California Privacy Policy

1. PERSONAL INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”).

1.1. What is Personal Information

Personal information does not include:

• Publicly available information from government records
• De-identified or aggregated consumer information
• Information excluded from the CCPA, including:
  
  • 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;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

AS A COURTESY, SOME OF THE FOLLOWING DISCLOSURES INCLUDE INFORMATION THAT IS EXEMPT FROM CCPA. THE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CCPA.

1.2. Categories of Personal Information We Collect

We collected the following categories of personal information that may overlap across categories:

• “Sensitive Personal Information” such as Social Security numbers, driver’s license, financial account or card numbers, precise geolocation, racial and ethnic characteristics, religious and philosophical beliefs, union membership, contents of mail, email and text messages, genetic and biometric data;
• “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
• “Other Personal Information or Consumer Records” such as 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, home value, or any other financial information, or medical information. Some personal information included in this category may overlap with other categories;
• “Internet or Network Activity” such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement; and
• “Biometric Information” such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, or gait.

1.3. How We Obtain Your Personal Information:

We obtain personal information directly and indirectly from you based on activity on our website or visiting our office. For example, from submissions through our website that you submit to us, website usage details collected through our cookies and analytics tools, our business-to-business transactions and communications, or security footage. We may also obtain personal information from third parties, for example the businesses with which we do business.

1.4. How We Use Your Personal Information:

In addition to the disclosures made in our Privacy Policy, we may collect, use, retain, or disclose the personal information we collect for one or more of the following purposes:

• We only use Sensitive Personal Information to provide the goods and services requested by you; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to ensure people’s physical safety; to perform services on our behalf; to verify or maintain the quality or safety of our products, services, and devices.
• For advertising or marketing services, or receiving analytic services:
  
  • to fulfill or meet the reason for which the information is provided;
  • to provide you with information, products, or services that you request from us;
  • to provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you; and
  • to carry out our obligations and enforce our rights arising from any contracts entered into by us.
• Undertaking internal research for technological development and demonstration;
• Debugging to identify and repair errors that impair existing intended functionality;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Auditing related to a current interaction with a consumer or our customers, and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Undertaking activities to verify or maintain the quality or safety of a device that is owned, manufactured by, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us;
• For short-term, transient use, including disclosure to third parties to build a profile about consumers or to alter consumer’s online experience outside the current interaction; and
• To comply with our legal or regulatory obligations.

1.5. How Long We Retain Your Personal Information

Based on contractual requirements in our role as service provider and/or legal requirements, such as a legal hold, personal information is maintained for a specified period of time, as required by legal, regulatory, or industry requirements. Additional information such as emails and vendor agreements are maintained for business purposes.

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide services, comply with our legal obligations, resolve disputes, and enforce our agreements. The criteria used to determine our retention periods include the nature and sensitivity of the personal information, the purposes for which it is processed, applicable legal and regulatory requirements, contractual obligations, and our legitimate business needs.

For example, we retain:

• Identifiers and contact information for the duration of our relationship with the relevant individual and for a reasonable period thereafter;
• Commercial and transaction-related information for as long as necessary to complete transactions and comply with financial and tax obligations;
• Employment-related information in accordance with applicable employment and recordkeeping laws; and
• Communications for business operations, legal compliance, and recordkeeping purposes.

1.6. How We Disclose Your Personal Information

We may disclose your personal information to a service provider, contractor, or third party. When we disclose personal information to a service provider or contractor, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract or as otherwise allowed under the CCPA. We disclose personal information to third parties as follows:

• With customer service platforms, word processing, and communication applications we disclose the following categories of Personal Information: Identifiers, Other Personal Information and Consumer Records, and Internet or Network Activity.
• With shipping providers we disclose the following categories of Personal Information:  Identifiers and Other Personal Information and Consumer Records.
• With our data analytics, network monitoring services, and incident response providers, we disclose the following categories of Personal Information:  Identifiers, Other Personal Information and Consumer Records, and Internet or Network Activity.
• With our advisors such as lawyers, and consultants, we disclose the following categories of Personal Information: Identifiers, Other Personal Information and Consumer Records, Internet or Network Activity, and Biometric Information.
• With our governmental and regulatory agencies, we disclose the following categories of Personal Information: Identifiers, Other Personal Information and Consumer Records, Internet or Network Activity, and Biometric Information.
• With law enforcement, government entities, courts, and pursuant to legal process where required by law, we disclose the following categories of Personal Information: Identifiers, Other Personal Information and Consumer Records, Internet or Network Activity, and Biometric Information.

1.7.  Sale of Personal Information

We do not sell your personal information. We do not sell the personal information of minors under 16 years of age.

1.8.  Sharing of Personal Information

We do not Share your personal information. Our site is not intended for or directed to minors. We do not knowingly Share the personal information of minors under 16 years of age. (“Sharing” means the disclosure of personal information for cross-contextual behavioral advertising.)

2. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

California residents have certain rights regarding their personal information—the Right to Know, Right to Delete, Right to Correct, Right to Limit the Use of Sensitive Personal Information, Right to Opt-Out, and the Right to Non-Discrimination. This section describes your CCPA rights and explains how to exercise those rights, if applicable.

2.1. Right to Know

You may have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information. Once we receive and verify your request, unless an exemption applies, we will disclose to you:

• The categories of personal information we collected about you
• The sources for the personal information we collected about you
• Our business or commercial purpose for collecting that personal information
• The categories of third parties with whom we share that personal information
• If we disclosed your personal information for a business purpose, the categories of personal information disclosed with each category of third-party recipients

2.2.  Right to Delete

You may have the right to request that we delete any of your personal information that we collected and retained about you, subject to certain exceptions.

2.3.  Right to Correct

You may have the right to request that we correct your personal information if it is inaccurate or incomplete.

2.4.  Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the applicable law, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or services, suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

3. EXERCISING YOUR RIGHTS

3.1.  How to Submit a Request

To make a request please contact us by either:

• Calling us at 866-458-3767, select option 6
• Contact us at Veros Online Web Form

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a Request to Know twice within a 12-month period.

A request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  
  • Depending on the nature of your request, we may require additional information to verify your identity or authority to make the request, including, for requests for specific pieces of personal information, a signed declaration under penalty of perjury confirming you are the consumer whose personal information is the subject of the request.

3.2.  Authorized Agents

Before we can respond to any request submitted by an authorized agent, we need to verify that person or entity’s authority to act on your behalf and the identity of the authorized agent.

If you are authorized to submit a request on behalf of a California resident, please email us at privacy@veros.com or call us at 866-458-3767 (option 6).

We may require the authorized agent to provide documentation demonstrating that they are authorized to act on your behalf, such as a signed permission from the consumer or a valid power of attorney. We may also require the consumer to verify their identity directly with us or to confirm that they provided the authorized agent permission to submit the request.

Depending on the nature of the request, we may request additional information from the authorized agent or the consumer as necessary to verify the request in a manner consistent with applicable law.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

3.3.  Response Timing and Delivery Method:

We will acknowledge receipt of your request within 10 business days of its receipt. We will respond to a verifiable request within 45 days of its receipt. If we require more time (up to 45 additional days for a total of 90 days from receipt of the request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your 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.

4. CHANGES TO THESE CALIFORNIA DISCLOSURES AND PRIVACY POLICY

We reserve the right to amend this California Privacy Policy at our discretion and at any time. If we make material changes to this privacy policy, we will post the new version on our website, www.veros.com.

5. HOW TO CONTACT US

If you have any questions or comments about this California Privacy Policy, the ways in which we collect and use your personal information, or your rights regarding such use, or you wish to exercise your rights, please contact us at: