Activate® Terms of Use and Privacy Policy

Introduction

NAS Recruitment Innovation (NAS) builds and hosts individually branded career-related websites on behalf of hiring organizations that combine job search functionality with career site content. These websites are known as ACTIVATE® websites (each, a “Site”). ACTIVATE websites can be identified by the Powered by ACTIVATE® logo located at the bottom of every ACTIVATE website.

PLEASE READ THESE TERMS CAREFULLY BEFORE USING THIS SITE.

These Terms of Use and Privacy Policy (these “Terms”) apply each time you access the Site or use the services offered on the Site (the “Services”). When you access the Site or use the Services, you accept these Terms as if you had signed them, and you consent to our collecting and using your information as described in these Terms. If you do not agree to these Terms, you may not access the Site or use the Services. We may revise or terminate these Terms at any time, without notice to you. You are responsible for reviewing these Terms. Your access of the Site or use of any of the Services following the posting of changes to these Terms means you agree to abide by those changes.

  1. TERMS OF USE

    1. Allowed Activities

      You may use this site only for lawful purposes and in accordance with these Terms. Do not use the Services to engage in or encourage any activity that is illegal, deceptive, harmful, a violation of others’ rights, or harmful to NAS’s business operations or reputation, including:

      • Violating laws, regulations, governmental orders, industry standards, or telecommunications providers’ requirements or guidance in any applicable jurisdiction, including any of the foregoing that require consent be obtained prior to transmitting, recording, collecting, or monitoring data or communications.
      • Interfering with or otherwise negatively impacting any aspect of the Services or any third-party networks that are linked to the Services.
      • Reverse engineering, copying, disassembling, or decompiling the Services.
      • Creating a false identity or any attempt to mislead others as to the identity of the user or the origin of any data or communications.
    2. Links to Third-Party Sites

      The Services may contain links to third party web sites (“Linked Sites”). The Linked Sites are not under the control of NAS and NAS is not responsible or liable for the communications or materials of any Linked Sites. The inclusion of any link does not imply endorsement by NAS of the third-party site or any association with its operators. You are responsible for adhering to the applicable terms of service for any other web site and are solely responsible and liable for any interactions you may have with such sites and other third parties.

    3. Intellectual Property Ownership

      The Site and the Services contain proprietary and confidential information that: (a) is the sole property of the NAS, its clients or its partners; (b) is protected under U.S. and international patent, copyright, trademark, trade secret and other intellectual property law; and (c) may only be used in accordance with these Terms or our express written consent. You are granted only those rights necessary to access the Site and use of the Services as permitted herein. All trademarks, service marks, trade names and trade dress (the “Marks”), whether registered or unregistered, appearing in the Site are proprietary to us, our clients or our partners. You may not display or reproduce the Marks without our prior written consent, and you may not remove or otherwise modify any patent, copyright, trademark, other proprietary notice or disclaimer from any content. All other rights not expressly granted herein are reserved.

    4. Disclaimers

      YOU EXPRESSLY ACKNOWLEDGE AND AGREE THAT THE SITE AND THE SERVICES, INCLUDING ALL INFORMATION AND OTHER CONTENT (INCLUDING THIRD PARTY INFORMATION) ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS AND WITHOUT WARRANTIES OF ANY KIND EITHER EXPRESSED OR IMPLIED. TO THE FULLEST EXTENT PERMISSABLE, PURSUANT TO APPLICABLE LAW, NAS DISCLAIMS ALL WARRANTIES, EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO: IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. NAS DOES NOT WARRANT THAT ANY PORTION OF ANY SITE OR ANY SERVICE WILL BE UNINTERRUPTED OR ERROR FREE, THAT DEFECTS WILL BE CORRECTED OR THAT ANY SITE OR ANY SERVICE THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL CODE. NAS DOES NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OR THE RESULTS OF THE USE OF THE SITES OR THE SERVICES IN TERMS OF CORRECTNESS, ACCURACY, RELIABILITY OR OTHERWISE. ANY MATERIAL DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICES IS DONE AT YOUR OWN DISCRETION AND RISK. SOME STATES MAY NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO THE ABOVE EXCLUSIONS MAY NOT APPLY TO YOU.

      NAS makes no representations or guarantees regarding the effectiveness of the Services or timeliness of the Services in meeting your employment objectives. We do not guarantee job placement, availability of jobs, or that any application submitted via a third-party site will result in employment.

