Privacy Policy



Effective Date: 1 June 2024

Regrow Agriculture, Inc. (collectively, “Regrow,” “we” or “us”) provides an Agriculture Resilience platform for today’s leading retailers, CPGs, processors, and farmers.  In this Privacy Policy (“Policy”), we describe how we collect, use, disclose and otherwise process the personal information described below, as well as the rights and choices you have regarding such personal information. 

This Policy applies to the extent we process personal information on our own behalf, as a controller or business. This Policy does not apply to the extent we process personal information, as a processor or service provider, on behalf of our business customers (“Customer Data”).  Where we process such Customer Data as a processor, such processing is subject to the privacy policies of our respective business customers. In such cases, Regrow will only process Customer Data on behalf of and under the instructions of our customers and as set out in our customer agreements, or where otherwise required by applicable laws.

If you are a California resident, please review our “CCPA Privacy Notice” for additional information about our information practices and your California privacy rights as required by California privacy law, including your right to opt out of sales of personal information.

You can review more detailed information about our privacy practices and your rights and choices below in our Policy, which is organized into the following sections:

  1. Scope
  2. Personal Information Collection 
  3. Purposes of Collection and Use
  4. Disclosure of Information 
  5. Aggregate and Non-identifiable Information 
  6. Cookies, Targeting, and Analytics
  7. Your Privacy Choices 
  8. Information About Children
  9. Third-Party Sites and Services 
  10. International Transfers
  11. Security 
  12. Retention 
  13. Changes to Our Privacy Policy
  14. Contact Us
  15. Additional Information for Individuals in Certain Jurisdictions
    Individuals in the European Union/European Economic Area and UK
    CCPA Privacy Notice for California Residents

1. Scope

This Privacy Policy applies to the personal information that Regrow processes as a controller or business related to: 

  • Users of our websites where this Policy is posted, including (“Site”), our SaaS platform (located at and, our mobile applications, and the services we provide through these, as well as any technology, downloaded applications and software, and other products and services provided by us that display or include a link to this Policy (collectively, the “Services”); 
  • Current, former, and prospective customers, vendors, and partners that use our products and Services or communicate with us for customer support, troubleshooting, or other interactions with us;
  • Individuals who register for and/or apply to participate in our webinars, other events, and programs; 
  • Individuals who are subscribed to receive news, information and marketing communications from us; 
  • Individuals who participate in surveys and research conducted by us; and
  • Individuals that communicate with us or otherwise engage with us related to our Services.

Not In Scope. This Policy does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal information is subject to different privacy notices. 

Additional Notices. In some cases, additional or supplemental privacy notices (each an “additional notice”) may be provided and will apply to certain personal information collected and processed by us.  For example, we may provide an additional notice in order to provide more specific information about how we use and disclose personal information if you participate in one of our programs and we collect additional information from you related to the program. The additional notice will control to the extent there is a conflict with this Policy, with respect to your personal information that is subject to that notice.  

Your use of our Services and Site, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. Our Terms of Use are incorporated by reference into this Policy.

2. Personal Information Collection 

We collect information directly from you, from third parties, and by automated means as set out below.   

Personal Information Collected Directly. 

The personal information that we collect and process will vary depending upon the circumstances and how you interact or engage with us, but generally includes: 

  • Registration and account information. When you register for a business customer account, we may collect personal information such as: name, company name, and title/position; email address, phone number, mailing address and contact details; account profile information; business affiliations; and other information related to your account, such as your preferences. 
  • Communications and interactions. When you communicate or interact with us, whether through the Site, Services, via email or otherwise, we collect and maintain a record of your contact details, contact preferences, communications, and our responses. Interactions may include when requesting a demo or filling out a ‘Contact Us’ form, requesting additional information about our Services, signing up for our mailing lists, or otherwise providing us information through the Site or Services. 
  • Payment and billing information.  In connection with our business customer accounts, we collect payment and billing information for those accounts, which may include billing contact name, address, and payment information in order to provide our Services to you. We may also collect payment information from contractors related to programs, such as Sustainability Watch, in order to make payments to them.
  • Events and other programs. For example, if you register for or attend an event that we host or sponsor, including summits and webinars, we may collect information related to your registration for and participation in such event.  Also, if you apply to get involved in our sustainability program, we collect your application information, including your name, email address, phone number, and occupation. If you are accepted into the program, we will collect information about you so that you can join our team, download the corresponding app, survey fields, and submit invoices. 
  • Research and surveys. We may conduct research and surveys, which may help us evaluate, develop and improve our Services and better respond to audience preferences.  If you respond to surveys or similar requests, we will collect your personal information, including name and contact information and survey responses.

Personal Information from Third Parties Sources.

We collect information about you from other sources, such as public sources, business partners, and other third parties. For example, we may collect information such as:  

  • Vendors and service providers. We outsource some of our operations to our service providers and vendors in order to provide and operate our Services.  They may collect and provide us with IP addresses, unique identifiers, and other user activity information.   
  • Lead information. We may receive lead and prospect information from third parties, about prospective business customers that may be interested in our Services.  We may also engage with third parties to enhance or update our customer information.
  • Social media and other third-party platforms. If you post information about us or engage with us on social media or other third-party platforms, we may collect personal information about you from that third-party platform. These third-party platforms and services control the information they collect and share about you.  For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.

Personal Information We Collect Automatically or Derive.  

We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags).  We may also derive information about you (e.g., your location information) and your use of the Services. Such information includes:

  • Device and browsing information. We may use cookies, third-party SDKs, pixel tags, and other tracking technologies to automatically collect personal information when you use our Site and other Services.  This information may include IP address and other unique identifiers, general location information, browser type, domain names, access times, pages views, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, and similar device and usage information. For more information about our use of cookies and other online tracking tools, please see the “Cookies, Targeting, and Analytics” section below.
  • Activities and usage. We collect activity information related to your use of our Site and Services, such as information about the links clicked, searches, features used, pages viewed, time spent, and files uploaded. We also collect activity information related to your use of our Services, such as data logs, as well as data used to: optimize and maintain performance of the Services and our products; and monitor, investigate and prevent and detect fraud, system abuse, security incidents, unauthorized activities and access, and other misuses of the Services. 

3. Purposes of Collection and Use 

The purposes for which we may process personal information will vary depending upon the circumstances. 

Legal Bases for Processing. 

Certain laws, including the EU General Data Protection Regulation (“GDPR”), require that we inform you of the legal bases for our processing of your personal information. Pursuant to the GDPR (and other similar laws), we process personal information for the following legal bases:

Performance of a contract. As necessary to enter into or carry out the performance of our contract with our business customers.

Compliance with laws. For compliance with legal obligations and/or defense against legal claims, including those in the area of labor and employment law, social security, and data protection, tax, and corporate compliance laws.

Our legitimate interests. In furtherance of our legitimate business interests, which are not overridden by your interests and fundamental rights, including:

  • Performance of contracts with customers and other parties;
  • Implementation and operation of our Services, including support and technical services for our business operations and customers;
  • Customer relationship management; 
  • Monitoring, investigating, preventing and detecting fraud, system abuse, security incidents, authorized activities and access, and other misuse of the Services; 
  • Ensuring physical, IT, and network perimeter security; 
  • Preventing harm to customers, their accounts, and/or Customer Data; 
  • Performing internal investigations; 
  • Improving our Site and Services, and developing new services and offerings; 
  • Conducting modeling, trend analysis, market research, analytics, research and related purposes; and 
  • Conducting mergers, acquisitions, and reorganization, and other business transactions. 

With your consent: Where we have your consent, the GDPR (where it applies) and other applicable laws give you the right to withdraw your consent, which you can do at any time by contacting us using the details at the end of this privacy notice. In some jurisdictions, your use of the Services may be taken as implied consent to the collection and processing of personal information as outlined in this privacy notice.

