Mitsubishi HC Capital America, Inc. and all of its subsidiaries, affiliates, and divisions, including Mitsubishi HC Capital Canada, Inc., Mitsubishi HC Capital Canada Leasing, Inc. (collectively, the “Company”, “we”, “us” or “our”) respect and value customer privacy, and we work to earn the trust that you put in MHCA. This privacy policy (the “Privacy Policy”) explains how we handle and protect personal information in connection with our business activities in North America, including our financial commercial products and services (the “Services”) and our websites and mobile applications (the “Sites”). It also describes the rights and choices you have regarding your personal information. 

Please read this Privacy Policy carefully. If you have any questions regarding this Privacy Policy, please email our Data Privacy Officer at [email protected]. If you do not agree with this Privacy Policy, you should not use our Sites or Services or otherwise provide us with your information.

1. What personal Information do we collect?
2. How Do We Collect Personal Information?
3. How Do We Use Personal Information?
4. We Disclose Personal Information for a Business Purpose
5. Cookies And Tracking Technologies
6. Data Security and Protection of Personal Information
7. International Transfers and Retention of Personal Information
8. Privacy of Children
9. Third-Party Services
10. Your Privacy Rights
11. Text Messaging
12. Changes and Updates to this Policy
13. Contact Us
14. Jurisdiction Specific Provisions
      Additional Disclosures for Quebec Residents 
      Additional Disclosures for California, Nebraska, and Texas Residents

1. WHAT PERSONAL INFORMATION DO WE COLLECT?
“Personal information” is information that identifies you as an individual or relates to an identifiable individual. Depending on your interactions with us and your use of our Services and Sites, we and our service providers may collect personal information such as: 

• Identifiers, customer records information, and protected class information: such as your name, email address, mailing address, telephone numbers, date of birth, social insurance number (SIN) in Canada and Social Security Number (SSN) in the US, driver’s license number, signature, health insurance card (Quebec) and other information you provide to us when you contact us or open an account with us, log in to your account on our Sites, and other information that we may need to provide you with our Services (such as citizenship, marital status, gender, education history, employment history, income, tax returns, information about your guarantors). In the US, this may also include characteristics of protected classes under state or federal law (such as sex, disability, citizenship, primary language, immigration status, and marital status).
• Transactional information: such as details about your purchase or use of our Services and your payment information (including your credit or debit card details, account numbers).
• Commercial information: such as your company identification number, business records of your company, insurance information, property records, financial records including assets and liabilities. This may include purchase information, such as products and services obtained and transaction histories.
• Equipment information: such as description of the vehicles/equipment you own or operate, make, model, year, colour license plate number and engine type (fuel, hybrid, electric, etc.) related to your use of our Services.
• Marketing information: such as your preferences for receiving promotional communications about our Services, including inferences based on details about how you engage with our communications and advertisements, such as your preferences and interests.
• Internet or other electronic network activity information: (i.e., technical information when you access or use our Sites), such as your IP address, device ID, browser type, operating system, device type, data about the pages you access on our Sites or the functionalities used on our Sites, language preferences, email bounce backs, click-throughs, general geographic information, and clickstream data.
• Biometric information: We may also provide you the option to voluntarily participate in transaction facilitation and security programs that use biometric information. You should review the specific details of such programs and review the program descriptions of the collection, use, disclosure, and retention of biometric information when considering whether to participate in these programs.
• Geolocation and telematics data: We may collect, use, and store data generated by, collected by, or stored in your equipment or any hardware or device interfacing with your equipment and derived from your use of our services or devices, including GPS coordinates, movement patterns, speed, vehicle diagnostics, and other related data. This information may be collected in real time and used to provide location-based services, enhance user experience, conduct analytics, and support operational and business purposes.
• Audio/video Data: such as audio, electronic, visual and similar information, such as photographs and call and video recordings.
• Education information: when you apply for a career opportunity, we may collect information subject to the federal Family Educational Rights and Privacy Act, such as student transcripts and grades.
• Professional and employment-related information: such as information you submit to us when applying for a career opportunity, which may include your education and employment history, your resume, letters of reference, reference, and any additional information provided by you in an application form or correspondence. We may use service providers, such as human resources and payroll service providers, to collect this category of information.
• Inferences: We may collect inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences or characteristics.
• Sensitive personal information: such as Social Security, driver's license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; health data; contents of mail, email, and text messages unless the Company is the intended recipient of the communication; and biometric information processed for the purpose of uniquely identifying an individual; personal information of a known child under 16.
• Other information: any other information that you or another person or organization on your behalf provides to us.

2. HOW DO WE COLLECT PERSONAL INFORMATION?
We and our service providers collect the personal information listed above directly and indirectly from the following sources: 

• Directly from you: for example, when you open a customer account and register with us for our Services, including when you update the information in your account when you log in on the Sites; purchase or use our Services, including when you wish to purchase equipment on the “Marketplace” section of our Sites; subscribe to receive our marketing emails; and contact, correspond or otherwise communicate with us, including when you request customer support, make an inquiry or complaint, dispute or pay a payment statement, or report an incident or problem with our Services. If you provide the Company the personal information of another individual, then you must take all measures, including obtaining the individual’s consent, to ensure that you have the lawful right to collect and communicate the information to the Company and for the Company to collect, use, communicate and retain the personal information in accordance with this Privacy Policy.
• From agents, partners, brokers or other persons and organizations: for example, information provided in an application for financing or provided to them in the course of providing their services to you, including when you authorize them to provide us with your personal information or as otherwise permitted by law.
• From applications for employment: for example, when you submit an application on the “Careers” page of our Sites or by any other channel.
• Automatically from your device: for example, certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services and Sites you are using. We use this information to ensure that the Services and Sites function properly.
• From a visit to or activity on our Sites or our communications and advertisement: for example, our Sites, email messages and advertisements may use first and third-party technologies (e.g., cookies, web beacons, tokens, pixels or tags, analytics engines) to automatically collect information about your access to and use of our Sites and your actions regarding email messages and advertisements. For more information about the technologies we use and how you can manage your choices, see MHCA Cookie Policy and the “Cookies and Tracking Technologies” section.
• From independent or public sources: for example, we may collect information from government agencies and other third-party sources of information about registered owners of equipment; organizations that perform background checks on job applicants; and publicly available information, such as social media. 

3. HOW DO WE USE PERSONAL INFORMATION?
We may use the personal information we collect for one or more of the following purposes:

• For general business purposes relating to or arising from our relationship and dealings with you and to your use of our Services and Sites: for example, we use information provided to us on an application for a financial product or when you wish to purchase or finance equipment, to determine your eligibility to our Services; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections and other documents and information regarding your use of our Services and as otherwise required by contractual or legal obligations; to create and manage your account with us and providing you with information and documents about your account; to process and respond to your inquiries, requests and other communications (including to process your career application and take a decision on that request).
• To aggregate, de-identify, and/or anonymize personal information: for example, we may aggregate, deidentify, and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
• To improve our business, our Services, and our Sites: for example, we may use your information to improve our Services and our Sites; for testing, research, analysis and product development; to understand and analyze your use of our Services and develop new services. We may use de-identified information for those purposes, so that this information does not identify you directly. We may record phone conversations with clients for the purposes of quality assurance and training.
• For personalization and marketing purposes: for example, we may use your information to better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests; to determine the effectiveness of our promotional campaigns; to provide you with marketing materials (including by email and other electronic messages) regarding the Company and its Services that might be of interest to you; to provide you with customized information, offers and promotions regarding our Services.
• For legal and compliance purposes: for example, we may use your information as necessary to comply with, and assessing compliance with, applicable laws, contractual and legal obligations, and our internal policies and procedures; to prevent, detect and investigate fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; to protect and enforce our legal rights, interests and remedies and protect the business, operations and customers of the Company or other persons and organizations. In certain cases, we use automated systems and record your voice to obtain and document your verbal consent. These recordings are used strictly for the purposes of verifying your identity, documenting consent, and fulfilling our regulatory and service obligations. Your consent will be requested verbally at the beginning of the call, and the recording of that consent will be kept as proof.
• Allowing you to participate in sweepstakes, contests, or other promotions: For example, we may offer you the opportunity to participate in a sweepstakes, contest, or other promotion. Some of these promotions have additional rules containing information about how we will use and disclose your personal information.  Please read those additional rules before choosing to participate.
• Other: we may also use your information as otherwise required or permitted by applicable laws. 

