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Privacy Policy

Last Modified: September 18, 2024

ScyllaDB Ltd. and its affiliated companies (collectively “ScyllaDB“, “we” or “us”) provides NoSQL proprietary software and cloud-based database infrastructure services (“Services”). This privacy policy (“Privacy Policy”) describes how ScyllaDB collects, uses, and shares data, including Personal Data, while using our Services (“Customer“), applying for a job (“Candidate”) or merely when engaging with our website, blog, join an event we host, or other similar forums as available through the website or additional landing pages (“Prospect”). Unless otherwise stated herein, Customer, Prospect and Candidate shall be, collectively and separately, referred to as “you” or “your“. You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. This Privacy Policy is hereby incorporated into our Terms of Service and any other terms of use governing the provision of our Services (“Terms”). Any capitalized terms used herein but not defined herein, shall have the meaning ascribed to it under the Terms of Service. This Privacy Policy applies to all users worldwide. If you are a resident of California, please refer to Section 12. Additional Privacy Information for California Residents for information about the categories of Personal Information we may collect and your rights under California privacy laws. If you are a resident of Colorado, Connecticut, Virginia, Texas, Florida, Washington, Oregon, or Utah, please refer to Section 13. Additional Privacy Information for Certain United States Residents, which includes additional information about privacy rights for residents of certain U.S. jurisdictions.

1) Policy Amendments

We reserve the right to periodically amend or revise this Privacy Policy at our sole discretion. The most recent version of this Privacy Policy will be reflected in the “Last Modified” heading located at the top of this Privacy Policy. We will not implement any substantial changes in our privacy practices without providing you prior notice. We recommend that you periodically review this Privacy Policy to ensure that you understand our most updated privacy practices and to check for any amendments.

2) Contact Information and Data Controller Information

ScyllaDB Ltd., incorporated under the laws of the state of Israel, is the Controller (as such term is defined under the EU and UK General Data Protection Regulations “GDPR” or equivalent privacy legislation) of certain Personal Data collected from its Customers, Candidates and Prospects.

If you have any questions, inquiry or concern regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, you can contact us through the following means:

  • DPO Contact Information
    By email: [email protected]
    By mail: Maskit 4, Building C, Herzliya 4673304, Israel
  • DPR Contact Information
    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://prighter.com/q/18882211857.

You may contact us directly at: [email protected], regarding our use or disclosure of your Personal Data.

3) Which Data Sets We Collect, for What Purpose and Lawfulness

We may collect two types of information from you, depending on your interaction with us: “Non-Personal Data”: During your interaction with our Services, we may collect aggregated, non-personal, non-identifiable information, which may be made available or gathered via your access to and use of the Services. We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc. “Personal Data”: We may also collect from you, during your access or interaction with the Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists. The types of Personal Data the purpose we process, the purpose, lawful basis, and our processing operations are specified in the table below:
Type of Personal Data Purposes and Operations Lawful basis under the GDPR
PROSPECTS
Online Identifiers and Profiling: When you interact with our website, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID, unique identifiers (“Online Identifiers”). Further, we will collect telemetry data associated with the Online Identifier this information includes the referring URL (that is, the webpage directing you to our website, and other websites you visited in the session), your interests in our competitors, how you interact with our webpage, time, duration of use, pages you have viewed on our website, etc. (“Behavioral Data”). First, Online Identifiers are used in particular to operate the website and enable its proper functionality, for security and fraud prevention purposes, debugging purposes and to resolve technical problems. Second, Online Identifiers and Behavioral Data are indirectly processed by marketing and analytic tools, to measure effectiveness and optimize our marketing campaigns, including by building targeted audience, and marketing our Services to people who have taken action on the website. Strictly necessary cookies which are required for the proper and basic operation of the website will be processed based on our legitimate interest of operating our website. Online Identifiers and Behavioral Data use for analytics and marketing will be processed based on your consent which we will obtain through our consent management platform, which can be withdrawn at any time by using the cookie preference settings available in the website footer or by managing opt-out through your browser or device.
Contact Information: If you voluntarily contact us register for our newsletter, webinar, demo or other inquiries, you may be required to provide us with certain information such as your name, job title, company name, email address, and any additional information you decide to share with us(collectively “Contact Information“). We will use your Contact Information to respond to your inquiry, provide you with our newsletter, etc. We process Contact Information subject to our legitimate interest except when you register to our newsletter which we process based on your consent which can be withdrawn at any time by using the “unsubscribe” link within the marketing communication.
Call Recordings: When our sales’ representatives contact you through your work phone, we may, subject to applicable laws, record our call (“Call Recordings”). We use such Call Recordings in order to analyze our calls with you for quality monitoring, training and compliance purposes [for example in the event of any claims or in order to provide you with any further assistance (if applicable)]. We will process our Call Recordings based on our legitimate interest or your consent, as required under the applicable data protection laws. If you provided your consent, it can be withdrawn at any time during or after the call.
CANDIDATES

Career: When you apply for a job, promoted on our website or other platforms, we will process your CV (and the information included therein), as well as additional information such as your contact information (name, email address and phone number), information regarding your education and skills, employment history, and your photo (to the extent provided by you).Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data (collectively, “Recruitment Information”).

