of our Services including: demographic data; interests and preferences; purchases; participation in our events and activities; usage of online and Mobile App features; and customer satisfaction;
  • Send, with your permission, emails and mobile device push notifications to you about activities and events operated by or on behalf of the Steelers, the NFL, and our authorized marketing partners unless you direct us to stop sending these communications to you;
  • Partner with the NFL and third party online advertising providers, such as GoogleAds, to display personalized advertising on our Services and manage our advertising on other publishers' websites based on the browsing activities and interests you have shown through your usage of our Websites, Mobile App, and other online and mobile platforms;
  • Enhance our customer relations, expand our fan base and markets, continue to improve our Services, and develop new Services by using data analytics tools derived from cookies and other technologies to analyze the usage, demographics, and purchasing patterns of our fans and users, and assess the effectiveness of promotions and marketing programs; and
  • Monitor the security of our Services including compliance with the specific terms and conditions of use that apply to our Services.

For information about how to restrict the use of your information for personalized advertising, see "How You Can Restrict Tracking Technologies and Personalized Advertising." For information about how to opt-out of marketing and promotional emails, see "How You Can Opt-Out of Marketing Communications."

Why and with Whom We Share Personal Information

  • The Pittsburgh Steelers Organization. We may share your personal information with our affiliated companies for the purposes listed in this Privacy Policy.
  • The NFL. The NFL hosts www.steelers.com and the other NFL member clubs' websites. Both the NFL and the Steelers collect internet usage data automatically on www.steelers.com. However, without your permission, we do not share your name, email address, or other directly identifying personal information you submit to us with the NFL.
  • Service Providers: We employ third parties to perform administrative and technology functions on our behalf. Examples include: fulfilling merchandise orders; hosting the Mobile App; processing registrations for camps and other events; providing customer service; managing account usernames and passwords; sending promotional emails and other marketing services; and providing information technology support, hosting and storage. These service providers may have access to personal information in order to perform their functions, but they are not permitted to use personal information for their own commercial purposes.
  • Payment Processors. We use third-party payment service to process payments for tickets, events, and other Services. Your personal information as needed to process the transaction will be collected by the payment processor—not by us—and will be subject to the processor's privacy policy, rather than this Privacy Policy. Payment processors are not permitted to use personal information for their own commercial purposes.
  • Third-Party Platforms: We use third-party platforms to deliver some of the features of our Services, including ticket sales and registration for training camps and youth summer camps. We also use Third-Party Social Media Services to communicate with fans who choose to communicate with us via those platforms. If you select these services or features, you will be transferred to a website owned and controlled by the third-party service even if that website displays the Steelers logos or appears to be a page on a Steelers Website. Any personal information you submit on these websites will be visible to the third-party service and will be covered by the third-party's privacy practices. The Steelers also receive the information you submit on these platforms, except for payment information, and upon receiving your information we will process as described in this Privacy Policy and our Terms of Use.
  • Data Analytics Services: When you use our online or Mobile App Services, data about you and your activities are collected by Google Analytics and other third-party data analytics services using cookies and similar technologies. Both the Steelers and the NFL (for www.steelers.com) receive aggregated Website usage and visitor demographics reports. The data analytics providers also use the aggregated data they collect on our Websites for their own business purposes. You can learn about how Google collects and processes data at https://policies.google.com/technologies/partner-sites. You can learn about the controls Google offers to manage the collection and use of your information at https://policies.google.com/privacy.
  • Third-Party Ad Services: We use third parties to serve advertisements on our Services and on selected websites and mobile applications operated by others. These third parties may set their own cookies or similar web technologies to collect information about users' online and mobile device activities over time and across different websites, which they use to serve personalized advertisements.
  • Marketing Partners and Contest Sponsors: We may send direct marketing promotional materials to you on behalf of our third-party marketing partners, such as advertisers and sponsors of our Contests. The terms of Contest will disclose whether personal information, such as name, email and/or postal address, will be shared with these third-parties.
  • Third-party Advertising Research. The Services may feature Nielsen proprietary measurement software, which will allow users to contribute to market research, such as Nielsen TV Ratings. Nielsen believes that you should have a choice about whether to contribute to our research and insights. To opt out of Nielsen measurement, you can activate the "Limit Ad Tracking" (for iOS devices) or "Opt out of Ads Personalization" (for Android devices) option in your devices settings. For web, please visit: http://www.nielsen.com/digitalprivacy to learn more about the Nielsen digital measurement products and your choices in regard to them.
  • Aggregated Information: We may share aggregated information, such as demographics and online/Mobile App usage statistics, with advertisers, sponsors, and other organizations. When we share this type of information, we use commercially reasonable measures to remove information that identifies you individually.
  • Legal Process and Security: We may disclose your personal information to third parties as we believe to be reasonable to enforce our Terms of Use and other agreements, respond to and resolve claims or complaints, prevent and detect fraud and for other risk management purposes, and to comply with laws, and to respond to law enforcement or legal process or a request for cooperation by a government entity.
  • Business Transactions: The Steelers reserve the right to disclose or transfer your personal information in connection with a business transaction such as a financing, reorganization, merger, or substantial sale of a business.

How You Can Restrict Tracking Technologies and Personalized Advertising

You can control how cookies and other internet and mobile application technologies are used to track and log data about your internet and Mobile App usage (including location-based information) and to deliver personalized advertisements to you on our Websites and third-party websites. These controls include:

If you restrict the use of cookies and other technologies, some of our Services cannot be fully utilized. If you choose to restrict personalized advertising, you will still receive ads, but they will not be personalized based on your browsing activity.

Do Not Track (DNT) is an optional browser setting that is used by some advertisers and other third-parties. Our Websites do not respond to DNT signals.

How You Can Opt-Out of Marketing Communications

The Steelers will send promotional emails, newsletters, push notifications and similar marketing communications to you if you sign up for our email or push notification alerts and give us permission to send those communications to you. You can choose to stop receiving email messages from the Steelers by following the "unsubscribe" instructions located near the bottom of each email we send. You can choose to stop receiving push notifications by turning off push notification at the device level. Please note that opt-out requests may take up to ten (10) days to be effective.

You may also receive promotional and marketing emails or push notifications from the NFL and other marketing partners if you specifically sign up to receive them. You can stop receiving these communications by following the unsubscribe instructions provided by the sender.

If you unsubscribe from receiving promotional emails or push notifications, you will still receive transaction-related and other communications that are not promotional or marketing in nature. For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited promotional email messages or push notifications.

Social Media Activities and Links to Other Websites

Fans may use social media platforms and services, such as Twitter and Facebook ("Third-Party Social Media Services") to post comments, questions, and images about the Steelers. This Privacy Policy does not apply to (1) information you share when you communicate with us using a Third-Party Social Media Services account, or (2) information you provide to third parties whose websites or applications you choose to access from links and advertisements posted on our Services. The Steelers are not responsible for the personal information you choose to post on Third-Party Social Media Services or how others may use your information or images.

When you connect your Services account with a Third-Party Social Media Services account, you will share information with friends and other users who can access your Third-Party Social Media Service account and with your Third-Party Social Media Service provider. By connecting with your Third-Party Social Media Service account, you authorize us to facilitate the sharing of information with those who have access to information on your Third-Party Social Media Service account. Your use of information that you submit on the Third-Party Social Media Service platform will be governed by the Third-Party Social Media Service's privacy policy. Also, if you connect with any of the social media activities available through our Services, such as the Facebook Like button and a "retweet" on Twitter, the Third-Party Social Media Service platform controls these activities, not the Steelers. Likewise, if you click on a third party link or advertisement on our Websites or Mobile App, you will be transferred away from the Steelers' Website or Mobile App and onto the third party's location, and the third party's privacy policy will govern information you provide at that location.

The companies that control these third party internet sites, mobile applications, and services may collect your IP address and the information that your visit originated from our Services, and may set a cookie to enable their features to function and track your usage. The links we provide do not constitute an endorsement by us of the content or owners of any linked websites, mobile applications or social media platforms. Your interactions with any Third-Party Social Media Service or any other third-party website, mobile application or service are governed by the service provider's privacy practices and you should consult the provider's privacy policy before submitting or allowing any collection of personal information.

Protection of Personal Information

We have adopted security procedures to protect the personal information we collect appropriate to the nature of the personal information. Despite our efforts to safeguard your personal information, we cannot guarantee it will be completely secure from unauthorized access, disclosure, use, or alteration. There is always a risk inherent in the electronic transmission and storage of information. To protect the security of your user name and password, we recommend that you use a complex password that is different from passwords you use for other activities, keep all your passwords in a safe place, and do not share your passwords with others. Always remember to logout after your session ends so that other people cannot access your account information.