4. WE DISCLOSE PERSONAL INFORMATION FOR A BUSINESS PURPOSE
The Company may disclose your personal information for the different purposes detailed below.  

The Company may disclose and transfer your personal information to our affiliates and service providers (i.e., organizations that provide services to the Company) to assist us to use your personal information as explained in this Privacy Policy and as otherwise permitted by and in accordance with applicable laws, including to help us in the following categories:

• operate our business;
• provide our Services to you;
• provide, operate and maintain our information technology systems and services;
• operate our Sites;
• process payments and complete transactions;
• detect and deter fraud;
• provide customer care services;
• enforce and collect payment of receivables;
• conduct promotions, sweepstakes, contests, surveys and other marketing activities and events;
• collect and analyze data; and
• manage job application requests. 

Our service providers may be located outside the United States or Canada, as explained in the “International Transfers and Retention of Personal Information” section. 

The Company may also disclose your personal information as required or authorized by applicable laws, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. We may also communicate your personal information to law enforcement agencies or other independent organizations if we reasonably believe the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance (including tax and regulatory compliance), or if we reasonably believe the disclosure is necessary or appropriate to protect and enforce the Company’s legal rights, interests and remedies or to protect the rights, interests, business, operations or clients of the Company or other persons and organizations, including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service or other agreements that govern your use of our Services and our Sites. 

The Company may also use and transfer your personal information in connection with a proposed or actual business transaction in which the Company is involved (e.g., a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of the Company’s business or assets). However, we will only disclose your personal information to the extent reasonably necessary for each transaction and in accordance with applicable laws. 

5. COOKIES AND TRACKING TECHNOLOGIES
We and our service providers use various technologies, including cookies, pixels, and web beacons, and similar online tracking technologies (collectively, “cookies”) to collect information about you when you interact with our Sites and Services, including information about your browsing behavior and user experience. First and third-party cookies allow us to collect such information as browser type, time spent on the Sites and Services, pages visited, language preferences, unique identifiers, content you view, click on, or share, screen actions, and other traffic data.  

We and our service providers use the information for security purposes, to power the interactive features of our Sites and Services, to facilitate navigation, to display information more effectively, to personalize your experience, to develop and improve the performance, functionality, and design of the Sites and Services, for advertising, and to help keep the Sites and Services free of bugs or errors. We also gather statistical information about use of the Sites and Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies are also used to track the actions of users of the Sites and Services (including email recipients), conduct advertising, measure the success of our marketing campaigns, and compile statistics about usage of the Sites and Services and response rates.  

Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Sites. We may also use cookies in online advertising to track responses to our ads. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com. 

If you do not accept cookies, however, you may not be able to use all functionality of our Sites, or our Sites might not work properly. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. 

Analytics.  We use Google Analytics to help us understand the use of our websites and mobile applications. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en. 

6. DATA SECURITY AND PROTECTION OF PERSONAL INFORMATION
All personal, private and confidential data is protected in compliance with the Company’s code of conduct, information security policy and internal control procedures. 

The Company uses reasonable safeguards appropriate to the sensitivity and amount of personal information under the Company’s legal control, to the purposes for which it is used and the format in which it is stored, we use a combination of measures – including administrative, physical and technical security and safeguarding measures – to help protect the security of the personal information 

Please remember that transmission of information via the Internet may not be secure. Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of information about you. 