      NAS does not make any representation or warranty about whether the Site or the Services are adequate to meet your privacy and security compliance obligations. You are responsible for determining whether the Services offer appropriate safeguards for your use of the Services, including, but not limited to, any safeguards required by applicable law or regulation, prior to transmitting or processing any data or communications via the Services.

    5. Limitation of Liability

      IN NO EVENT SHALL NAS OR ANY OF ITS AFFILIATES BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, CONSEQUENTIAL, PUNITIVE OR INCIDENTAL DAMAGES, LOST PROFITS OR THE COST TO PROCURE SUBSTITUTE GOODS AND SERVICES OR DAMAGES RESULTING FROM LOST DATA, LOST EMPLOYMENT OPPORTUNITY, OR BUSINESS INTERRUPTION RESULTING FROM OR ARISING UNDER OR IN CONNECTION WITH SERVICES OR THE USE OR ACCESS TO, OR THE INABILITY TO USE OR ACCESS, THE SITE, EVEN IF NAS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES AND WHETHER SUCH DAMAGES ARISE IN CONTRACT, NEGLIGENCE, TORT, UNDER STATUTE, IN EQUITY, AT LAW OR OTHERWISE. YOU ASSUME ALL RESPONSIBILITY AND RISK FOR YOUR USE OF THE SITE, THE INTERNET GENERALLY, AND THE DOCUMENTS OR EMPLOYMENT-RELATED MATERIALS THAT YOU POST, PROVIDE OR ACCESS AND FOR YOUR CONDUCT ON AND OFF THE SITE. IN NO EVENT SHALL OUR TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES AND CAUSES OF ACTION, REGARDLESS OF THE FORM OF ACTION, EXCEED ONE THOUSAND U.S. DOLLARS (US $1,000).


  2. PRIVACY POLICY

    NAS recognizes and respects the privacy of visitors to our Sites. The purpose of this privacy policy is to describe your privacy rights and how NAS stores and discloses personal information and other data collected via the Site. We reserve the right to modify this policy at any time. This URL will always contain the latest, most up-to-date version of our privacy policy.

    1. Personal Information

      By default, NAS collects no personal information associated with visitors to our ACTIVATE websites apart from the IP address of the device being used to access the Site. However, some of the hiring organizations we work with may choose to enable additional ACTIVATE modules that do collect personal information. These modules include:

      • Job Alerts and Talent Network

        The ACTIVATE Talent Network allows you to sign up to receive email job alerts as new jobs become available that match your interests. To receive job alerts, you will be required to provide your email address, area of interest and/or location of interest. Depending on the criteria you select, you may receive job alerts from NAS as frequently as once per. The information collected is used strictly to provide relevant job alerts to you. NAS never shares with, sells or distributes this information to any third-party, not even the organization for whom it was collected, except as noted below. If you no longer wish to receive job alerts, you may unsubscribe at any time using the “Unsubscribe” link located at the bottom of every job alert email. This information is securely stored within the NAS hosting environment located in the continental United States.

      • Additional Communications

        As you’re signing up for job alerts, you may also opt-in to receive additional communications from the organization whose website you are visiting. By opting in, you may be asked to provide additional information such as your first name, last name, postal code, phone number and other pieces of information that will allow the hiring organization to provide relevant, employment-related communications to you. Unless engaged by the Client for managed service,NAS does not control these communications, nor do we have any awareness of or influence over the kinds of communications these organizations send. Additional communications are subject to the privacy policies associated with the communicating organization. By opting-in, you are authorizing NAS to share this information along with your email address, phone number (where applicable), area and/or location of job interest with the organization for whom it was collected. NAS never shares with, sells or distributes this information to any other third-party. The personal information you provide is securely stored within the NAS hosting environment located in the continental United States.

      • Landing Pages

        In addition to the Talent Network, the organizations we work with may elect to create one or more landing pages that collect your personal information for employment and employment marketing purposes. The kinds of personal information and specific purpose for collecting this information varies by landing page. By providing this information, you are authorizing NAS to share this information with the organization for whom it was collected, and you are opting-in to receive communications from this organization. NAS does not control these communications, nor do we have any awareness of or influence over the kinds of communications these organizations send. These communications are subject to the privacy policies associated with the communicating organization. NAS never shares with, sells or distributes this information to any other third-party. The personal information you provide is securely stored within the NAS hosting environment located in the continental United States.