How Long We Retain Personal Information

We will retain your fan profile and other personal information (including geolocation data) as long as we provide Services to you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain and use your information after providing the Services to you for our legitimate marketing purposes (unless you instruct us to stop sending communications to you).

Children's Online Privacy

Our Services are not specifically directed to children. The Steelers do not knowingly collect, use, or disclose personal information from children under the age of 13. If we learn that personal information from children under age 13 has been collected, we will take reasonable measures to promptly delete that information from our records. If you become aware of any personal information we have collected from children under age 13, please contact us as explained below under "How to Contact Us." In order to sign up for our online and Mobile App Services, it is necessary to confirm that you are at least 13 years of age. Some activities, such as Steelers' summer youth camps, are intended for children. To register a child under age 13 for a Steelers' summer camp or another activity open to that age group, the parent or guardian must submit the online registration form, provide a credit card payment, and provide such other proof of consent to the gathering of any information regarding such parent's or guardian's child as may be requested by the Steelers.

If you believe we have obtained data about a child under 13 years of age without the consent of a parent or guardian, please notify us at feedback@fans.steelers.com .

International Users

Please note that our Services are directed towards users who reside in the United States. If you reside or are located in a different country, the data protection laws of that country may differ from the laws of the United States in the ways your personal information is protected. We want you to understand that when you provide your personal information to us, or we obtain it through your use of our Services or other means, your information will be transferred to the United States and processed in accordance with the laws of the United States and the guidelines of this Privacy Policy. You agree to and acknowledge our collection, transfer, and processing of your Personal Information in accordance with this Privacy Policy.

Changes to this Privacy Policy

We may revise this Privacy Policy at any time and will post the revised Privacy Policy with the effective date on our Websites. If we make a material change to the way in which we collect, use, or share your personal information, we will post a notice on our Websites. Your continued use of the Services after a change to this Privacy Policy constitutes your consent to be bound by the revised Privacy Policy. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices.

How to Access and Manage Your Personal Information

You can correct, update, or make changes to the information we have about you by logging in to your Mobile App or online account and making the required changes or by contacting us as explained in "How to Contact Us." You may request that we no longer use your information to provide services to you by emailing us at feedback@fans.steelers.com or by contacting us by postal mail at the address provided in "How to Contact Us." We will respond within a reasonable timeframe.

How to Contact Us

Please direct your account changes and questions and concerns regarding this Privacy Policy and your personal information either:

By postal mail to:
The Pittsburgh Steelers
3400 South Water Street
Pittsburgh, PA 15203
Attn: Privacy Policy

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Notices to California Consumers and Rights of California Residents

California Consumer Privacy Act
This section of our Privacy Policy supplements our Privacy Policy to provide additional information under the California Consumer Privacy Act of 2018, as amended, and applies only to consumers who reside in the State of California.

Categories of Personal Information Collected
The chart below summarizes the categories we may have obtained about you during the past twelve (12) months, depending on the nature and scope of our interactions with you.

Table inside Article
Categories of Personal Information Collected in Past 12 Months Business or Commercial Purpose for Which the Information is Collected
Personal identifiers To enable use of our Services, to communicate with you, to understand and improve how users interact with our Websites, and use our Services.
Personal information under California Civil Code section 1798.80 To enable use of our Services, to communicate with you, to understand and improve how users interact with our Websites, and use our Services.
Commercial Information To enable transactions you’ve requested from our Services
Electronic Information To enable use of our Services, to communicate with you, to understand and improve how users interact with our Websites, and use our Services.
Geolocation Data To enable use of our Services, to communicate with you, to understand and improve how users interact with our Websites, and use our Services.

The personal information we collect about consumers and the business or commercial purposes for which it is used is described in these sections of our Privacy Policy:

  • Personal Information We Collect through Our Services
  • Personal Information We Collect Using Cookies and Tracking Technologies
  • Personal Information We Collect from Other Sources
  • How We Use Personal Information
  • Why and With Whom We Share Personal Information

No Sales of Personal Information
California consumers have the right to direct a business not to sell their personal information to others ("Right to Opt-Out").

In the preceding twelve (12) months, the Steelers have not made sales of personal information for monetary or other valuable consideration. In the future, the Steelers may participate in sponsorships, marketing programs, or other activities that may be deemed to constitute sales of your personal information.