7. INTERNATIONAL TRANSFERS AND RETENTION OF PERSONAL INFORMATION
As a North American organization, we may collect, process, and store personal information on servers located in the United States and Canada. Personal information collected from individuals residing in Canada, including Québec, may be transferred to or accessed by entities in other jurisdictions, including the U.S., where data protection laws may differ from those in Canada or Québec. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside and might permit the government, government agencies, courts, law enforcement agencies and security authorities in those countries to access your personal information without notice. Similarly, if you are accessing our services from outside the U.S. or Canada, please be aware that your information may be transferred to, processed, stored, and used in these and other jurisdictions.  

To see our policy on human rights, click here. 

We retain personal information, including sensitive information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:   

• The length of time we have an ongoing relationship with you and provide Services to you, for example, for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
• Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; or
• Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations. 

8. PRIVACY OF CHILDREN
Our Site and our Services are not directed to individuals under the age of 18. In compliance with laws in the Unites States (including U.S. Children’s Privacy Protection Act, or “COPPA”) and Canada, we do not knowingly collect personal information from children under the age of 18 and we do not knowingly sell or disclose personal information of children under the age of 18. Please contact the Company’s Data Privacy Officer using the “Contact Us” information below if you reasonably believe that someone under the age of 18 has provided MHCCNA with personal information. 

9. THIRD-PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services or Sites link. The inclusion of a link on the Services or Sites does not imply endorsement of the linked site or service by us or by our affiliates. 

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, X (formerly known as Twitter), Instagram, YouTube, Pinterest, LinkedIn, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our mobile applications. 

10. YOUR PRIVACY RIGHTS 
Depending on your jurisdiction and applicable laws, you may have the following privacy rights: 

• The right to request access to and review the information we have about you and to update your personal information by logging your account profile page on the Sites or by sending us an email at [email protected] to request access to or correction of your personal information.
• The right to withdraw your consent to our collection, use and sharing of personal information in accordance with this Privacy Policy at any time, subject to contractual and legal restrictions and reasonable prior written notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide you with certain Services. In some circumstances, legal requirements may prevent you from withdrawing your consent. 

The Company respects your right to make your own choices about how your personal information is handled. Should you choose to unsubscribe to promotional emailing lists or any registrations, you can opt-out by following the “unsubscribe” link in any email or by contacting us at the information provided in the “Contact Us” section. It may take several days for us to register a change of preference across all our systems. Please note that you cannot opt-out of non-promotional communications, such as those about your transactions, servicing, or our ongoing business relations. 

If you prefer that we discontinue sharing your personal information on a going-forward basis with third parties for their direct marketing purposes, you may opt out of this sharing by contacting us at the information provided in the “Contact Us” section.  

If you are a resident of California, Nebraska, or Texas, in the United States, or Quebec in Canada, please see the section at the end of this Privacy Policy entitled “Jurisdiction Specific Provisions” for further information on your privacy rights and choices. 

11. TEXT MESSAGING 
CONSENT TO RECEIVE MESSAGES 

We may offer text messages (such as SMS, MMS or successor protocols or technologies, collectively “Text Messages”) as a communications option for important updates, alerts, and information related to your account, services, or inquiries. "Opting In," refers to requesting, joining, agreeing to, enrolling in, signing up for, acknowledging, responding to, or otherwise consenting to receive one or more text messages. By Opting In, you expressly consent to receive Text Messages (including autodialed messages) even if your mobile number is registered on a state or federal “do not call” list, and you agree to this privacy policy, these Text Messages Terms of Use, and to the use of an electronic record to document your agreement. 

TYPES OF TEXT MESSAGES
The types of Text Messages we send may include: 

- Account notifications
- Transaction alerts 
- Service updates 
- Promotional or marketing content (only if you opt in separately). Please note that you are not required to opt In to receive promotional or marketing content as a condition of purchasing any goods or services. 
Message frequency may vary depending on your interactions with us. 

MESSAGE AND DATA RATES
We do not charge you for the messages you send and receive via this text message service. Depending on your mobile carrier and plan, message and data rates may apply. Please check with your wireless provider for details. 

SUPPORTED CARRIERS 
Our Text Messages service is supported by most major U.S. and Canadian carriers. However, delivery is not guaranteed and may be affected by your carrier’s network availability. 