    2. Opting out

      By signing up for job alerts, opting in to additional communications, or providing personal information on any of our landing pages, you are agreeing to the terms of this privacy policy. If you do not agree with our privacy policy, please do not sign up for job alerts, opt-in to additional communications, or provide personal information on any of our landing pages. At any time, you may unsubscribe from any email communications generated by NAS systems by utilizing the “Unsubscribe” link contained within every email or by contacting NAS using the details in the “Contact us” section below. In addition, you may unsubscribe from any text communications generated by NAS systems by replying STOP.

    3. Your Rights:

      Under data protection laws, you may be able to exercise certain rights including:

      • Access: The right to request access to your Personal information that is processed by NAS;
      • Correct: The right to request personal information to be updated and corrected, or completed if incomplete;
      • Erase: The right to request your personal information to be deleted. Where we have legal requirements to retain information, we will confirm this.
      • Sensitive data: The right to limit the use and disclosure of sensitive personal information (race or ethnic origin, religious beliefs, genetic data, biometric data, health data, and sexual orientation).
      • Object or Restrict: The right to object to or restrict our processing of your Personal Information, which includes opting out from marketing communications, selling personal information to a 3rd party (also includes sharing) or restricting the processing of personal information to only certain activities.
      • Non-discrimination: The right to non-discrimination for exercising your data privacy rights.;
      • Withdraw Consent: When Personal Information processing is based on your consent, you have the right to withdraw consent at any time; and
      • Automated decision making: To opt out of processing of personal information used for solely automated decision making and profiling.

      To exercise your rights, you can write the Data Protection Officer at dataprotection@nasrecruitment.com

    4. California Residents

      If you reside in California, you have rights under the California Consumer Privacy Act (CCPA) in addition to the rights outlined in this Privacy Policy. You may access our California Privacy Policy here.

    5. Other State Laws

      Some US States have individual Laws which regulate the processing of personal information. In addition to the details stated in this Privacy Policy, these State laws provide various data protection principles including:

      • Data minimization – limit the collection of personal information to what is adequate and relevant.
      • Purpose limitation – only to process personal information for purposes that are reasonably necessary and compatible with its original disclosed purposes.
      • Duty to avoid unlawful discrimination – not to process personal information which violates laws prohibiting unlawful discrimination.
      • The business must establish, implement, and maintain reasonable administrative, technical, and physical data security practices to protect the confidentiality, integrity, and accessibility of personal information.
      • Process consumers’ sensitive data only after obtaining the consumer’s consent. Sensitive data includes genetic or biometric data, precise geolocation data and personal information revealing racial or ethnic origin, religious beliefs, and health status.
    6. Cookies

      ACTIVATE™ websites utilize cookies for a variety of purposes:

      • Essential

        Essential cookies are required for our websites to operate properly and securely and to store your cookie preferences. These cookies are not used to store personal information about you.

      • Analytics

        Analytics cookies are used to track how you use our websites, including the pages you visit, how many times you’ve visited our site, the links you click, your search activity (including search keywords), referring source (the name or URL of the website that sent you to our website), the IP address of your web browsing device, and other related analytics data. In addition, upon request, hiring organizations may elect to place their own performance cookies and tracking code in order to gather similar kinds of analytics data. NAS shares the data we collect only with the organization for whom it was collected. We never share with, sell or distribute this information to any other third party. Performance cookies are never used to collect or store personal information.

      • Functional

        Functional cookies are used to store information such as your username, region, or language preferences in order to tailor your browsing experience for you. NAS does not currently utilize these types of cookies, but may do so in the future. Should we ever decide to implement these kinds of cookies, we will update this privacy policy before doing so.

      • Marketing

        Marketing cookies are used to track your browsing habits and serve relevant advertisements to you on other third-party websites, such as search engines, that utilize affiliate advertising. For example, if you search for a particular job on our website, at some point in the future, you may see an advertisement in your favorite search engine about that job or job category. NAS shares this information only with the organization for whom it was collected.. The only personal information we collect is the IP address of the device used to access the Site.

      • Other

        Some of our websites may contain embedded third-party content, such as YouTube videos, third-party forms, and chat widgets. These third parties may utilize their own cookies in order to track your activity and/or store other information about you as applicable to this embedded content. NAS does not control these cookies, or influence the kinds of information stored or tracked by these cookies. For more information, please refer to the privacy policy associated with the provider of the embedded content.