In addition, we may process your personal information where necessary to protect the vital interests of any individual.

Processing Purposes. 

In general, we use personal information for the purposes set forth below, and where GDPR or other relevant laws apply, we have set forth the legal bases for such processing in parenthesis (see above for a further explanation of our legal bases): 

Providing Services and Site and support. To provide and operate our Services and Site, communicate with you about your use of the Services and Site, provide troubleshooting and technical support, respond to your inquiries and requests, process your payments (for business customer accounts), communicate with you, and for similar service and support purposes. (Legal bases: performance of our contract and/or our legitimate interests)

Communicating with you about the Services. For example, to send notices, updates, security alerts and other administrative messages, and to consider your request or application (e.g., if you submitted an application for our sustainability program, we will use it as part of the application review process). We may also send user surveys and questionnaires, such as for market research. (Legal basis: performance of our contract)

Analytics and improvement. To better understand how users access and use the Services and Site, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop new services and features, and for internal quality control and training purposes. (Legal basis: our legitimate interests)

Our advertising services. To promote Regrow’s products and services on third-party websites, as well as to measure and understand the reach and effectiveness of these ads and provide analytics and reporting to advertisers and ad partners. 

Marketing and promotional purposes. For marketing purposes, including to send you newsletters, updates, alerts, and promotional information we think may interest you, as well as to evaluate, measure and improve our marketing. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. (Legal bases: our legitimate interests and/or with your consent)

General business operations. To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping, and legal functions. (Legal bases: our legitimate interests; and/or compliance with laws)

Security and protection of rights. To protect the Services and our business operations, including to prevent and detect fraud, misuse, and unauthorized activities, as well as where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Policy. (Legal bases: our legitimate interests and/or compliance with laws)

Complying with legal obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. (Legal bases: our legitimate interests and/or compliance with laws)

4. Disclosure of Information

We may disclose the information, including personal information, that we collect to others, as reasonably necessary for the purposes described above and as otherwise directed or authorized to by you, which may include: 

Vendors and service providers. To vendors, service providers, contractors, or agents who process such information on our behalf, in order to provide services to us or perform functions on our behalf, including IT service providers and analytics providers, and data providers that we work with to enhance our data. 

Affiliates and subsidiaries. To our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.

Business users. If you use the Services on behalf of your company (our business customer) or if you access any Regrow services as an authorized user of one of our business customers, we may share personal information about your access to the services and your communications or requests to us, with the relevant business customer. In addition, other users from that same business customer may have access to information, data, actions, and comments you provide within such online platforms or services. 

Ad measurement providers. To advertising measurement providers and other service providers that help us and ad companies understand information about the content and ads viewed, and the effectiveness of ad campaigns, including the audience that saw the ads and how they responded. These measurement providers collect or receive information about your viewing of or interaction with content and ads within the Services and through our advertising services on other websites, mobile apps, and platforms. 

Protecting rights and interests. To law enforcement and others where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others.  For example, in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and respond to violations of our Terms of Use. We may also disclose personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

Legal compliance. To regulators, law enforcement and other third parties in order to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, in response to a subpoena, warrant, court order or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

Business transfers. We may disclose your information to another entity in connection with an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer, including during negotiations related to such transactions.

5. Aggregate and Non-identifiable Information

We may collect, use, disclose, and otherwise process aggregate and non-identifiable information, including related to our Services, for marketing, advertising, research, compliance, or other purposes. Where we use, disclose or process data that has been de-identified data we will maintain and use the information in de-identified form and not to attempt to re-identify the information, except pursuant to applicable privacy laws.

6. Cookies, Targeting, and Analytics 

We and our third-party service providers use cookies, pixels, java script, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access and use the Services, how they interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess, secure, protect, optimize and improve the performance of our Services.