ELIGIBILITY
You must be at least 18 years old and the authorized user of the mobile number provided to opt in to our Text Messages services. 

OPTING OUT OF TEXT MESSAGES
If you no longer want to receive text messages, you may reply to any text message with STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, or UNSUBSCRIBE. As a person-to-person communication service, opt-out requests are specific to each conversation between you and one of our employees and their associated phone number. After unsubscribing, we may send you confirmation of your opt-out via text message. 

TEXT MESSAGING HELP AND SUPPORT
For help, reply “HELP” to any message or contact our customer service team at 1-855-840-1298 (Canada) or 1-800-680-3002 (US).

12. CHANGES AND UPDATES TO THIS POLICY
The Company reserves the right to modify or amend this Privacy Policy from time to time to reflect applicable laws or regulations, or changes to our practices or procedures. We will post each revised Privacy Policy on our Sites and will provide additional notice of changes to this Privacy Policy as required by applicable laws, including for example the email address you provided us. 

All changes to this Privacy Policy will be effective when we post the revised Privacy Policy on our Sites. The Company’s collection, use, communication, and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. 

It is your responsibility to ensure that you read and understand the latest version of this Privacy Policy. The “Last Updated” date of this Privacy Policy is the date of the last revision. 

13. CONTACT US
We welcome your inquiries or comments about this Policy and any queries, concerns or complaints about how the Company handles your personal information, or if you wish to exercise any of your privacy rights, please contact the Company’s Data Privacy Officer via email at [email protected], by phone 1-888-374-7132 or by mail as follows: 

14. JURISDICTION SPECIFIC PROVISIONS
ADDITIONAL DISCLOSURES FOR QUEBEC RESIDENTS
The Company uses reasonable safeguards appropriate to the sensitivity and amount of personal information under the Company’s legal control, to the purposes for which it is used and the format in which it is stored, we use a combination of measures – including administrative, physical and technical security, including: 

• A privacy framework governing the protection of personal information through its lifecycle.
• Internal policies and procedures that define the roles and responsibilities of the Company’s personnel regarding the handling of personal information.
• Technical safeguards, such as encryption, firewalls, passwords and antivirus software, to protect personal information collected, used or stored in electronic format.
• A designated Data Privacy Officer accountable for the Company’s compliance with applicable privacy laws.
• Employee privacy and data security training.
• Procedures for receiving, investigating and responding to complaints or inquiries regarding the Company’s information handling practices.
• Contractual provisions and other measures to require our service providers with whom we share personal information to maintain adequate privacy protections and standards. 

In accordance with Quebec’s Act Respecting the protection of personal information in the private sector, as amended by An Act to modernize legislative provisions as regards the protection of personal information, (the “Quebec Privacy Act”), individuals residing in Quebec benefit from additional rights. This section outlines the rights you have regarding your personal information, as well as how to exercise it.  

As a Quebec resident, you have the following rights regarding your personal information:  

• Right of access: You may request access to the personal information we hold about you.
• Additional Information: you may request not only the information that was provided to the Company at the time of collection but also additional information, such as the categories of people who have access to your personal information within the Company, the applicable retention period, and the contact information of the Privacy Officer. If your personal information was collected from a third person, you may similarly request to be informed of the source of the information unless the information was collected for an inquiry to prevent, detect or repress a crime or statutory offence.
• Right to rectification: You may request correction of inaccurate, incomplete, or equivocal personal information.
• Right to withdraw consent: You may withdraw your consent to the use or disclosure of your personal information at any time, subject to legal or contractual restrictions.
• Right to data portability: You may request that your personal information be communicated to you in a commonly used technological format. However, this information must have been collected from you. Please note that created or inferred information is excluded from the right to portability, as it has not been collected directly or indirectly from you. Rather, it is generated through analysis, observation, or obtained through algorithms and correlations. Similarly, computerized personal information that a public body or company obtains from third parties is excluded from the right to portability. The disclosure of your personal information in a structured and commonly used technological format must not cause serious practical difficulties for the organization.  

