Privacy Policy

The Private Suite LAX, LLC

Last updated: December 2, 2020

INTRODUCTION
The Private Suite LAX, LLC (“we” or “us”) is committed to protecting and respecting your privacy and personal data and information. This privacy policy relates to how we may collect, use and share personal data and information from you when and if you use, purchase, or access our services, use or access our website (“Website”), and/or use or access our services through third party websites, mobile apps, plug-ins, and social media platforms including, but not limited to, Instagram, Facebook and others (collectively, “Third Party Platforms”).  This privacy policy also relates to our use of any personal data and information you provide to us by telephone, cell phone, or smart phone (including text communications), in written correspondence (including letter and email), facsimile, in person, or otherwise.

Please keep in mind that Third Party Platforms may also have their own separate and distinct privacy policies and they too may collect, use, share, or even sell personal data and information from and about you, as you interact with their platforms. Therefore, you should consult those other Third-Party Platform privacy policies as well to better understand how such Third-Party Platforms are handling your personal data and information. Our Website may include links to Third Party Platforms. Clicking on those links or enabling those connections may allow third parties to collect, share, and even sell personal data and information about you. We do not control Third Party Platforms, we are not responsible for their privacy policies, we are not responsible for the availability of such Third Party Platforms, and we do not endorse and are not responsible or liable for any content, advertising, products, services, or other materials on or available through such Third Party Platforms. Furthermore, we are not responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any Third Party Platforms including, but not limited to, any content, goods or services available on or through such Third Party Platforms. When you leave our Website, we encourage you to read the privacy policies of every website, mobile app, or digital platform that you visit, as they may be materially different from ours.

This privacy policy may be amended, updated, changed, or modified from time to time and any revisions will be posted to this page, so please check back regularly. In addition, we may also provide you with specific notice of such amendments, updates, changes, modifications, and revisions from time to time by email, text, or other forms of communication.

Please note that our services and Website are not intended to be used or accessed by children under the age of 18, even though your children may be travelling with you at such time as you use or access our services and Website. We do not knowingly or intentionally collect personal data and information relating to children unless you have asked us to do so or we are required to do so by law.

GDPR and CCPA
Whenever you provide personal data and information to us through our Website or otherwise, we are legally obligated to use your personal data and information in accordance with all applicable laws and regulations regarding the collection, sharing, use, and protection of such personal data and information. This includes, but is not limited to, compliance with the General Data Protection Regulation 2016 (“GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”), as the case may be.  The GDPR laws and regulations are described or referred to in this privacy policy as the “Data Protection Laws”.

If you are a resident of the European Union, this privacy policy also forms part of our terms and conditions (“Terms and Conditions”), which include, among other things, our terms of business and terms of service. This privacy policy is not intended to override our Terms and Conditions except insofar as it contains conflicting provisions with respect to data protection, in which case the terms of this privacy policy shall apply. If you are a resident of the European Union, you may have additional rights under the Data Protection Laws, as specified herein.
If you are a California resident and you provide personal data and information to us through our Website or otherwise, you may have certain additional rights under the CCPA, as specified herein, in the CCPA, and otherwise.

WHO WE ARE AND HOW TO CONTACT US
For purposes of the Data Protection Laws, the data controller is The Private Suite LAX, LLC. We are a limited liability company registered in Delaware under company number 6017115. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:

FAO: Privacy Officer
The Private Suite LAX, LLC
6871 W Imperial Hwy
Los Angeles, CA 90045
United States of America

Email:                   [email protected]

Telephone:         +1-310-907-9950 and ask to speak to the Privacy Officer.

If you are a resident of the European Union, you have the right to make a complaint to your national data protection authority at any time, a list of which can be found on the European Data Protection Board’s website (https://edpb.europa.eu/about-edpb/board/members_en). We would, however, appreciate the chance to deal with your concerns before you approach them, so please contact us in the first instance.

THE DATA WE COLLECT ABOUT YOU
We collect, share, and process personal data and information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with, a particular consumer or household (“personal data”). The categories and corresponding personal data we may collect from you, share with our business partners and service providers, and process include the following:

  • Identity Data or Identifiers including first name, last name, alias, title or other identifier (such as job title), marital status, date of birth, gender, passport number (for international reservations), images, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, or other similar identifiers.
  • Contact Data includes billing address, email addresses and telephone numbers.
  • Transaction Data includes details about services you have purchased from us or your visits to our premises.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
  • Profile Data including your username and password, purchases or orders made by you, your interests, preferences (including details about your personal likes and dislikes as identified during your visits to our premises), feedback and survey responses.
  • Usage Data and Internet or other electronic network activity including browsing history, search history and information regarding your interaction with and how you use our Website and advertisements.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Categories of personal information described in the California Customer Records Act including name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial, medical or health insurance information.
  • Characteristics of protected classifications including color, religion, sex (including pregnancy, childbirth and other related medical conditions), gender, gender identity, gender expression, marital status, medical condition, military or veteran status, national origin, ancestry, physical or mental disability, genetic information, age.
  • Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Geolocation data including physical location and movements.
  • Sensory data including audio, electronic, visual, thermal, olfactory, or similar information.
  • Education information including education information including, to the extent not publicly available, the consumer’s name, the name of the consumer’s parent or other family members, the address of the consumer or the consumer’s family, personal identifiers (such as social security numbers, student numbers or biometric records), and indirect identifiers (such as the consumer’s date of birth, place of birth and mother’s maiden name).
  • Inferences drawn from personal data including inferences drawn from any of the aforementioned types of personal data to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

 

We also collect, use, and share aggregated data, such as statistical or demographic data. Aggregated data could be derived from your personal data and the personal data of others but is not considered to be personal data under law as it does not, directly, or indirectly, reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your aggregated data with your personal data so that it can, directly or indirectly, identify you, we will treat the combined data as personal data and such personal data would be used solely in accordance with this privacy policy.

Under the CCPA, personal data does not include information that is lawfully made available from federal, state, or local government records.

Although we do not collect financial data directly from you, your payments for our services are processed via one of our third party service providers, Stripe; and Stripe will share some of your financial data with us, as described in Section 5.1.3 below. You can access and review Stripe’s privacy policy at the following url: https://stripe.com/privacy.

We do not collect, share, use or process the following special categories of personal data about you: details about your race or ethnicity, sexual orientation, political opinions, trade union membership, genetic or biometric data. However, we may collect, share, use or process special categories of personal data relating to your health, religious or philosophical beliefs, and criminal convictions or offences insofar as this information is either: (a) provided directly by you or your third party representative because it is necessary for you to fully enjoy our services (for example, by ensuring accessibility of the venue or the availability of a requested prayer space); or (b) necessary for us to comply with applicable laws and/or regulations.

We do not intentionally or knowingly collect personal data relating to children under the age of 18, unless either:

  • It is necessary for us to process your reservation and provide the services you have requested, or comply with applicable laws and regulations (for example, we collect the full legal name, birthdate, passport number and passport expiration for all passengers, including children under the age of 18, on all international reservations – we require this information to coordinate with United States Customs and Border Patrol).
  • You provide us with your express consent to do so (for example, because you would like us to remember your children’s preferences for the next time you use our services).

 

In no event will we intentionally or knowingly collect personal data relating to a child under the age of 18 directly from such child. Rather, any personal data collected about a child under the age of 18 will be collected from a parent, guardian, or authorized representative.

We only collect data from you directly or via third parties (see Section 5.1.3 below titled “Third parties or publicly available sources”).

HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

  • Direct interactions. You, or your personal representative (more details below) may give us your identity, contact, profile, financial data, or other personal data by filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise. This includes personal data you or your representative provide when you or your representative:
    • apply for membership;
    • create an account on our Website;
    • make a reservation;
    • request that marketing communications or promotional materials be sent to you;
    • respond to marketing communications or promotions or provide information in response to a survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Website, we will automatically collect technical data about your computers, laptops, iPad, smart phones, hardware, devices, equipment, browsing and search-related actions, patterns, and histories. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy (https://reserveps.com/cookie-policy/) for further details
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following categories of parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
    • Contact, Financial and Transaction Data from providers of technical or payment services.
    • Identity and Contact Data from data brokers or aggregators, including trade organizations or exhibition organizers.
    • Identity and Contact Data from publicly available sources such as the press and social media platforms.
    • Identity and Contact Data from airlines.