The recruitment information is subject to our candidate privacy policy which you can visit at: https://www.scylladb.com/data-privacy-notice-for-candidates/
We will use your Recruitment Information to process your job application and for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements. Following the completion of the recruitment process, we may further retain and store the Recruitment Information (including other interactions with us under such process) as part of our internal record keeping, including for legal defense from any future claim, as well as, where we find applicable and subject to applicable law requirements, to contact you in the future for other position we believe you qualify for. If you are hired, your Recruitment Information will be kept on our HR systems as part of your employment and our corporate management. We currently use third party service provider for the purpose of managing job applications, currently we are using Comeet which processes your Recruitment Information on our behalf subject to this data processing agreement. We process the Recruitment Information subject to our legitimate interest. In some cases, for example, if we ask you to provide diversity and inclusion data, we will process such data based upon your consent. You may always withdraw consent at any time by directly contacting us or using the DSR form available here. We will retain your data for records keeping and future defense from legal claims under our legitimate interest, or if you have provided consent to contact you in the future.
CUSTOMERS
Customer Account: In order to use our Services (including the free trial services) you will need to create an account. The information provided during the registration process will include your full name, email address, your job title, company name, etc. (“Registration Information”). We use the Registration Information to create your account, provide account management (including billing and invoices), support and to provide the Services. In addition, we might use your email for direct marketing purposes (“Direct Marketing”), meaning, we may send you marketing related communications by email, materials and content regarding the Services you are currently using or any services we may offer in the future to keep you up to date. We process Registration Information for the performance of our contract with you. Direct marketing is processed subject to our legitimate interest. You can opt-out at any time using the “unsubscribe” option appears on the bottom of the message. Please note that if you choose to unsubscribe from our direct marketing, we will still retain your contact details and send you service-related emails, such as invoices.
Usage Data: When you use our Services, information and certain data gets automatically generated and collected in order to help us understand how you are using our Services, and how to better provide the Services to you. (“Usage Data”). The Usage Data includes Online Identifiers and the click stream within the Services, the use of the Services (i.e., accessed or used by Customer), the time spent on those pages or features, crash data and analytics, etc. We use the Usage Data to help us to understand how you are using our Services, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers, decide how to improve the Service based on the results obtained from this processing. We process the Usage Data subject to our legitimate interest.
Customer Support: When you contact us for customer support, we will process your Contact Information. Further, we may also record our call with you. We will use the Contact Information to provide the customer support needed. We will retain such correspondence for as long as needed, and to evidence the support was provided. Our correspondence with you, its content and the call recording may be processed and stored by us in order to analyze our customer support efforts, for quality monitoring, training and compliance purposes (for example in the event of any claims or in order to provide you with any further assistance (if applicable)). We process your Contact Information to provide the support services and fulfill the contractual obligations.
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in Section 10 below “Cross-Border Data Transfer“, is based on the same lawful basis as stipulated in the table above. In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests. We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above. Note however, we will not use your Personal Data for any purpose that is materially different from the purposes for which the information was originally collected as detailed in the table above or subsequently authorized by you or required by applicable law.

4) How We Collect Data

Depending on the nature of your interaction with the website and Services, the above detailed data is collected as follows:

  • Information you provide us directly – for example, when you register and create an account, apply for a job or correspond with us.
  • Information we receive from third parties – for example, through data enrichment partners or third parties listed on your CV.
  • Information we receive automatically – we will collect your Online Identifiers and Behavioral Data including analytics data (or use third-party measurement and marketing tools). For more information on the cookies we use and how to opt out of third-party collection of this information, please see our Section 5 below “Cookies and Similar Technologies”.

5) Cookies and Similar Technologies

We use “cookies” (or similar tracking technologies) when you access our website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies may be used for different purposes such as: (i) allowing you to navigate between pages efficiently; (ii) enabling automatic activation of certain features; (iii) remembering your preferences; and (iv) making the interaction between you and our Services quicker and easier. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). Please see our cookie policy available here which details the cookies we use on our website, as well as our cookie setting tool available below enabling you to change your settings and preferences at any time.

