California Consumer Privacy Notice

California Consumer Privacy Act of 2018 (“CCPA”) Privacy Notice for California Residents. If you are a California resident (occasionally referred to as “Consumer”), California law provides you with additional rights regarding our use of your Personal Data. For purposes of this California Consumer Privacy Notice and only for California residents, the term Personal Data means “personal information” as defined under CCPA.

This “Privacy Notice for California Residents” section does not apply (at least until January 1, 2021) to the Personal Data of California residents that we collect:

  • which is reflecting a written or verbal communication or a transaction between us and you, where you are acting as an employee, owner, director, officer, or contractor of a company or government agency and whose communications or transaction with us occurs solely within the context of our conducting due diligence regarding, or providing or receiving a product or service to or from such company or government agency; or,

  • in the course of your acting as a job applicant to or an employee of our company to the extent that your Personal Data is collected and used by us solely within the context of your role or former role as a job applicant to, an employee of our company.

Starting January 1, 2020, California residents have the right to (a) access a copy of their Personal Data held by us, (b) request deletion of their Personal Data held by us, and (c) opt-out of the sale of their Personal Data. These rights can be exercised by completing and submitting a request as provided below. The categories of your Personal Data we collect, and the purposes for which the categories of Personal Data are or may be used, are described above in this Privacy Policy.Disclosures of personal information, including sales or sharing of personal information to third partiesWe do not disclose personal information in exchange for cash payments or other forms of monetary compensation. However, we want to make it clear that the definition of "sale" under California law is broad enough to encompass the disclosure of personal information in exchange for anything of value, not just monetary compensation. Additionally, California law defines "sharing" as the disclosure of personal information for targeted advertising purposes.With these definitions in mind, we want to inform our customers and stakeholders that we may have sold or shared the following categories of personal information to third parties: Identifiers

  • Characteristics of classifications

  • Unique and other online identifiers

  • Internet or other electronic network activity information

  • Geolocation data

  • Inferences or audience segmentation

We may have sold or shared each of these categories of personal information with the following categories of third parties:

  • Affiliates – These are companies that are under our common ownership or control, and may include subsidiaries or parent companies.

  • Service Providers – These are third-party companies that process personal information on our behalf to provide services or products to you. This may include payment processing, shipping, or customer support.

  • Social Networking Platforms – These are companies that operate social networking websites or applications, such as Facebook, Twitter, or Instagram, and may collect personal information from you to provide their services.

  • Advertising Networks – These are companies that help us to display advertisements for our products or services to you, as well as to help others place ads on our website or other platforms.

  • Analytics Partners – These are companies that help us to collect and analyze data about how our products or services are used, so that we can improve them and better understand our customers.

  • Promotional Partners – These are companies that we partner with to promote our products or services through various marketing campaigns, such as sweepstakes, contests, or special offers.

  • Government Agencies – These are entities such as law enforcement authorities, regulatory agencies, or courts that may require us to disclose personal information in order to comply with legal or regulatory requirements.

Do Not Sell My Personal InformationTo exercise your right to "Do Not Sell My Personal Information" under the CCPA, please follow these steps: click on the cookie icon located in the bottom left corner of the page to access the Privacy Preference Center. From there, select the "Do Not Sell My Personal Information" tab and follow the prompts to opt-out.

Right To Access to Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you:

  • The categories of Personal Data we collected about you.

  • The categories of sources for the 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 disclosed your Personal Data for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.

Deletion Request Right

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 (as described below). As permitted by CCPA we may delete your Personal Data by (a) permanently and completely erasing the Personal Data on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Data; or, (c) aggregating the Personal Data.We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:

  • Complete the transaction for which we collected the Personal 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 our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

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

  • Comply with a legal, regulatory or law enforcement 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 emailing us at or calling us at 713-407-4400.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.

Verification Process

Email Verification Method: Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).

Response Timing and Format

We will confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request's receipt. 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. Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Data is for purposes consistent with the California resident’s reasonable expectations, when considering the submission’s circumstances.


We will not discriminate against you simply for your 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 by refusing to gran discounts or other benefits, or imposing penalties;

  • Provide you a different level or quality of goods or services; or,

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

California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578, available here):

CalOPPA applies only to companies which collect Personal Data of California residents.

How We Respond to Do Not Track Signals.

CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. Visitors can visit our Site anonymously by adjusting the settings in your browser.

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