 

We may obtain your personal data from third parties who act on your behalf, for example travel agents, personal assistants, airlines, credit card relationship managers, family members or other parties through which you may reserve our services. Although we take certain precautions to limit fraudulent or dishonest use of our services, it is your responsibility to ensure that you only provide third parties you trust with your personal data and that you give them appropriate authority to provide us with personal data on your behalf.  You and any third parties using our service or booking reservations for you, on your behalf, or for your benefit represent and warrant that such third parties have the requisite authority from you and your consent to engage in such activities on your behalf. Please click on the hypertext link to the Terms and Conditions on the home page of our Website for more information.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data from you by law, or in order to provide or make available our services to you, or pursuant to a contract we are negotiating with you or have entered into with you, and you fail to provide that data when requested, we may not be able to provide the services requested or perform under the contract we have with you or are trying to enter into with you. If we need certain personal data from you in order to provide services to you or finalize an agreement with you and you fail or refuse to provide such personal data to us, then we may need to cancel all or part of a service you have requested that we provide you.  We will notify you if this is the case.

HOW YOUR DATA WILL BE USED
We use information held about you to:

  • carry out obligations arising from any contracts entered into between us;
  • provide our services to you, your family members, and travel companions;
  • provide certain third-party services that we make available to you, your family members, and travel companions;
  • carry out feedback and research related to our services; and
  • notify you about changes to our services.

 

We do not sell any of the personal data we collect from you or your authorized representatives to third parties. We have not sold any personal data collected from our users during the 12 months leading up to the effective date of this privacy policy.

We share your data with third parties where there is a legal obligation for us to do so or where we have identified a valid lawful basis for sharing your data with third parties as set out in the table in Section 7.4 below. Please also see Section 8 below, which describes additional lawful basis for processing personal information we collection from users.  We may process your personal data without your knowledge or consent where this is required or permitted by law.

We have set out below in a table format, a description of all the ways we plan to use, share, or disclose personal data we collect from you or your representatives (including, but not limited to, business purposes), and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process personal data we collect from you or representatives for more than one lawful ground depending on the specific purpose for which we are using such personal data. Please contact us if you need details about the specific legal basis we are relying on to process personal data we collect from you or your representatives where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing (including basis of legitimate interest)
To register you as a new user or customer.

To register members of your party as users of the service.

Identity

Contact

Performance of a contract with you and members of your party
To provide our services to you and members of your party, and to process related transactions, including to:

Manage payments, fees, and charges

Prepare for your visit to our premises

Collect and recover money owed to us

Identity

Contact

Transaction

Usage

Marketing and Communications

Performance of a contract with you and members of your party

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you and members of your party, which will include:

Notifying you and members of your party about changes to our terms or privacy policy

Asking you or members of your party to leave a review or take a survey

Facilitating your and members of your party future visits to our premises and use of our services

Inviting you and members of your party to events

Notifying you and members of your party about promotional offers from our affiliates

Notifying you and members of your party about new locations we serve

Fulfilling any other purpose for which you or your representatives provide your personal data

 

Identity

Contact

Profile

Marketing and Communications

Performance of a contract with you or members of your party

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated, to study how customers use our products or services, keeping you up to date on the latest services offered by us and our affiliates)

To enable you and members of your party to partake in a competition or complete a survey Identity

Contact

Profile

Usage

Marketing and Communications

Performance of a contract with you and members of your party

Necessary for our legitimate interests (to study how customers use our products or services, to develop them and grow our business)

To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Identity

Contact

Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

Necessary to comply with a legal obligation

To measure or understand the effectiveness of the advertising we serve to you and members of your party Identity

Contact

Profile

Usage

Marketing and Communications

Technical

Necessary for our legitimate interests (to study how customers use our products or services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences Technical

Usage

Profile

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you and members of your party about goods or services that may be of interest to you and members of your party Identity