Also note that, most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that once you choose to opt out or disable cookies, some features of the website may not operate properly, and your online experience may be limited.

6) Sharing Data with Third Parties

We share your Personal Data with third parties, including our partners or service providers that help us manage our business operations. You can find in the table below information about the categories of such third-party recipients.

Category of recipientData that will be sharedPurpose of sharing
Essential service providers, which process data on our behalf, for the purpose of providing the Services, securing and improving the Services.All types of Personal Data as strictly necessary and on a case-by-case basis.We may disclose Personal Data to our trusted service providers that provide technology or platforms that are essential for providing the Services (“Essential Service Providers”). Such Essential Service Providers include hosting, and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platforms, data and cyber security services, fraud detection services, billing and payment processing services, session or activity recording services, support and customer relation management systems. The Essential Service Providers are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Marketing service providersContact Information, Registration Information, Online Identifiers and Behavioral Data.Our marketing service providers, that either process on our behalf certain data which we use to target you and offer you our Services, or they provide us with tools to do so.
ScyllaDB, Inc.All types of Personal Data as strictly necessary and on a case-by-case basisWe may share certain information with ScyllaDB Ltd.’s fully-owned subsidiary – ScyllaDB Inc., which provides us with certain required services such as sales services and customer support, as well as for internal compliance.
ConsultantsAll types of Personal Data as strictly necessary and on a case-by-case basisOur legal, financial and compliance advisors (“Consultants”) may be exposed to certain Personal Data. The Consultants are bound by privilege obligations or confidentiality agreements and are prohibited to share any Personal Data except for providing the services we requested.
Necessary DisclosuresAll types of Personal Data as strictly necessary and on a case-by-case basisTo the extent permitted or required by applicable law, we may disclose information about you to third parties to: (i) enforce or apply our Terms or any applicable service agreement; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our customers or others; violation of our applicable policies and agreements; or as otherwise required by law.

When we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary for them to provide the services to us. These parties are required to secure the data they receive and perform their services while ensuring compliance with all applicable data protection regulations.

Note, we will not share your Personal Data with additional third parties or for purposes not detailed in the table above or subsequently authorized by you or required by applicable law. You may contact us directly at: [email protected] regarding our use or disclosure of your Personal Data.

7) Privacy Choices

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed. In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:
Right to be informed, right to know You have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy.
Right to access You have the right to know which Personal Data we specifically hold about you, and receive a copy of such or access it. If you wish to receive a copy of the Personal Data, please submit DSR form available here.
Right to correction You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. Please submit a DSR form as available here.
Right to be forgotten, right to deletion You have the right to request the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. Depending on your territory, we may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, other legitimate interests such as record keeping with regards to our engagements, completing transactions, providing a service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising free speech, ensuring the right of another consumer to exercise their free speech rights, or exercising another right provided for by law; engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. In order to exercise your right to deletion please submit a DSR form as available here.
Right to portability You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please submit our DSR form as available here.
Right to opt out under the EU, and specifically in the US the right to opt out from: (i) selling Personal Data; (ii) right to opt out from targeted advertising; and (iii) right to opt out from profiling and automated decision making Direct Marketing or newsletter: You have the right to opt-out receiving any marketing communication from us, by unsubscribing through the email received. Cookies: When you no longer wish for cookies to track your behavior on our website for analytic and marketing purpose, change your preferences through the cookie settings available here. Sale of Personal Data for targeted advertising, monetary gain or profiling, or share or sale of personal information for analytic or marketing: If and to the extent applicable, you have the right to opt out of the sale of your Personal Data, for the purposes of targeted advertising, sale to a third party for monetary gain, analytic, etc. as detailed under the DSR form available here or through the cookie settings available here. Last, you are able to install privacy-controls in the browser’s settings to automatically signal the opt-out preference to all websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control, where applicable, subject to your jurisdiction, as a valid request to opt-out of the sharing of information linked to your browser. Note you may have the right to authorize another person acting on your behalf to opt out (including by technical tools and opt out signals). In any event, please keep in mind that opt-out tools are limited to the browser or device you use because they work off your browser ID and device ID and, accordingly, you will need to opt-out on each browser and device you use. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again.
Right to appeal or complaint If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK. Additional information for the appeal procedure under certain state laws, please see section 13 below “Jurisdiction-specific Notices”.
Non-discrimination Such discrimination may include denying a service, providing a different level or quality of service, or charging different prices. We do not discriminate our customers or users.

8) Data Retention

We retain the Personal Data we collect for the minimum period of time necessary to fulfil the purpose for which it was collected, as set forth above, all under the applicable regulation, or until you express your preference to opt out, where applicable. Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

9) Security

We work hard to protect the Personal Data we collect from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry standards, as we further explain in our Security Policy. Further, ScyllaDB undergoes independent third-party audits to confirm that it meets strict industry standards for security, availability, processing integrity, confidentiality, and privacy.

