Information for California Residents

This section provides additional information for residents of California under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered “personal information,” such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.

Personal Information Collected in the Last 12 Months

We collect the following categories of personal information about Customers:

• Personal Identifiers, including name, email address, postal address, and telephone number
• Online Identifiers, including unique personal identifier, device identifier, IP address, customer number, online identifier, and account login
• Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, browsing history, and search history
• Commercial and Financial Information, including purchases, other purchasing behavior, and credit card or debit card number

We collect the following categories of personal information about Newsletter Subscribers:

• Personal Identifiers, including name and email address
• Online Identifiers, including unique personal identifier

We collect the following categories of personal information about SMS Subscribers:

• Personal Identifiers, including name, email address, and telephone number
• Online Identifiers, including unique personal identifier

We collect the following categories of personal information about Users:

• Personal Identifiers, including name and email address
• Online Identifiers, including unique personal identifier, device identifier, and IP address
• Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, browsing history, and search history

Sources of Personal Information

We collect personal information about Customers from the following sources:

• You (the consumer)

We collect personal information about Newsletter Subscribers from the following sources:

• You (the consumer)

We collect personal information about SMS Subscribers from the following sources:

• You (the consumer)

We collect personal information about Users from the following sources:

• You (the consumer)

Business or Commercial Purposes for Collecting Information

We collect personal information for the following business purposes:

• Provide Products or Services
• Advertising and Marketing
• Security
• Internal Research
• Short-Term Transient Use
• Audit Current Interactions

We also “share” (as defined in the CCPA) personal information for commercial purposes, including to advertise and market our products.

Information Disclosed for Business or Commercial Purposes in the Last 12 Months, and Categories of Parties Disclosed To

Customers

Personal Information Disclosed	Category of Party
Personal Identifiers, including name, email address, postal address, and telephone number	Ad Networks, Business Operations Tool, Payment Processors, Service Providers
Online Identifiers, including unique personal identifier, device identifier, IP address, customer number, online identifier, and account login	Ad Networks, Business Operations Tool, Data Analytics Provider, Service Providers
Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, browsing history, and search history	Ad Networks, Data Analytics Provider, Service Providers
Commercial and Financial Information, including purchases, other purchasing behavior, and credit card or debit card number	Ad Networks, Business Operations Tool, Data Analytics Provider, Service Providers

Newsletter Subscribers

Personal Information Disclosed	Category of Party
Personal Identifiers, including name and email address	Service Providers
Online Identifiers, including unique personal identifier	Service Providers

Users

Personal Information Disclosed	Category of Party
Personal Identifiers, including name and email address	Service Providers
Online Identifiers, including unique personal identifier, device identifier, and IP address	Ad Networks, Data Analytics Provider, Service Providers
Internet Activity, including interactions with websites, apps or ads, browsing history, and search history	Ad Networks, Data Analytics Provider, Service Providers

CCPA Rights

Your CCPA rights are described below. You can make a Request to Know or a Request to Delete under the CCPA by submitting a Privacy Request by emailing privacy@privateclubmarketing.com.

Right to Know

You have the right to request to know the following about the personal information we have collected about you in the past 12 months:

• the categories and specific pieces of personal information we have collected about you
• the categories of sources from which we collect personal information about you
• the business and commercial purposes for which we collect personal information
• the categories of third parties with whom we share the information
• the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose

If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.

Right to Delete

You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.

We consider information to be necessary for our business operations if it is used to:

• Complete an obligation to you that you have requested
• Detect and resolve issues related to security or functionality
• Comply with legal obligations

Right to Non-Discrimination

If you exercise your CCPA consumer rights:

• We will not deny goods or services to you
• We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
• We will not provide a different level or quality of goods or services to you

Right to Opt-Out

You have the right to opt-out of any selling and sharing of your personal information.

You may exercise your right to opt-out by emailing privacy@privateclubmarketing.com

Request Verification

Before we can respond to any CCPA requests, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft.

The verification process depends on which type of request you make and how you make it. Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request.

For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.

In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:

• If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
• If the only data we have collected about a consumer is gathered through website cookies (i.e., the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.

Authorized Agent

A California resident's authorized agent may submit a Request to Know or a Request to Delete under the CCPA by emailing us at privacy-ccpa@privateclubmarketing.com. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.

If you have trouble accessing this notice, please contact us at privacy-ccpa@privateclubmarketing.com.

Contact Us

If you have any privacy-related questions, please send them to privacy-ccpa@privateclubmarketing.com.