Contact

Technical

Usage

Profile

Marketing and Communications

Necessary for our legitimate interests (to develop our products or services and grow our business)

LAWFUL BASIS FOR PROCESSING
We only process personal data collected from you or your representative (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:

  • Contractual obligation: Contractual obligations refers to processing of personal data that is necessary to comply with our obligations arising out of a contract.  For example, where you have purchased services from us, we will use the personal data you provide to fulfil our contractual obligations.
  • Legitimate Interest: Legitimate interest means in the interest of our business, or in conducting and managing our business in order to enable us to give you and the members of your party high quality services and products and a secure experience.  We try to take into account, consider, and weigh any potential impact on you and members of your party (both positive and negative) and your rights before we process personal data collected from you or your representative for our legitimate interests.  Where we rely on legitimate interests as a basis for processing personal data, we will create a record of our decision to do so.  Generally speaking, we rely on legitimate interests when processing the personal data we collect from you and your representatives does not, in our opinion, affect your rights or freedoms or those of the members of your party, and is proportionate to our interests (e.g. keeping you or members of your party up to date with our latest services or obtaining your feedback or that of the members of your party on our service).
  • Consent: We will seek to obtain consent from you or your authorized representative to process:
  • personal data we collect from you or your representative that is outside of our contractual obligations (see above) unless we have identified a Legitimate Interest (see above); and any special category data.
  • Legal obligation: We may process personal data collected from you or your representative where we believe it is necessary for us to do so to comply with the law.

 

THIRD PARTIES and SHARING INFORMATION
We will keep the personal data we collect from you or your representative within our business organization except where disclosure is required or permitted by law, or when we use third party service providers (data processors) to supply or support our services to you or members of your party. We have contracts in place with our third party service providers and data processors that include provisions which require them to collect, use, share and protect personal data collected from you or your representative in a manner that is consistent with our own collection, use, sharing, and protection practices. Pursuant to these contracts, our third party service providers and data processors are not permitted to share your personal data with any business or organization other than us, or to sell personal data collected from you or your representative to any business or organization.  In addition, our third-party service providers and data processors are required to provide reasonable security over the personal data we collect from you or your representative and retain such personal data only for periods of time that are reasonable and necessary per our instructions.  All the aforementioned notwithstanding, you agree that we are not responsible or liable for any of the actions or omissions of our third-party service providers or data processors.

Please see below the list which sets out the categories of third-party service providers and data processors who may receive personal data collected from you or your representative:

CATEGORIES OF THIRD PARTY SERVICE PROVIDERS AND DATA PROCESSORS WHO MAY RECEIVE PERSONAL DATA COLLECTED FROM YOU OR YOUR REPRESENTATIVE
IT support services
Email providers
Website providers
Secure document disposal service
Domestic and international airline and flight operators
U.S. Customs and Border Protection and other air traffic or national security agencies
Banks
Online payment providers
Accountants
Solicitors
Software providers including, but not limited to, sales software providers, financial software providers, analytics software providers
Feedback aggregators and collectors
Couriers
Marketing agencies
Data storage providers
Database management providers
Advertisers
A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by us about users is among the assets transferred
Affiliates and business partners
Other third parties: (1) if required by applicable law, (2) to enforce or apply the terms of our Terms and Conditions and other agreements, including for billing and collection purposes, (3) if we believe disclosure is necessary or appropriate to protect our rights, property or safety and that of our customers or others, (4) to comply with a judicial proceeding, court order, other legal obligation or a regulatory or government inquiry, (5) for any other purpose disclosed by us when you provide the data or (6) with your consent

 

If you or your representative provide personal data about another person to us, you or your representative, as the case may be, represent and warrant, and we will believe, that you or your representative have the consent of that individual to enable us to collect, use or disclose their personal data as described in this privacy policy, and we will rely on our belief and such representation and warranty from you or your representative.

Some of you may receive a complimentary membership from us through your relationship with a credit card company. If you receive a membership with us through your credit card company in this manner, then we may share personal data we collect from you or your representative (including personal data we collect from the aforementioned credit card company) and data about your usage of our services with such credit card company in order to try and facilitate a more seamless travel experience for you.