      • Cookie Options

        As a visitor of our websites, your cookie preference options may vary based on (1) your location and (2) the intended audience of the hiring organization whose website you are visiting. If applicable, we will determine your location based on the IP address of your web browsing device. Upon your initial visit to each of our ACTIVATE™ websites, you will be presented with a pop-up indicating that the site uses cookies. You may Deny or Accept All cookies used on the Website with the exception of those deemed Essential. No matter which option you click, you will always have the ability to adjust your cookie preferences by clicking the “Cookie Privacy” widget in the lower area of our websites. Cookie preferences must be set per website and only apply to the specific website for which they were set.

    7. CONTACT US

      If you have any questions or concerns regarding these Terms or your personal information as applicable to Powered by ACTIVATE® websites, please contact our Data Protection team as follows:

      • NAS Recruitment Innovation, Inc.
      • ATTN: Data Protection
      • 6133 Rockside Road, Suite 302
      • Independence, OH 44131
      • United States
      • dataprotection@nasrecruitment.com
      • Last updated March 5, 2025

NAS Recruitment Innovation (NAS) Supplementary Privacy Notice for California Residents Only

EFFECTIVE DATE: JANUARY 1, 2020 LAST REVISED: MARCH 5, 2025 This notice supplements the information contained in the main Privacy Policy set forth above and applies solely to residents of the State of California (“California Privacy Policy“).  We have adopted our California Privacy Policy to comply with the California Consumer Privacy Act of 2018 as amended (“CCPA“)[1]. Our California Privacy Policy is intended to fulfill CCPA’s objectives of providing California consumers with a comprehensive disclosure of the collection, sharing, disclosure, and sale of their personal information by businesses (as CCPA defines those terms), and of the rights that California consumers have regarding their personal information (“California Privacy Rights“).

  1. California Privacy Rights Under CCPA
    1. Right to Know About Personal Information Collected, Disclosed or Sold (“Right to Know”)
      1. Scope of Applicable Personal Information

        CCPA provides you the right to request that we disclose to you any or all of the following about your personal information for the 12-month period preceding your request:

        1. the specific pieces of personal information that we have collected about you;
        2. the categories of personal information we have collected about you;
        3. the categories of sources from which we have collected your personal information;
        4. the categories of personal information that we have sold or disclosed for a business purpose about you;
        5. the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
        6. the business purpose for collecting or selling your personal information.

        CCPA also provides you the right to receive information about any financial incentives (i.e., compensation payments) that we may offer in connection with use of your personal information for participating in certain of our Services (as that term is defined in the introduction in our Main Privacy Policy).

        For detailed information about the personal information that we collect and the purposes for which we collect it, please see Part II (“Information We Collect and What We May Do With It”) below.

        If you exercise your Right To Know, after we confirm your identity, as explained more fully in Part III (“Exercising Your California Privacy Rights”), we will:  (a) disclose to you the information we have collected about you during the preceding 12 months that corresponds to your request; and (b) deliver, free of charge to you, by mail, or electronically, the personal information that you have requested, in the manner required by CCPA and as further described below in Part III (“Exercising Your California Privacy Rights”).

      2. Exclusions from Scope of Personal Information.

        CCPA excludes the following from its definition of “personal information”:

        1. Publicly available information from government records
        2. De-identified or aggregated consumer information
        3. Information excluded from CCPA’s scope, such as
          1. Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
          2. Personal information regulated by other sector-specific laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
      3. Statement With Respect to the Personal Information of Minor Children:

        NAS Does Not Collect, Use, Disclose or Sell Personal Information of Minor Children.

        NAS does not offer any Services designed for, intended to attract, or directed towards children under the age of 18.  We have a historically followed a careful policy that should we become aware of personal information we have unknowingly collected or held about or for minors under age 18, we will immediately and permanently delete it.

        Moreover, we have not ever, and nor do we intend to ever, knowingly or purposefully collect, use, disclose, share, or sell any personal information of minors under age 18.

    2. Right to Have Personal Information Deleted (“Right to Delete”)

      You have the right to request the deletion of your personal information that we collect or maintain.

