Privacy Policy

Privacy Policy

Privacy Notice

Last updated: May 2026


This Privacy Notice explains how we collect and process personal data from Publishers, Users, End-Users, visitors to our corporate website and social media pages, as well as how we share data with our third-party partners, depending on how you interact with us, our platform, or with Publisher Digital Assets where our Services are implemented.


Online Media Solutions Ltd. (“OMS“, “we” or “us“) is an ad-technology company that provides ad placement and campaign management services (the “Services“) to digital publishers. Our Services help publishers monetize their digital properties by connecting them with advertisers through real-time bidding (RTB) technology and other advertising solutions. Publishers who use our Services are our customers (“Publishers“), and they implement our technology on their websites, mobile applications, and other digital properties (collectively, “Publisher Digital Assets“).


Our Services operate within a digital advertising ecosystem that involves several groups of individuals and third parties. Publishers are the owners and operators of digital properties who contract with us to manage advertising on their assets. Publisher personnel who engage with us and/or access our platform to manage campaigns, view analytics, and access insights are referred to as “Platform Users“. When visitors and end-users of Publishers access Publisher Digital Assets, they may see advertisements delivered through our Services – these individuals are referred to as “End-Users“. Additionally, we work with various third-party partners who provide data enrichment services, identity syncing, and advertising technology solutions to enhance our Services and improve ad targeting and delivery (“Partners“). 


When we refer to “personal data“, we mean information that may directly or indirectly identify you, or as otherwise defined as personal data under law. 


When we refer to the “Website,” we mean OMS’s informational as available on https://onlinemediasolutions.com/.


When we refer to “you“, we mean either Platform Users, End-Users or visitors to our Website or social media pages, as applicable.


Table of Contents

  1. The Basics

  2. Personal Data We Collect as a Controller, How We Use it, and Why

    1. Visitors to Our Website and Social Media Pages

    2. Business Contacts

    3. Platform Users

    4. End-Users of Publisher Digital Assets

  3. Sharing the Personal Data We Collect

  4. International Transfers

  5. Security

  6. Your Rights – How to Control Our Use of Your Personal Data

  7. Data Retention

  8. Third-Party Services

  9. Children

  10. Changes to the Privacy Notice


  1. The Basics


  1. Who We Are


  1. We are Online Media Solutions Ltd. d/b/a “OMS”, a limited liability company incorporated under the law of the State of Israel. Our registered address is HaManofim 9, Herzeliya 4672560, Israel and our registration number is 512598145.


  1. We have appointed a data protection officer (DPO), who oversees our privacy practices. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your rights, please contact us at [email protected]


  1. Representative for data subjects in the European Union (EU). We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter, or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/16932930965


  1. Our Role: Controller and Processor. Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a “controller“) and a party that processes personal data solely on the controller’s behalf and according to the controller’s instructions (called a “processor“). We are the controller in respect of the processing described in this Privacy Notice. Additional entities who may be serving as separate, independent controllers are listed below.


  1. A Note on Legal Bases. Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU’s General Data Protection Regulation (“GDPR“), the possible legal bases include (but are not limited): your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data. Where we are a controller, we only collect and process data where we have established a legal basis. Below you can find more details about specific legal bases. Under Israeli law, the legal basis for processing is consent. You are not required under law to provide us with the Personal Data described in this Privacy Notice. However, if you do not agree to provide the same, we will not be able to provide you with some or all of our Services.


  1. Personal Data We Collect, How We Use It, and Why. Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don’t provide us with certain information, we may not be able to provide you with the associated services. For the avoidance of doubt, we may also use personal data to enforce our rights, enforce our contracts, protect our assets, and pursue available remedies or limit damages we may sustain.


  1. Visitors to Our Website and Social Media Pages.

    1. Contact Form Information. When you send us a message through the contact form on our Website, we collect any data you provide, such as your name, phone number, email, and the content of your message.


How We Use this Data: To respond to your message and manage our relationship with you.


Legal Basis: We process this personal data based on our legitimate interests in responding to inquiries and managing our relationship with you, or, where appropriate, to take steps at your request prior to entering into a contract.