How to Exercise Your Rights 
You may exercise any of your rights by sending a written request to our Data Privacy Officer at the contact information below:  

Email: [email protected] 
Postal address: Mitsubishi HC Capital Canada, Inc. or Mitsubishi HC Capital Canada Leasing, Inc. 
Data Privacy Officer 
2200 Rue de la Sidbec Sud 
Trois-Rivières, Québec G8Z 4H1 – Canada 
Phone: 1-888-374-7132 

To ensure timely processing of your request, please include your full name and relevant case details. The website of Quebec’s commissioner offers tools to help you formulate your request. You can consult written request templates (French only) here. 

Please note that a request for access may also be made by a person acting as a representative, heir, or successor of the person concerned, as liquidator of the estate, as beneficiary of a life insurance policy or death benefit, or as holder of parental authority. In all cases, this person must prove their role and identity. 

Response Time 
We will respond to your request within 30 days of receiving it, in accordance with the law. If your request is complex or involves a large volume of information, this timeline may be extended by up to an additional 30 days. If so, we will notify you in writing. 

If we are unable to fulfill your request, we will provide you with written reasons for the refusal and information about your recourse options, including the right to file a complaint with the Commission d’accès à l’information du Québec (CAI). 

ADDITIONAL DISCLOSURES FOR CALIFORNIA, NEBRASKA, AND TEXAS RESIDENTS
Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), the Nebraska Data Privacy Act, and the Texas Data Privacy and Security Act, we are providing the following additional details regarding the categories of personal information about California, Nebraska, and Texas residents that we collect, use, and disclose. This section supplements the information provided above in this Privacy Policy.   

Categories of Personal Information Collected and Disclosed 

The following chart details which categories of personal information about California, Nebraska, and Texas residents we collect, as well as which categories of personal information we have collected and disclosed for our operational business purposes in the preceding 12 months. 

We do not “sell” or “share” your personal information, including your sensitive personal information, as such terms are defined under the CCPA.  We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated.  Without limiting the foregoing, we do not knowingly “sell” or “share” the personal information, including the sensitive personal information, of minors under 16 years of age.   

Purposes for the Collection, Use, and Disclosure of Sensitive Personal Information 
Subject to your consent where required by applicable law, we collect, use, and disclose sensitive personal information for purposes of: performing services on behalf of our business; providing goods or performing services as requested by you; ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising; order processing and fulfillment; servicing accounts and providing customer service; verifying customer information; processing payments; activities relating to quality and safety control or product improvement; securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure; preventing, detecting, and investigating security incidents; resisting and responding to fraud or illegal activities; and other collection and processing that is not for the purpose of inferring characteristics about an individual.  We do not use or disclose sensitive personal information for additional purposes.  

Rights and Requests 
If you are a California, Nebraska, or Texas resident, you may request:

1. To know whether we process your personal information, and to access such personal information. If you are a California resident, you may also request that we disclose to you the following information:
a. The categories of your personal information we collected and the categories of sources from which we collected your personal information; 
b. The business or commercial purpose for collecting your personal information;  
c. The categories of third parties to whom we disclosed your personal information; and 
d. The categories of your personal information that we disclosed for a business purpose, and the categories of service providers or contractors to whom we disclosed your personal information. 

2. To correct inaccuracies in your personal information. 

3. To have your personal information deleted.  

4. To receive the specific pieces of your personal information, including a copy of your personal information in a portable format. 

You have the right not to be unlawfully retaliated or discriminated against for exercising your privacy rights. 

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your personal information. If you make a deletion request, we may ask you to verify your request before we delete your personal information.  

To make a request, enter a personal information request, contact the Company’s Data Privacy Officer via email at [email protected], or call us at 1-888-374-7132. 

Authorized Agents
If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Rights and Requests” or confirm that you provided the agent permission to submit the request. 

Appeal Process  
If you are a Nebraska or Texas resident and we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal.  You may file an appeal by contacting us via [email protected]. 

De-Identified Information  
Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.