Cookies.  Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through the Services for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others allow us to track your activities in our Services, support the security and performance of the Services, or allow us to track activity and usage data within Service.  Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable cookies altogether. 

Pixel Tags. Pixel tags (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device, pixel tags are embedded invisibly on web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics. We may use non-affiliated analytics companies, for example Google Analytics (see privacy policy and opt-out), to evaluate use of our Services. We use these tools to help us understand use of, and to improve, our Services, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.  

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt out of targeted advertising by following the instructions in the “Cookies, Targeting, and Analytics” section.

Advertising and Targeting. As described above, we work with third parties, such as third-party ad networks, analytics and measurement services and other third-party ad companies to manage our advertising on third-party sites and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools (which we may refer to collectively as “targeting cookies”) to collect activity information within our Services (as well as on third-party sites and services), as well as IP address, location information, unique ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you with more relevant ads and content within our Services and other online services and on third-party sites and apps, and to evaluate the success of such ads and content.  

Preferences. We make available several ways for you to manage your preferences regarding third-party advertising and cookies within our Site and Services. Many of these are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Site and Services. In addition, if you delete or block cookies, you may need to reapply these preferences.  Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us.   

Cookie preference manager. You can review or change your preferences for targeting cookies and tags on our Site by adjusting your cookies in your browser settings. By clearing the cookies in your browser settings and visiting again, you will be able to make changes to your cookie preferences. 

Browser settings. To prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies, notify you when a cookie is set or delete cookies. Visitors to our Site and other online services who disable cookies will be able to browse the Site, but some features may not function. 

Industry ad choice programs. You can control how participating third-party ad companies use the information that they collect about your visits to our Sites and those of third parties, in order to display more relevant targeted advertising to you. For more information and to opt out of receiving targeted ads from participating third-party ad networks go to:

  • U.S. Users: (Digital Advertising Alliance) (You can also download the DAA AppChoices tool in order to help control interest-based advertising on apps on your mobile device.)
  • EU Users: (European Interactive Digital Advertising Alliance)

Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or contextual ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

7. Your Privacy Choices 

Users have several choices regarding their personal information and privacy preferences, as described in this section. 

Marketing Communications. We may send periodic promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email or emailing us at  Please note that it may take up to ten (10) business days for us to process opt out requests. If you opt out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.  

Cookie and Targeted Advertising. As described in the “Cookies, Targeting, and Analytics” section above, you can manage your preferences for cookies (including targeting cookies) on our Site and Services by adjusting your cookie settings or other preferences.

Mobile Device Settings. In some of our mobile Services, we may send push notifications from time-time in order to update you about updates. With your permission, we may collect your device’s location information.  If you no longer wish to receive these types of communications or share your location data, you may update the app settings on your mobile device.

Accessing and Updating Your Account Information. If you register for an account with us, you can access and update certain information we have relating to your account within your account profile settings. Please note that we may maintain copies of information that you have updated, modified or deleted, as permitted, in our business records and in the normal course of our business operations.

Additional Information for Certain Jurisdictions. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us. Some privacy and data protection laws require that we provide specific information about individual rights to applicable consumers, which we have set forth at the end of this privacy policy:

  • EU/EEA. If you are in the European Union / European Economic Area, below we provide further details about your rights under the GDPR.
  • California. If you are a California resident, you have certain rights, under California privacy laws, regarding your personal information as set forth in Section 15.B CCPA Privacy Notice for California Residents. 

For more information about our privacy practices and your privacy choices, you may contact us as set forth in the ‘Contact Us’ section below.

8. Information About Children

The Regrow site is not intended for minors under the age of 13. We do not knowingly or specifically collect information about minors under the age of 13. If you believe we have unintentionally collected such information, please notify us at and we will take action as necessary to securely delete such information. 

9. Third-Party Sites and Services

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

10. International Transfers

Regrow is headquartered in the United States and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.