  1. Activity and System Data (including Cookies). When you visit our Website, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device identifiers, and your activity on our Website (for example, pages visited, duration, and links clicked). 


A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a sort of tag, letting the website know that it’s you (really, your device) that’s visiting. There are other technologies that act similarly, like web beacons and pixel tags, but for simplicity’s sake we’ll refer to them all as “cookies“. Websites and applications can place their own cookies (called “first-party cookies“) but can also place cookies from other sites (called “third-party cookies“). If your browser holds both first and third-party cookies for a given website, both the website and the third party are notified when you visit the site. Our Website uses both first-party and third-party cookies. For more information, please see below.


How We Use this Data: We use this data to provide and maintain the Website (e.g., load balancing, security, and fraud prevention). We also use aggregated analytics to understand usage of the Website and to improve it and develop new services.


Legal Basis: For strictly necessary cookies and similar technologies used to provide and secure the Website, we rely on our legitimate interests in operating our Website. For analytics and advertising cookies and similar technologies, we rely on your consent.


While the specific names and types of cookies we use on the Website may change from time to time, they generally fall into one of the categories listed below. 


Cookie Type

Function

Necessary

These cookies are essential for the Website to function correctly and securely. They enable you to access and navigate the Website, and help us identify and prevent security risks, such as protecting your session information. These cookies cannot be disabled.

Functionality

These cookies remember your settings, preferences, and other choices you make  in order to help personalize and streamline your experience.

Performance/Analytics

These cookies collect analytical information to help us understand how you use our Website, for example pages viewed, links clicked, and how long you spent on each page. This helps us improve our Website to better suit user needs.

Advertising / Marketing

These cookies help us deliver targeted advertisements and measure the effectiveness of our marketing campaigns. We use tools for advertising and retargeting. These cookies may track your browsing activity across websites to serve ads relevant to your interests.


We place cookies from the third parties listed below who serve as independent data controllers of your personal data and who process such data in accordance with their respective privacy notices: 


  • Google LLC (Analytics and Advertising). We use Google Analytics for audience and usage analytics, and Google Ads for advertising and marketing purposes, including retargeting purposes. For more information about how Google collects information and how you can control such use, see: https://policies.google.com/technologies/partner-sites?hl=en-US.


  • HubSpot, Inc. (Marketing Automation, and Analytics). We use HubSpot for marketing automation and website analytics and visitor behavior tracking. For more information about how HubSpot collects information and how you can control such use, see: https://legal.hubspot.com/privacy-policy.


  • LinkedIn Corporation (Advertising and Analytics). We use LinkedIn Insight Tag for advertising and audience analytics purposes. For more information about how LinkedIn collects information and how you can control such use, see: https://www.linkedin.com/legal/privacy-policy.


  1. Visitors to Our Social Media Pages. When you engage with our social media outlets (for example, when you post on our Facebook or LinkedIn pages, like our posts, or comment), we collect the personal data you provide, such as the content of your post and information available to us through your profile or account. The social media companies we use may also provide us with aggregate and analytical information about activity relating to us.


How We Use this Data: We may use this information to engage with you or respond to your posts and comments, and to analyze the effectiveness of our social media efforts and to improve how we manage them.


Legal Basis: When we process your personal data to engage with you or respond to your posts and comments, we do so on the basis of our legitimate interests to engage with and serve our audiences in an effective manner. When we process your personal data to improve our social media outlets, we do so based on our legitimate interests to improve our services and develop new ones.


  1. Business Contacts


  1. Existing Customers and Partners. If you are a contact person of an existing customer or partner, we process certain business contact information about you, including your name, email, phone number and position with such customer or partner.


How We Use this Data: We use this data to communicate with you, manage our relationship with the relevant customer or partner, including to provide and administer our Services, manage contracts and related communications, provide customer support, handle billing and account administration, maintain our records, and for our internal administrative purposes.


