Updated: March 18, 2021
1. Information We Collect and Disclose About You
We collect and use the following personal data that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal data”). In particular, we have collected the following categories of personal data and disclosed them for business purposes within the last twelve (12) months:
|Categories of Personal Data||Collected||Disclosed|
|B. Personal data categories listed in the California Customer Records statute||Yes||Yes|
|C. Protected classification characteristics under California or federal law||Yes||Yes|
|D. Commercial information||Yes||Yes|
|E. Biometric information||Yes||Yes|
|F. Internet or other similar network activity||Yes||Yes|
|G. Geolocation data||Yes||Yes|
|H. Sensory data||No||No|
|I. Professional or employment-related information||Yes||Yes|
|J. Education information||Yes||Yes|
|K. Inferences drawn from other personal data (e.g. via cookies)||Yes||Yes|
We obtain the categories of personal data listed by the following means:
- Directly from you in person, by telephone, text or email and through our Sites.
- Directly and indirectly from your activity on our Sites, such as from submissions through our Sites or usage details collected automatically like cookies.
- Directly or indirectly from third-parties that interact with us in connection with the services we perform or with your consent.
2. Use of Personal Data
We may use or disclose the personal data we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal data in order to register for an event, we will use that information to register you and make appropriate preparations.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To carry out our reporting obligations to state and federal regulators.
- To improve our website and present its contents to you.
- To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
- To debug, and identify and repair errors that impair existing intended functionality.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- 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 data 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 data held by us is among the assets transferred.
We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. Sharing Personal Data
We may disclose your personal data to a third party for a legitimate business purpose. When we disclose personal data for a legitimate business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except performing the contract.
We disclose your personal data for a legitimate business purpose to the following categories of third parties:
- Our subsidiaries and affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal data in connection with products or services we provide to you.
We DO NOT sell any personal data.
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to know:
- The categories of personal data we collected about you.
- Our business or commercial purpose for collecting that personal data.
- The categories of third parties with whom we share that personal data.
- The specific pieces of personal data we collected about you (also called a data portability request).
If we sold or disclosed your personal data for a business purpose, you have the right to know;
- For sales, the categories of personal data and the categories of third parties to whom the personal data was sold; and
- For disclosures for a business purpose, the categories of personal data.
Please note that we are not required to:
- Retain any personal data about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal data; or
- Provide the personal data to you more than twice in a 12-month period.
Deletion Request Rights
You have the right to request that we delete any of your personal data 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 data 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 do any of the following:
- Complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform per 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 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.
- 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 phone, mail or email. See “How to Contact Us”.
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 data. 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 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 data 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 data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal data 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 45 days of its receipt. If we require more time (up to 90 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 the receipt of the verifiable consumer 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 data 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.
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.
6. Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. We will post the updated version on our Sites and indicate at the top of the notice when it was most recently updated.
7. How to Contact Us
If you have any questions or comments about this privacy notice, the ways in which we collect and use your personal data, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
By e-mail at: email@example.com
By phone at:
(800) 283-0105 (Toll Free)
In writing at:
Attention: Privacy Officer
19886 Ashburn Road
Ashburn, VA 20147