If you are in the European Economic Area, and we process your personal information in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a “third country”), we will implement measures to adequately protect your personal information, such as putting in place standard contractual clauses approved by the European Commission or another measure that has been approved by the EU Commission as adducing adequate safeguards for the protection of personal information when transferred to a third country. You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA; you may request such details by contacting us as set forth in the “Contact us” section below.

11. Security

We have implemented safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared device.

12. Retention

As a general rule, we retain your personal information for as long as necessary to fulfill the purposes for which it was collected and is used by us, as stated in this Policy. Further, to the extent permitted by applicable law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.  With respect to retaining Customer Data, our business customers instruct us on how long to retain Customer Data, which we handle as a data processor.

13. Changes to Our Privacy Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site.  If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as via email or prominent notice on the Site.

14. Contact Us

If you have questions or concerns regarding the way in which your personal information is being processed or this Policy, please email us at or reach out to Regrow using the contact information below:

Regrow Agriculture Inc.
Attn: Regrow Privacy Officer
87 Packers Falls Road
Durham, New Hampshire 03824 USA

15. Additional Information for Individuals in Certain Jurisdictions

Residents of certain jurisdictions have additional rights under applicable privacy laws, as described in this section.

Please note that for Customer Data that we process on behalf of our business customers, in our capacity as a processor or service provider, we will provide reasonable assistance to that business customer as necessary to enable them to respond to your requests to exercise your privacy rights. If possible, you should submit your request directly to the relevant business customer. 

Individuals in the European Union/European Economic Area and UK. 

Subject to the conditions set out in applicable law, data subjects in the European Union/European Economic Area (“EEA”) and UK have the following rights regards our processing of their personal information:

  • Right of access. To confirm whether we are processing your personal information and to receive a copy of that personal information (along with certain other details).
  • Right to correction (rectification). To request that we correct any personal information we hold about you that is inaccurate or incomplete.
  • Right of erasure. To request that we delete your personal information under certain circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). (NOTE: If you request that we delete your personal information, we may do so by deleting your account(s) with us.) 
  • Right of restriction. To request that we restrict the processing of your personal information under certain circumstances, such as where you contest its accuracy or object to our use or stated legal basis.
  • Right to data portability. To receive a copy of personal information we have obtained from you in a structured, commonly used, and machine-readable format and to reuse it elsewhere or to ask us to transfer it to a third party of your choice, under certain circumstances.
  • Right to object. To object to our processing of your personal information on the basis of our legitimate interests, in which case, we must stop such processing unless we have compelling legitimate grounds that override your interest or where we need to process it for the establishment, exercise, or defense of legal claims. Where we are relying on our legitimate interests (other than marketing), we believe that we have a compelling interest in such processing, but we will individually review each request and related circumstances.
  • Right to object to marketing.  To request that we stop processing your personal information for marketing purposes, on the basis of our legitimate interests. If you do so, we will stop such processing for our marketing purposes.
  • Right not to be subject to automated decision-making. To not be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us.
  • Right to withdraw your consent. Where you have consented, to withdraw your consent to our processing of your personal information, without affecting the lawfulness of our processing prior to the withdrawal of your consent. 
  • Right to lodge a complaint. To lodge a complaint with a supervisory authority if you believe our processing of your personal information infringes the law. 

Submitting a GDPR Request. Please contact us as set out in the Contact Us section below to exercise one of these rights. Please note that some of these rights may be limited, such as where we have an overriding interest or legal obligation to continue to process the data. If we receive any requests from individuals related to Customer Data, we will forward the request to the relevant customers.

CCPA Privacy Notice for California Residents. 

Below, we provide information, as required under California privacy laws, including the California Consumer Privacy Act and its implementing regulations, each as amended (“CCPA”), which require that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under California privacy laws.

Categories of Personal Information We Collect. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose or commercial purpose.  

Sales and Sharing. California privacy laws define a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) Identifiers  and Usage Data to third-party advertising networks, analytics providers, and social networks. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.