Legal Basis: When we process this data for entering into the contract with the applicable customer or partner or to provide the Services, we do so in performance of a contract or to take steps at the request of the relevant customer or partner prior to entering into a contract. Where we process such data for internal administrative purposes, recordkeeping, customer support, and to maintain the security of our systems and prevent fraud, we do so on the basis of our legitimate interests to maintain our business and assets.


  1. Prospective Customers and Partners. If you are a contact person of a prospective customer or partner, we may process your business contact information, including your name, email, phone number, position with such prospective customer or partner. We may also obtain enrichment data about you and your organization from third-party data providers (such as business intelligence platforms, lead generation services, and professional networking sites) to help us identify potential business opportunities, qualify leads, and personalize our outreach.


How We Use this Data: We use this data to identify and evaluate potential business relationships, conduct sales and marketing outreach, present our Services, respond to inquiries, and maintain records of our business development activities.


Legal Basis: When we process this data for entering into the contract with the applicable customer or partner, we do so in performance of a contract or to take steps at the request of the relevant customer or partner prior to entering into a contract. When we process for other purposes, we do so on the basis of our legitimate interests to grow our business, identify potential customers and partners, and market our Services. Where required by applicable law for sending marketing communications, we will do so based on your consent, and you may withdraw your consent or opt-out at any time by contacting us at the details provided in this Privacy Notice.


  1. Platform Users. If you are a Platform User, we process the following information from and about you. 


  1. Registration Data – In order to access our Platform, we will create an account for you. For creating an account, you will be asked to provide your name and email address. If you access our Platform using a third-party login service (such as Google or Apple), we may receive additional personal data about you from that service, subject to its privacy notice.


How We Use this Data: We use your registration information to allow you to access our platform, save your preferences, protect the security of our platform, prevent fraud, and address any issues that arise. We use your contact details to communicate with you about our platform.       


Legal Basis: When we process your registration data to provide you with our services, we do so to perform a contract with you, in this case our agreement with the Publisher on whose behalf you access our platform. When we process your registration data to maintain our platform, including to prevent fraud, protect the security of and/or address issues with our platform, we do so on the basis of our legitimate interest to maintain our assets. 


  1. Activity and System Data (Including Cookies) – When you use our platform, we automatically collect data about your computer or mobile device, including personal data such as your IP address, usage data, metadata, and your activity on our platform (e.g. log information, session duration, and reports generated). 


How We Use this Data: We use this data to (i) provide you with our platform and maintain our platform, including security, fraud prevention and addressing problems, and (ii) generate aggregated analytics data about the use of our platform so we can maintain and improve the platform and develop new products or services. 


Legal Basis: When we process this data to provide you with our services, we do so to perform a contract with you, in this case, our agreement with the Publisher on whose behalf you access our platform. When we process this data to maintain our platform and improve it or develop new products and services, we do so on the basis of our legitimate interest to maintain and improve our assets.


  1. End-Users of Publisher Digital Assets. When End-Users visit or engage with Publisher Digital Assets where our Services are implemented, we collect certain personal data through cookies and similar tracking technologies (including pixels, web beacons, and local storage), either through our technology, the Publisher and/or Partners whom Publisher has permitted, as further detailed below. Such data includes:

  • Identifiers: Cookie IDs, vendor IDs, device IDs, and other online identifiers;

  • Technical Information: IP address, browser type and version, device type, operating system, screen resolution, and user agent string;

  • Consent Data: TCF (Transparency and Consent Framework) consent strings;

  • Usage and Interaction Data: Pages viewed, content accessed, time spent on pages, clicks, scrolling behavior, ad impressions, ad interactions, and referral URLs;

  • Inferred Data: Preferences, interests, audience segments, behavioral patterns, and assessments of your likelihood to engage with or respond to advertisements, all derived from the data collected above.