MARKETING
We may use your Identity, Contact, Technical, Usage and Profile Data or those of the members of your party to form a view on what we think you and they may want or need, or what may be of interest to you and them. This is how we decide which products, services and offers may be relevant for you and the members of your party.  We call this marketing.

You and members of your party will receive marketing communications from us if you have requested information from us or purchased services from us, and you have not opted out of receiving those marketing communications.

We strive to provide you and the members of your party with choices regarding certain personal data uses, namely around marketing and advertising. In particular:

  • We will always obtain your express opt-in consent before we share your personal data with any third party for marketing purposes; and
  • You can ask us or third parties or data processors to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or the members of your party or by contacting us at any time.

 

WHERE YOUR DATA IS HELD
The personal data we collect from you or your representative is stored by us and our third-party service providers and data processors in the United States of America. If you are an individual residing in the European Union, we have ensured that either:

  • an adequacy decision has been made by the European Commission permitting the transfer of data to that country; or
  • standard contractual clauses (“SCCs”) are in place, and we have received assurances that an adequate level of protection of the personal data is being provided based on a case by case assessment of the circumstances of the transfer, including adequate technical and operational measures in place to protect the personal data.

 

DATA SECURITY
We have implemented security measures to try and prevent the personal data we collect from you or your representative from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to personal data we collect from you or your representative to those employees, agents, contractors and other third parties who have a business need to access or know such data. These employees, agents, contractors and other third parties will only process your personal data and that of the members of your party pursuant to an agreement with us or on our instructions, and they are subject to a duty of confidentiality.

We have implemented procedures to deal with any suspected, threatened, or actual data breach involving the personal data we collect from you or your representative, and we will notify you, the members of your party, as the case may be, and any applicable regulator of a data breach when we are legally required to provide such notice.

Although we implement data security measures to try and protect the personal data we collect from you or your representative, we cannot guarantee the security of personal data transmitted to us using the Internet or through our Website. Any transmission of personal data to us using the Internet or through our Website is made at your own risk. Accordingly, you and the members of your party agree that we and our directors, officers, members, managers, shareholders, partners, employees, contractors, affiliates, agents and representatives shall not be liable for any loss, injury or damage arising from or relating to the transmission of personal data to us by you or your representative using the Internet or through our Website.

It is important for you and the members of your party to protect against unauthorized access to your passwords and to your computers and mobile devices. Be sure to sign-off when finished using a shared computer or mobile device and use other reasonable measures to secure your sensitive information.

DATA RETENTION

  • We will only retain your personal data and that of the members of your party for as long as reasonably necessary to fulfil the purposes we collected it for and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements that may apply to us. We may retain your personal data and that of the members of your party for a longer period of time in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
  • To determine the appropriate retention period for personal data, we take into consideration the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of the personal data, the purposes for which we process the personal data, whether we can reasonably achieve those purposes through other means, and the legal, regulatory, tax, accounting or other requirements that apply to us.
  • By law, we must keep basic information about our clients who are residents of the European Union (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being clients.
  • If you are a resident of the European Union or the State of California, in some circumstances you can ask us to delete your data (see Sections 14, 15, and 16 below for further information).
  • We may anonymize your personal data and that of the members of your party for research or statistical purposes so that it can no longer be associated with you, in which case we may use this information indefinitely without further notice to you or members of your party. Please also see Section 4.2 for further information.

 

ACCESS OR UPDATE YOUR INFORMATION
You and members of your party, if an account has been created for them, can access, or modify your account with us. See Section 16.2 for a contact form and Section 16.4 for a phone number and email address you may use to contact us regarding access to and modification of your account. Notwithstanding the aforementioned, even after you or members of your party cancel your account or ask us to delete the personal data we have collected from you or your representative, we may retain information related to your account and those of the members of your party, as the case may be, to comply with legal requirements, for our internal security or recordkeeping, or for fraud detection.  Moreover, we may not be able to completely delete all your personal data or that of the members of your party due to financial, contractual, or legal requirements, or technical constraints.