      If you exercise your Right to Delete, after we confirm your identity, as explained more fully below in Part III (“Exercising Your California Privacy Rights”), we will, in the manner specified by CCPA, permanently delete your personal information from our records, unless one of the CCPA exceptions applies to your deletion request applies.

      Also, to the extent required by CCPA, we will direct deletion of your personal information by third parties with whom we have shared the personal information that you have requested that we delete.

      Exceptions to your Right To Delete include, but are not limited to, instances when the personal information is necessary to complete a transaction or provide the service requested by you for which the subject personal information was collected or provided (such as to participate in our market research Activities), detect security incidents or protect against deceptive, fraudulent, or illegal activity, or to comply with a legal obligation under CCPA, the California Electronic Communications Privacy Act, or other California or US federal law.

    3. Right to Opt-Out of the Sale of Personal Information (“Right to Opt-Out”)

      Under CCPA, you also have the right to opt-out of the “sale” (as defined by CCPA) by a CCPA-subject business of your personal information to third parties.

    4. Right to Not Be Discriminated Against for Exercising Your California Privacy Rights (“Right to Non-Discrimination”)

      You have the right to not receive discriminatory treatment if and when you exercise any of your California Privacy Rights under CCPA.  This would include, as examples, imposing a penalty fee or denying services to you because you exercised a CCPA right.

      We will never penalize or otherwise subject you to discriminatory treatment for exercising any of your California Privacy Rights.

      Please note that exercising your right to delete some or all of your personal information may mean that you are not able to participate in certain market research opportunities that we offer.

      For example, if we do not have enough information to determine whether you meet the criteria for a study, you will not receive invitations to participate.  In addition, certain studies may require that certain aspects of your personal information be shared with the client (such as a focus group opportunity, where your name, contact information, medical background, and practice location are needed in order to convene a desired focus group).

      Financial incentives, such as per-survey compensation payments, are made for certain of our market research Activities.  Market research compensation payment amounts are set at levels determined by taking into account many variables such as (by way of examples only) the complexity of the subject matter of the research inquiry, the professional education, training, and experience level desired for the respondents, the number of respondents needed, and the number of qualified respondents available.

      If you have questions about your Right to Non-Discrimination, please contact us as described in Part III (“Exercising Your California Privacy Rights”) below.

  2. Information We Collect and What We May Do With It

    NAS, our subsidiaries, and our affiliates, as well as our third-party business partners with whom we conduct our regular business operations, may collect, share, or disclose personal information solely for business purposes as described in the following sections:

    1. Categories of Third Parties refers to the following persons or entities with whom we may share personal information for business purposes:

      1. Business Support Consultants (examples include our consultants, advisors, and/or vendors who help us by (as examples only)): (a) preventing fraud or violations of our Terms of Service; (b) analyzing site user data and behavior, and tracking page performance; (c) identifying site issues and repair errors that impair intended functionality; (d) providing communication services with hiring organizations; (e) providing customer service to our Site users; (f) providing CCPA-required and other verifications of consumers or consumer consent; and/or (g) providing data storage and/or data processing services. All of our Business Support Consultants have written agreements with us which:
        1. require them to comply with all legal privacy requirements to which we are subject, including those provided in CCPA;
        2. limit their access to personal information to the minimum necessary in order to perform their services for us; and
        3. restrict them from making any use of personal information beyond fulfilling the specific services to us for which they are engaged;
      2. Business Partners (examples include clients, prospective clients and their representatives who may engage us to conduct market research or provide other services for CCPA-permitted business purposes); and
      3. Public Authorities (examples include law enforcement and other government authorities if required by law or reasonably necessary to protect the rights, property, and safety of others or ourselves)
      4. Hiring Organizations. Examples include employers, employee recruitment professionals and hiring managers who NAS advertise job opportunities on their behalf.
    2. Business Purposes for Collecting Personal Information: NAS will only collect and use your personal information for the following business purposes listed below:
      1. Providing you with the services and support that you may request, and processing and validating your transactions;
      2. Communicating with you about your account or transactions, changes to our policies and other administrative matters, or responding to your questions and comments;
      3. Understanding better your interests in order to provide you with customized job opportunities and other content;
      4. Administering and improving all of our products, services and operations;
      5. Ensuring compliance with our policies and Website Terms and Condition, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others;
      6. Complying with our legal and regulatory requirements; and
      7. Providing you with information regarding employment opportunities and career-related information, tools, and resources, and sharing your resume and other job candidate information with prospective employers and recruiters.