Note that Publishers may occasionally transmit location data (such as latitude/longitude coordinates) to us. We do not request or use such location data, and we discard it promptly upon becoming aware of its receipt


How We Use this Data: We use this data to: (i) facilitate real-time auctioning of ad inventory to advertisers and their platforms, including by matching End-Users across sessions for frequency capping (limiting how often you see the same ad), attribution (measuring ad effectiveness) and to identify End-User interests to match relevant advertisements; (ii) detect and filter bot traffic, invalid traffic or other fraudulent or malicious activities, to protect our interests and assets and those of our Publishers and Partners; and (iii) derive aggregated and anonymized based on the foregoing data to analyze trends and insights, to improve ad delivery and optimize our Services.


Legal Basis: When we process End-User data to provide advertisements to you, we do so based on your consent, as obtained by the relevant Publisher. You can withdraw your consent at any time through the applicable Publisher and/or Publisher Digital Asset. When we process End-User data for fraud detection, security purposes, and service optimization, we do so on the basis of our legitimate interests to maintain and improve our Services, and to maintain the integrity of our, the Publishers’ and the Partners’ assets. 


Sharing End-User Data: In the digital advertising ecosystem, End-User data flows between multiple parties to facilitate real-time advertising. When an End-User visits a Publisher Digital Asset where our Services are implemented, we collect End-User data (as described above) and share it with Partners and participants in the real-time bidding (RTB) process. This includes supply-side platforms (SSPs) that represent Publishers’ ad inventory, demand-side platforms (DSPs) that represent advertisers’ buying interests, ad exchanges that facilitate the auction process, and ultimately advertisers and their advertising agencies who bid on and purchase ad placements. We also share End-User data with our Partners who provide data enrichment services (such as adding demographic or interest-based insights to user profiles), identity synchronization services (to match user identifiers across different platforms for consistent ad experiences), and advertising technology solutions that support ad delivery and measurement. Each of these parties acts as a controller of End-User data and processes such data in accordance with their respective privacy notice and applicable legal requirements.


Cookies: Identifiers, Usage and Interaction Data and Inferred Data as well other data is derived from cookies. A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a sort of tag, letting the website know that it’s you (really, your device) that’s visiting. There are other technologies that act similarly, like web beacons and pixel tags, but for simplicity’s sake we’ll refer to them all as “cookies“. Websites and applications can place their own cookies (called “first-party cookies“) but can also place cookies from other sites (called “third-party cookies“). If your browser holds both first and third-party cookies for a given website, both the website and the third party are notified when you visit the site. 


Most web browsers are initially configured to accept cookies, but you can change the settings so your browser refuses all cookies or certain types of cookies. In addition, you are free to delete any existing cookies at any time. By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. This means that you won’t be shown ads that relate to your browsing activities. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device. Adjusting your preferences does not mean you will no longer receive ads, it only means the ads that you do see can be less relevant to your interests.


  1. Sharing the Personal Data We Collect. We share your personal data as follows:


  1. Affiliates. We share your personal data, with our wholly owned subsidiary, Dream Ad S.A., with its main place of business at Avenida Samuel Lewis y calle 58 Torre ADR, Piso 8 Torre ADR, Piso 8 Panama Panama 0816-05159 Panama , where this is necessary to provide you with our products and services and/or fulfil the purposes stated above, and so that we can manage our business, such as to keep updated records.


  1. Publishers. If you are a Platform User, accessing our platform on behalf of a Publisher, that Publisher may have access to information about your use of our platform. 


  1. Service Providers. Below is a list of the types of service providers we use, the service each provides, and the types of data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct. 


Type of Service

Description

Personal Data Shared

Cloud Computing

We use service providers that offer cloud computing services. They offer us space on their servers for us to store our files and programs, including your personal data. 

All types of data.

Email/Communication Providers

We use email and communications infrastructure providers to deliver emails and facilitate communications with you.

Contact details and communications content and metadata.

Customer Relationship Management (CRM)

We use an external CRM tool to help us keep track of our customers and information related to them, including their personal data. 

Customer Business Contact Data and Platform Users registration data.

Analytics Providers

We use a service provider to assist us with analytics services.

Website visitors’ data.


  1. Change of Ownership. If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice.


  1. Law Enforcement Related Disclosure. We may share your personal data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of our contractual relationships and this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements. 


  1. International Transfers. Some of our service providers and additional controllers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.


  1. If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area (“EEA“), we will ensure that such transfers are made in accordance with applicable law. 


  1. When we transfer your personal data to Israel or Argentina, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection. 


  1. When we transfer your personal data to entities in the US that are covered under the Data Privacy Framework (DPF), we rely on the decision by the European Commission that determines that these entities are considered to provide an adequate level of data protection.


  1. Where we transfer your personal data to other countries or to entities not covered by the DPF, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses. 


  1. Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA. 

 

  1. Security. The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. For further details about the security measures we employ please see our Security Policy, available at https://onlinemediasolutions.com/security/.


  1. Your Rights – How to Control Our Use of Your Personal Data. Depending on which laws apply, you have certain legal rights over your data. Below is some general information about rights that may apply to you but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at [email protected]. If you want to exercise your rights regarding your personal data held by other controllers, such as Publishers and Partners, you can contact the applicable controller directly. We may ask for reasonable evidence to verify your identity before we can comply with any request. 


  1. Right of Access. You may have a right to know what personal data we collect about you. We may charge you with a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your personal data is subject to GDPR.


  1. Right to Correct Personal Data. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16 of the GDPR for more details, if your personal data is subject to GDPR.


  1. Deletion of Personal Data (“Right to Be Forgotten”). If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your personal data is subject to GDPR.


  1. Right to Restrict Processing. If you are located in the EU, you may have the right to ask us to stop processing your personal data. See Article 18 of the GDPR for more details, if your personal data is subject to GDPR.


  1. Right to Data Portability. If you are located in the EU, you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly-used, and machine-readable format. See Article 20 of the GDPR for more details, if your personal data is subject to GDPR.


  1. Right to Object. If you are located in the EU, you may have the right object to certain processing activities. See Article 21 of the GDPR for more details, if your personal data is subject to GDPR.


  1. Withdrawal of Consent. If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won’t affect processing we have done from before you withdrew your consent.


  1. Right to Lodge a Complaint with Your Local Data Protection Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.


  1. Your Rights Under the CCPA. Please note that the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), may not apply to us based on our current business operations and the applicable statutory thresholds. Nevertheless, as a matter of good faith and our commitment to transparency, we voluntarily provide California residents with the rights and disclosures described in Annex A to this Privacy Notice. Nothing in this section or in Annex A shall be construed as an admission that the CCPA applies to us.


  1. Your Rights Under Israeli law.  If you are subject to Israeli law, you may request to access any personal data you have provided to us and request that such personal data be corrected, updated, or deleted, including in accordance with Articles 13 through 14 of the Israeli Privacy Protection Law, 1981. You may exercise such rights by emailing us at [email protected]. You may have the right to delete your personal data subject to and in accordance with Article 3 of the Israeli Privacy Protection Regulations (Provisions Regarding Information Transferred to Israel from the European Economic Area), 2023.


  1. Data Retention

    1. We retain your personal data as long as necessary to fulfill each of the purposes we described above. When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which the personal data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business’s retention policy. 


  1. In some circumstances, we may store your personal data even after we’re finished using it if required to do so by law (e.g. to fulfill tax or audit requirements), or to keep accurate records of our interactions in case there is a prospect of litigation relating to your personal data. In such cases, we will maintain the same security measures as described above.


  1. In furtherance of our data minimization principles, we generally delete or anonymize End-User personal data on approximately thirty (30) day cycles, unless longer retention is necessary for the purposes described in this Privacy Notice or as required by applicable law, or unless the relevant End-User has engaged in further consent-based actions, in which case such cycles renews.


  1. Please contact us at [email protected] if you would like details about the retention periods for each type of personal data we process.


  1. Third-Party Services. You may have access to third-party services through our services. Please note that all use of third-party services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.

 

  1. Children. We do not knowingly collect nor transfer personal data from/of children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has registered to our Services without parental permission, please advise us immediately. 


  1. Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version.