RIGHTS OF THE RESIDENTS OF THE EUROPEAN UNION
Under the Data Protection Laws, residents of the European Union have the following rights, among others:

  • To be informed: If you or the members of your party, as the case may be, are residents of the European Union, we must make this privacy policy (sometimes referred to as a “privacy notice” under the GDPR) available to you and members of your party, and be transparent over how we process your personal data and that of members of your party.
  • Access: If you or the members of your party are residents of the European Union, you are entitled to know what details we hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. You can find out if we hold any of your personal data by making a formal request under the Data Protection Laws. Such requests should be made using the contact details provided in this privacy policy. If we do not hold personal data about you or members of your party, we will confirm this in writing at the earliest opportunity. If we do hold your personal data or that of members of your party, we will respond in writing. Our response will:
    • confirm that your data is being processed;
    • verify the lawfulness and the purpose of the processing;
    • confirm the categories of personal data being processed;
    • confirm the type of recipient to whom the personal data has been, is being, or will be disclosed; and
    • let you or the members of your party have a copy of the data in format we deem suitable or as reasonably required by you or the members of your party.
  • Rectification: If you or the members of your party, as the case may be, are residents of the European Union, we are obliged to correct or update your personal data and those of the members of your party.  We will correct or update such personal data without delay provided you or the members of your party, as the case may be, make the request in writing to the contact details provided in this privacy policy, clearly specifying which data is incorrect or out of date.
  • Erasure: If you or the members of your party are residents of the European Union, you have the right to be forgotten. Under the Data Protection Laws, you and the members of your party have the right to require us to erase your personal data under specific circumstances. A request for such personal data to be deleted will be decided on a case-by-case basis and should be submitted in writing to the contact details provided in this privacy policy.
  • Restrict processing: If you or the members of your party, as the case may be, are residents of the European Union, you have the right to ‘block’ or suppress the processing by us of your personal data.
  • Portability: If you or the members of your party, as the case may be, are residents of the European Union, you have the right to obtain the personal data that you or your representative provided to us in a commonly used machine-readable format and reuse it with a different provider.
  • Object: If you or the members of your party are residents of the European Union, you have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so.
  • Rights in relation to automated decision making and profiling: We do not use automatic decision making or profiling.
  • Withdraw consent: If you or the members of your party, as the case may be, are residents of the European Union, where you or your representative have given us consent to process your personal data or that of the members of your party, you and they can withdraw that consent at any time either by contacting us using the details set out in this privacy policy, or by following the opt-out links in electronic messages you receive from us where relevant.  We do not penalize individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can.

 

Please note that you or the members of your party, as the case may be, may need to provide identification in order to verify and prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarized above.

If you or the members of your party, as the case may be, agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

RIGHTS OF RESIDENTS OF CALIFORNIA
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings or signals. We do not currently take actions to respond to “Do Not Track” signals. It is our view that a uniform technological standard has not yet been developed. We may adopt a standard once one is created.

California Civil Code Section §1798.83 permits users of our Website who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes, if applicable. To make such a request, please contact us by visiting If you or members of your party believe any of the information, we possess about you is incorrect, please contact us at the same webpage listed above.

California residents protected by the CCPA have specific rights regarding their personal data:

  • Access to Specific Information – You have the right to request that we disclose to you the following about our collection and use of your personal data over the last 12 months:
      • The specific pieces of personal data we collected about you;
      • The categories of personal data we have collected about you;
      •  The categories of sources from which the personal data was collected;
      • The business or commercial purpose for collecting or selling personal data;
      • The categories of third parties with whom we share the personal data;
      • The categories of personal data that we disclosed about you for a business purpose and, for each category identified, the categories of third parties to whom that particular category of personal data was disclosed for a business purpose;
      • The categories of personal data that we sold about you and, for each category identified, the categories of third parties to whom that particular category of personal data was sold;
    • We are not required to provide you with these disclosures more than twice within a 12-month period. For requests seeking disclosure of specific pieces of personal data, we will not disclose any such data if we cannot verify the identity of the requestor. Similarly, for requests seeking categories of personal data, we may deny the request if we cannot verify the identity of the requestor. In either case, we will inform the requestor that we cannot verify their identity, and direct them to the general business practices regarding collection, maintenance, and sale of personal data in this privacy policy.  If we deny your request for specific pieces of personal data, in whole or in part, because of a conflict with applicable laws or an exception to the CCPA, we will inform you and explain the basis for the denial.
    • At no point will we ever disclose, even pursuant to a verifiable consumer request, a consumer’s social security number, driver’s license number, other government-issued identification number, financial account number, health insurance or medical identification number, account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. If applicable, we will notify you in response to a request for information that we have collected such personal data from you.
  • Right to Request Deletion – You have the right to request that we delete any personal data about you which we have collected from you or your representative. Upon receipt of a verifiable consumer request to delete your personal data, we will delete such data and direct our service providers to delete your data from their records, subject to certain exceptions provided in the CCPA including, but not limited to, if it is necessary for us or our service providers to maintain the personal data in order to:
      • complete the transaction for which the personal data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us;
      • detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for that activity;
      • debug to identify and repair errors that impair existing intended functionality;
      • exercise free speech, ensure the right of another consumer to exercise his or her free speech, or exercise another right provided for by law;
      • comply with the California Electronic Communications Privacy Act;
      • engage 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
      • enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
      • to comply with a legal obligation; or
      • otherwise use your information, internally, in a lawful manner that is compatible with the context in which you provided the information.
    • We use a two-step process for requests to delete personal data. First, you must make a verifiable consumer request. After receiving your request, we will contact you to separately confirm that you want your personal data deleted. We will contact you again once your personal data has been deleted.
    • If we cannot verify the identity of the person requesting deletion of personal data, we may deny the request and will inform the requestor we cannot verify their identity.  If we deny your request to delete personal data, we will notify you of the reasons why. We will delete any part of your personal data not covered by the exception allowing us to deny deletion of a portion of your personal data.
  • Non-Discrimination – If you are covered by the CCPA, we will not discriminate against you merely because you have exercised any of your rights under the CCPA. Except as permitted by the CCPA, we will not, merely because you have exercised your rights under the CCPA, do any of the following:
      • Deny you goods or services;
      • Charge you different prices or rates for goods or services, including using discounts or other benefits or by imposing penalties;
      • Provide you with a different level or quality of goods or services; or
      • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

  • Opt-Out Right – The CCPA provides consumers certain rights with respect to opting out of the sale of personal data. We do not sell your personal data.

 

To request your right to disclosure or deletion of the personal data we have collected about you, please submit a verifiable consumer request to us by calling us at +1-310-907-9950 and asking to speak to the Privacy Officer, or emailing [email protected]. If you have questions or concerns about our privacy policies or practices, please contact us at [email protected].

A verifiable consumer request can only be made by you, by you on behalf of your minor child, or by a person or entity registered with the California Secretary of State authorized by you to act on your behalf. In order to ensure we are able to promptly respond to your request, your request should include sufficient information that allows us to verify you are the person about whom we collected personal data or that you are an authorized representative of such person (including, for example, your full name, email address, and mailing address) and a detailed description of what you are requesting. We will review the identifying information provided in your request against information contained in our records to verify the request. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.

If you are using an authorized agent to exercise any of your rights under the CCPA, you must provide us proof in the form of a signed, written authorization of the authorized agent’s ability to act on your behalf. You must also provide us with your full name, email address and mailing address to enable us to verify your identity.  We will confirm receipt of your verifiable consumer request within 10 business days of our receipt. We will also provide you with information about our verification process and when you should expect a response.

We will disclose and deliver the personal data required within 45 days of receiving your verifiable consumer request.  Should we require more time (up to an additional 45 days), we will notify you of the extension and the reasons for the delay.  The disclosure will cover the 12-month period preceding the receipt of your verifiable consumer request.

If requests from you are manifestly unfounded or excessive, we may charge a reasonable fee to respond to your request or we may refuse to act on the request. If we choose not to act on your request, we will notify you of the reasons behind our decision.

APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this privacy policy.

 

If you do not consent to the collection, use and disclosure of your personal data as described in this privacy policy, please do not provide us with personal data.