      These business purposes are indicated by numeral, as applicable, in the third and fourth columns (respectively) of the charts in the next two sections.

      We will never use your personal information differently than what we have disclosed to you in this notice, unless we first notify you and obtain your consent to a different use.

    3. Notice at Collection (Personal Information Collected By Us Upon Your Visiting Our Site)
    4. Personal Information We Have Collected Over the Past Twelve Months.


  3. Exercising Your California Privacy Rights

    In order to exercise your Right to Opt-Out, Right to Know, Right to Delete, and Right to Non-Discrimination, please submit your request to us in any one of the ways listed below.

    • By Webform: please complete the form below which you may either send electronically, or print out and mail to us at our address below:
    • By E-mail: dataprotection@nasrecruitment.com please put “California Privacy Request” in the subject line)
    • By Mail or Courier: NAS Recruitment Innovation, Inc. ATTN: Data Protection 6133 Rockside Road, Suite 302 Independence, OH 44131 United States
    • Only you, or a person (or a business entity registered with the California Secretary of State) whom you have authorized to act on your behalf may make a consumer request about your personal information. Consistent with CCPA’s provisions, we may require either (or both) that you provide your authorized agent with written permission to act for you and verify your own identity to us (or provide a power of attorney signed by you stating your authorized agent’s power to act for you).[2]

    If you have questions or concerns about your rights under our California Privacy Policy, or any of the provisions or practices described in either our California Privacy Policy or our Main Privacy Policy, please contact us via the telephone number, e-mail address, or mail/courier address provided above.

  4. Responding to Right to Know and Right to Delete Requests

    Within ten (10) business days of receipt of your Right to Know or Right to Delete request, we will confirm our receipt, provide you details about the process we will follow to respond to your request, and/or ask questions, or for additional information, that may be required.

    We plan to fulfill these requests within 45 calendar days of receiving the request. If we need more time to respond to your request, we will let you know the reason and, within the first 45 calendar days following receipt of your request, estimate how much additional time we will need (in any event, we will complete your request within 90 calendar days in total from receipt of the request).If we deny your Right to Know or Right to Delete request, in whole or in part, we will provide you with the reason for this, and if our denial is partial, we will disclose to you, or delete (as applicable), the other information you have requested.

    1. Verification Process: To assert your Right to Know or your Right to Delete, you will be asked to verify your identity before fulfilling your request. This verification process may require you to provide pieces of personal information that we already hold on you, or, in certain circumstances, a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
    2. Procedure; Frequency of Submitting Right to Know Requests: You may make requests regarding your Right to Know only twice within any 12-month period.We do not charge a fee to process or respond to your Right to Know requests, unless a particular request 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.
    3. Procedure; Frequency of Submitting Right to Delete Requests: You may make a Right to Delete request to us at any time.  Following verification of your request, we will immediately and permanently delete the personal information requested by you, unless one of CCPA’s exception to this right applies to your request.If we cannot verify the identity of the consumer requesting deletion of personal information, we may deny the Right to Delete request, and will inform the requestor of this.Once we verify the identity of the consumer making the Right to Delete request, we will respond to their request by either:
      1. permanently and completing erasing the personal information from our systems and records, in the manner specific by CCPA;
      2. de-identifying the personal information (meaning, carefully encrypting the personal information so it no longer identifiable or linkable to a particular consumer); or
      3. aggregating the personal information individual (meaning, we will carefully remove any consumer-identifiers from it, and group it together with other similarly-stripped data from which the resulting data group contains no particular consumer’s personal information in an identifiable fashion).

      We will inform you of the manner in which we have deleted your personal information following a Right to Delete request.

  5. Updates to this Supplementary Privacy NoticeWe may reserve the right to periodically update our California Privacy Policy. Please reference the “LAST UPDATED” legend above for the effective date of the most recent updates. Your continued use of our Site following these changes means that you accept the revised California Privacy Policy.

 

1 California’s full CCPA statute, 1798 Cal. Civ. Code #chr(0167)##chr(0167)# 1978.100 – 1798.199, may be found here: https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=CIV&division=3.&title=1.81.5.&part=4.

2 For information on preparing a Power of Attorney, see Cal. Probate Code #chr(0167)##chr(0167)# 4000-4465 (“Powers of Attorney”), here: http://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=PROB&division=4.5.