Annex A 


Your Rights Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA)


If you are a resident of the State of California, depending on the applicability of certain laws and exemptions, you may have certain rights over your data. Below is some general information about rights that may apply to you. We recommend that you check the law or consult with a lawyer to understand what applies in your specific case. We may ask for reasonable evidence to verify your identity or to verify that you have been authorized to act on behalf of the relevant individual. For the purposes of this section, “personal data” shall have the meaning of  “Personal Information” as defined under the CCPA. 


Please note that the CCPA may not apply to us based on our current business operations and the applicable statutory thresholds. Nevertheless, as a matter of good faith and our commitment to transparency, we voluntarily provide California residents with the rights and disclosures described in this Annex A. Nothing in this Annex A shall be construed as an admission that the CCPA applies to us.


  1. Right to Know. You have the right to request that we disclose to you any or all of the following in respect of the 12-month period preceding your request: 


  • The specific personal data we have collected about you. 

  • The categories of personal data we have collected about you. 

  • The categories of sources from which we collected the personal data about you. 

  • The categories of third parties to whom we disclose personal data about you. 

  • The categories of personal data about you we have sold and the categories of third parties to whom we have sold such personal data.

  • The categories of personal data about you we have disclosed for a business purpose and the categories of third parties to whom we have disclosed such personal data. 

  • Our business or commercial purpose(s) for collecting or selling your personal data. 


  1. Right to Delete. Subject to certain exceptions, you have the right to request that we or any of our service providers delete your personal data.


  1. Right to Correct. You have the right to request that we correct any inaccurate personal data that we maintain about you, considering the nature of the personal data and the purposes of the processing of the personal data.


  1. Right to Opt-Out of the Sale or Sharing of Personal Data. If you are 16 years of age or older or have consented to the sale of your personal data, you have the right to direct that we do not sell or share your personal data at any time. You may change your mind and opt back into the sale of your personal data at any time by contacting us. We may deny any request to opt-out of the sale of personal data that we deem in our good-faith, reasonable and documented belief is fraudulent.


  1. Right to Limit Use and Disclosure of Sensitive Personal Data. To the extent we collect any sensitive personal data about you, you have the right to instruct us to limit our use of such personal data only to for the purpose of providing you with our services and certain business operation purposes.   


  1. Right to Non-Discrimination for Exercising your Consumer Privacy Rights. You have the right not to be discriminated against for exercising any of your consumer privacy rights, such as, not being denied any goods or services or charged different prices or rates.


  1. How to Exercise your California Privacy Rights


  • Contact Information. To exercise any of the rights detailed above, please submit a verifiable request to us by contacting us at [email protected]. You may only request to exercise your right of access twice within a 12-month period.


  • Submitting a Verifiable Request. In order to exercise your right to know or right to delete you must submit a request containing sufficient information that allows us to reasonably verify you are the person about whom we collected the applicable Personal Data or an authorized agent of such person, which may include details relating to your account. Any requests made through your password protected account will be verified through our existing authentication procedures for such an account. 


  • Submitting Requests through an Authorized Agent. An authorized agent may exercise requests on your behalf. In order to exercise your right to know or right to delete through an agent, we may ask for reasonable evidence to verify your identity and the agent’s identity, and written authorization permitting the agent to act on your behalf before complying with your request. In order to submit a request to opt-out of the sale of your personal data through an agent, we may ask for written authorization permitting the authorized agent to act on your behalf before complying with your request. We reserve the right to deny the request of any agent that does not provide proof that they have been authorized to act on behalf of the applicable consumer in accordance with applicable law. 


  1. The Past 12 Months. In the past 12 months we have not “sold” nor “shared” (as such terms are defined in the CCPA) any personal data about you. In the past 12 months, we have disclosed the following categories of personal data for a “business purpose” (as defined in the CCPA), all as specifically detailed in Section 2 of the Privacy Notice: 

    1. Category A: Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

    2. Category B: Any personal information described in subdivision (e) of Section 1798.80, such as his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

    3. Category D: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    4. Category F: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

    5. Category I: Professional or employment-related information.

    6. Category K: Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    7. Category L: Sensitive personal information, such as a consumer’s account log-in, access code, password, or credentials allowing access to an account.