As explained in the section of this Privacy Policy titled, "Why and With Whom We Share Personal Information," the Steelers share online usage data from www.steelers.com with the NFL, which hosts that website along with similar websites for other NFL teams. We also may share some fan information with sponsors of contests and sweepstakes or participate in joint marketing programs with selected third-party businesses that offer products and services we believe may be of interest to our fans. Generally, we do not consider these sponsorship and marketing arrangements to be sales of your personal information although we may receive reciprocal services or customer information from them.

Right to Know about Personal Information Collected, Disclosed, or Sold
California consumers have the right to request any of the following information regarding personal information collected about the consumer or the consumer's household during the last twelve (12) months ("Request to Know"):

  1. The categories of personal information collected about you.
  2. The categories of sources from which the personal information is collected.
  3. The business or commercial purpose for collecting or selling personal information.
  4. For personal information sold or exchanged for value with a third party: categories of personal information and categories of third parties.
  5. For personal information disclosed to a third party for our business purpose: categories of personal information; and categories of third parties.
  6. The specific pieces of personal information collected about you (except for very sensitive personally identifiable information).

If you request specific pieces of information, you may have the right to have the information transmitted in a portable format that should facilitate transmission to another entity. The process by which we verify and respond to your requests is explained below under "How to Make a Verifiable California Consumer Request" and "How We Will Respond to a California Consumer Request."

Right to Deletion of Personal Information
California consumers have the right to request that a business delete any personal information about the consumer which the business has collected from the consumer, subject to a range of exclusions permitted by law ("Request to Delete"). For example, a business is not required to delete personal information if it is necessary to complete a transaction, is reasonably used for an ongoing business relationship, or is used internally in a lawful manner that is compatible with the context in which the consumer provided the information.

Once we receive and verify your request, we will delete (and direct our service providers to delete) the requested personal information from our records, unless an exclusion applies. The process by which we verify and respond to your requests is explained below under "How to Make a Verifiable California Consumer Request" and "How We Will Respond to a California Consumer Request."

Designating an Authorized Agent
California consumers may designate an authorized agent to act on their behalf to opt-out from the Company's collection or sale of their Personal Information. An authorized agent may be a natural person or a business entity registered with the Secretary of State. An authorized agent must also submit to the Company written proof of their authorization to act on the consumer's behalf.

Personal Information of California Minors
We do not sell the personal information of minors under 16 years of age.

How to Make a Verifiable California Consumer Request
California consumers may submit a request to exercise any of their rights described above using any of the following methods:

By phone: (833) 888-0218

Online webform: CCPA Online Webform

Please note that in order for us to verify certain requests (including verification of your identity, California residency, and – for requests made on behalf of someone else – your relationship with the individual on whose behalf the request is being made), you may be required to confirm information that we have on file for you; including email address, phone numbers, full names, addresses and other personal information. We reserve the right to deny a consumer request if the identity or authority of the requesting party cannot be confirmed.

How We Will Respond to a California Consumer Request
For any Request to Know or Request to Delete, we will respond within ten (10) days and may request additional information necessary to verify that you are permitted to make the request. We will respond to any verifiable consumer request within forty-five (45) days of receiving it, subject to delays and exclusions permitted by law. If we require more time to respond, we will let you know the reason why and the extension period in writing. If you have a password-protected online account with us, we will respond via that account. If you do not have an online account, we will use the email address or U.S. Postal address provided to us when making the request.

For Requests to Know, our response will cover the twelve (12) month period preceding our receipt of the request. If we cannot comply with all or part of your request, we will explain the reasons why. 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 readily from one entity to another entity.

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.

Protection from Discrimination for Exercising California Consumer Rights
California consumers have a right not to receive discriminatory treatment by the business for exercising the privacy rights conferred by the California Consumer Privacy Act. As such, we will not discriminate against a California consumer for exercising any of the rights described in this section. This means that except as legally permitted 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.

Financial Incentive Program
We are permitted to offer certain financial or service incentives to encourage consumers to provide certain financial information. If we offer a financial or service benefit program to you, we will provide a written description of the material terms of the program to you in a written Notice of Financial Incentive, and you will only be enrolled as a participant if you affirmatively opt-in to the program. You may revoke your opt-in consent at any time. The Notice of Financial Incentive will explain the process for opting-in to participate and withdrawing from the program (opting-out) in. 

California "Shine the Light" Law
Under California Civil Code Section § 1798.83, California's "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses those businesses with which we shared customer information for the immediately prior calendar year. You may request this information by contacting us as explained in the section of the Privacy Policy titled "How You Can Contact Us" and indicating "Request for California Privacy Information." Not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

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