Sources of Personal Information. In general, we may collect the categories of personal information identified in the table above from the following categories of sources:

  • Directly from you
  • Our affiliates and subsidiaries
  • Third-party platforms
  • Third-party sites and services
  • Ad networks
  • Analytics providers
  • Social networks
  • Internet service providers
  • Operating systems and platforms
  • Our vendors and service providers

Purposes for Collecting and Disclosing.  As described in more detail in Section 3. Purposes of Collection and Use, in general, we collect and otherwise process the above personal information in order to provide our Services to you, respond to your requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:

  • Providing Services and Site and support 
  • Communication with you about the Services
  • Analytics and improvement 
  • Our advertising services 
  • Marketing and promotional purposes
  • General business operations 
  • Security and protection of rights
  • Complying with legal obligations

Retention. We will retain your personal information as long as necessary for purposes for which the personal information was collected and is used by us, as stated in this Policy. If you request that we no longer use your personal information to provide Services to you, please contact us using the contact information provided in this Policy. However, if you withdraw consent or otherwise object to our collection, use and disclosure of your personal information, you may not be able to use the Services. Further, to the extent permitted by applicable law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

California Residents’ Rights. California residents have the right to receive certain information about how their personal information is used and disclosed and to not be discriminated against for exercising their privacy rights under the CCPA.  The CCPA also grants California residents the following rights (subject to certain limitations):

Opt-out of sales and sharing. The right to opt-out of our sale and sharing of their personal information.

Delete. Subject to certain exceptions, the right to request deletion of their personal information that we have collected about them.

Know/access. The right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them and to have this delivered either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information, including: 

  • Categories of personal information collected;
  • Categories of sources of personal information;
  • Business and/or commercial purposes for collecting and selling their personal information;
  • Categories of third parties/with whom we have disclosed or shared their personal information;
  • Categories of personal information that we have disclosed or shared with a third party for a business purpose; and
  • Categories of third parties to whom the residents' personal information has been sold and shared and the specific categories of personal information sold and shared to each category of third party.

Correct. The right to request that a business that maintains inaccurate personal information about the resident correct that personal information.

Limit use or disclosure of sensitive personal information. The right to limit the use or disclosure of sensitive personal information to those uses authorized by California privacy laws. However, we do not use or disclose sensitive personal information beyond these purposes.

Submitting CCPA Requests to Know, Correct and Delete. California residents may submit a verifiable request to exercise their CCPA rights as set forth below:

  • Email:
  • Via our webform.

When you submit a request to know, to delete or to correct we will take steps to verify your request by matching the information provided by you with the information we have in our records. To verify your request, we will request that you provide us with your name, email and contact details and to confirm your email address. In some cases, we may request additional information in order to verify your request or where necessary to process your request. 

Authorized agents may initiate a request on behalf of another individual by contacting us in writing at the contact information set forth above. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent. We will respond to verifiable requests received from California residents as required by law. If we are unable to adequately verify a request, we will notify the requestor.

Requests to Opt-Out of Sales and Sharing. California residents may submit requests to opt out of “sales” and “sharing” (e.g., targeted advertising) of their personal information by:

  • Webform. You may opt out of our sales and sharing of your personal information by submitting a request through our webform.  We will process your request based upon the personal information in our records that is linked or reasonably linkable to the personal information provided in your opt out request.
  • Browser Opt Out. You may also opt out of “sales” and “sharing” by our site of online data via your browser by clearing cookies in your browser and declining cookies when returning to or by turning on “global privacy control”—or GPC— signals for your browser. If we recognize that your browser is transmitting a GPC signal, we will opt that browser out of “sales” and “sharing” (including via targeting cookies). Your opt out is browser specific and applies to sales and sharing via cookies and similar browser-based tools through our website. If you come to this website from a different device or from a different browser on the same device, you will need to apply your preferences, or turn on GPC, for that browser and device as well.  More info on GPC is available here