ScyllaDB has been certified to be compliant with the following standards: SOC 2, ISO 27001, ISO 27017 and ISO 27018.

Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.

Please contact us at: [email protected] if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

10) Cross-Border Data Transfer

We may store or process your Personal Data in a variety of countries including the United States. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our Services. Personal Data transferred from within the EU, the UK or Switzerland to ScyllaDB Inc., is subject to the DPF Principles, as all defined and detailed in the Data Privacy Framework Statement available here: Data Privacy Framework Your personal information may be transferred and stored in countries outside the EEA that are subject to different standards of data protection. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data collected within the European Economic Area (“EEA“) is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the EU standard contractual clauses approved by the European Union (SCCs). Additionally, following the withdrawal of the United Kingdom (UK) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK is subject to and made pursuant with the UK standard contractual clauses. In addition to the standard contractual clauses mentioned above we are certified under the EU-US Data Privacy Framework (“DPF”), the UK Extension to the EU-US DPF, and the Swiss-US DPF, which entered into force on July 10, 2023. For more information about our DPF certifications please see our Data Privacy Framework

11) Children Privacy

Our Services are not directed nor is it intended for use by children and we do not knowingly collect information about anyone under the age of 16. We will discard any information that we receive from a user that is considered a “child” immediately upon our discovery that such a user shared information with us. Please contact us at: [email protected] if you have reasons to believe that a child has shared any information with us.

12) California Residents

This section applies to California residents only pursuant to the California Consumer Privacy Act of 2018 as amended by the CPRA (“CCPA”). Please see the CCPA Privacy Notice here which discloses the categories of Personal Information collected, purpose of processing, source, categories of recipients with whom the Personal Information is shared with for a business purpose, whether the Personal Information is sold or shared, the retention period, and how to exercise your rights as a California resident.

13) Jurisdiction-Specific Notices

Information provided below supplements the information contained in this Privacy Policy and applies solely to consumers who reside in each applicable state. These additional disclosures are intended to provide you with additional information with regard to our handling of your Personal Data and certain consumer rights.

Any disclosures regarding users’ rights and choices, the personal data or personal information processed, collected, used, shared or sold are all disclosed in the Privacy Policy, this section solely states additional rights, such as rights to appeal, which are specific per applicable state.

A. Supplemental Information for Colorado Residents

Under the Colorado Privacy Act (“CPA”), Colorado residents acting in an individual or household context (and not in a commercial, employment context or as a job applicant) or someone on their behalf, are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

B. Supplemental Information for Connecticut Residents

Under the Connecticut Data Privacy Act (“CDPA”), Connecticut residents acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity) or someone on their behalf, are allowed to exercise certain rights regarding their Personal Data. We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension. If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

C. Additional Information for Florida Residents

Under the Florida Digital Bill of Rights (“FDBR”), Florida residents acting in an individual or household context (and not in a commercial or employment context) are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of your request. We reserve the right to extend the response time by an additional 15 days when reasonably necessary and provided consumer notification of the extension is made within the original 45-day timeframe. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected], specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

D. Additional Information for Montana Residents
*Effective October 2024

Under the Montana Consumer Data Privacy Act (“MTCDPA”), Montana residents acting in an individual or household context (and not in a commercial or employment context) are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of your request. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the original 45-day timeframe. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected], specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Montana Attorney General at:https://app.doj.mt.gov/OCPPortal/complaintstart.aspx

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to once annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

E. Additional Information for Oregon Residents

Under the Oregon Consumer Data Privacy Act (“OCDPA”), Oregon residents acting in an individual or household context (and not in a commercial or employment context) are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of your request. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the original 45-day timeframe. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected], specifying you wish to appeal. Within 45 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Oregon Attorney General at: [email protected].

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to once annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

F. Additional Information for Texas Residents

Under the Texas Data Privacy and Security Act (“TDPSA”), Texas residents acting in an individual or household context (and not in a commercial or employment context) are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of your request. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the original 45-day timeframe. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected], specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Texas Attorney General at: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

G. Supplemental Information for Virginia Residents

Under the Virginia Consumer Data Protection Act (“VCDPA”) Virginia residents acting in an individual or household context (and not in a commercial or employment context) or someone on their behalf, are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request we will not be able to grant your request.

H. Additional Information for Utah Residents

Under the Utah Consumer Privacy Act (“UCPA”), Utah residents acting in an individual or household context (and not in a commercial or employment context) are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of your request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, we will provide with the reasoning for our refusal.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.