Privacy Policy

U.S. Privacy Notice

This U.S. Privacy Notice (this “Notice”) constitutes part of and should be read in conjunction with the Luxon Terms and Conditions and Cookie Policy Notice. If you are a resident of the United States, this Notice explains how we may collect, create, process, store, protect, disclose, share and transfer your Personal Data as part providing our Services and/or otherwise as part of our business operations.

We have defined some terms that we use throughout the Notice. You can find the meaning of a capitalised term in the  Definitions section below or as otherwise may be defined in this agreement.

“Personal Data” means any information that identifies or is reasonably capable of identifying an individual, directly, or indirectly, such as a name or identification number, an online identifier or other identifiable characteristics and other information that is being associated with an identified or reasonably identifiable individual.

Luxon may also collect, create, process, store, protect, disclose, share and transfer your Non-Personal Data as part providing our Services and/or otherwise as part of our business operations. For example, Luxon may use anonymised and aggregated transactional information for commercial purposes such as reviewing or analysing transaction data and patterns.

Please note that Luxon provides services to both individual consumers and businesses and this U.S. Privacy Notice applies to both and should be read and interpreted accordingly.

This Notice

This Notice is issued by Luxon Pay, LLC (“Luxon Pay“, “Luxon” “we”, “us” and “our”), a Delaware limited liability company with company number 20254216183 whose registered office is 10233 S Parker Rd Ste 300, Parker, CO 80134.

This notice applies to individuals outside our organisation who are residents of the United States and with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our Services, and visitors to our premises (together, “you”). For the purposes of this Notice, Luxon is the Controller.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in Applicable Law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice. You can always find the latest version of this Notice here on this page.

This Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law.

Collection of Personal Data

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

• Data you provide to us: We obtain Personal Data when you provide those data to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your identity documents, or when you submit wage slips or other proof of funds documents, or when you provide other information required by Applicable Laws, or when you choose to provide us with information about your contacts or address book or provide information otherwise required by us to provide our Services).
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• Registration details: We collect or obtain Personal Data when you use, and/or register to use, any of our Sites, Apps, or Services.
• Content and advertising information: If you interact with any third party content or advertising on our Site or in our App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; identity service providers; global PEP and Sanctions watchlists; etc.).

Cookies and similar technologies

We, and our third-party partners, may also automatically collect information you provide to us and information about how you access and use Services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

• Device and network information: We may collect the device type, manufacturer, model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
• Usage information: We may collect the site from which you came, the site to which you are going when you leave our Services, how frequently you access our Services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our Services (such as the pages you visit, the content you view, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our Services, or engage in chat features or other communication platforms we provide.
• Location information: We may collect general geographic location that we or our third-party providers may derive from your IP address, as well as more precise geolocation when you grant us access through your device settings.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, and to improve the effectiveness of our products, services, offers, advertising, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your privacy choices section below. For additional details about the cookies we use on our websites and to adjust your preferences with regard to those cookies, please visit our “Cookie Preferences” manager linked in the footer of our websites.

Please note that third parties you interact with may have their own privacy policies, and we are not responsible for their operations or their use of the data they may collect. Information collected by third parties is governed by their privacy practices and we are not responsible for unauthorized or unlawful third-party conduct. We encourage you to learn and understand the privacy practices of any relevant third parties you engage with.

Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, or Services, including where those data are collected from different devices.

Categories of Personal Data we Process

We Process the following categories of Personal Data about you:

• Personal Identity Information: (such as given name(s), preferred name(s), gender, date of birth, age, nationality, title, language)
• Formal Identity Information: (such as government issued identity documents such as identity cards, passports, driving license and/or any other government issued or public information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.)
• Financial Information: (such as bank account and/or card details, routing number, location data and addresses, invoices, payment records, transaction history and/or other financial data)
• Transaction Information: (details of transactions on our Services, such as details of sender and receiver, amounts, timing and date, eWallet addresses)
• Employment Information: (such as job title, employer, location, proof of salary and/or earnings)
• Correspondence Information: (such as account registration details, email, contact number and home address)
• Contacts Information: (such as if you choose to provide us with information about your contacts and your address book by syncing, uploading or importing it to our App)
• Sensory Information: (any audio or visual information such as recordings of calls, CCTV videos and selfies for identity verification)
• Additional Information: (such as where we exercise discretion to collect information required to comply with legal/compliance obligations)
• Data relating to our Sites and Apps: (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site, App usage statistics, App settings, QR codes, dates and times of connecting to an App, location data, and other technical communications information (some of which may constitute Personal Data), username; password, security login details, aggregate statistical information.)
• Consent records: (such as records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent)).
• Service Information: (such as information about how frequently you use our Services, average transaction volumes, eWallet balances, people and merchants you send/receive money to/from and any other information provided or produced in the context of using the Services)

Uses of Personal Data

Disclosure of Personal Data to third parties

We disclose Personal Data within Luxon, for legitimate business purposes and the operation of our Sites, Apps, or Services to you, in accordance with Applicable Law. In addition, we disclose Personal Data to:

• You and, where appropriate, your appointed representatives;
• Any legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of Applicable Law or regulation;
• Accountants, auditors, lawyers and other outside professional advisors to Luxon, subject to binding contractual obligations of confidentiality;
• Third-party Processors and associated Processors (such as payment services providers) located anywhere in the world, subject to the requirements noted below in this Section;

• Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
• Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• Any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with Applicable Law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security or confidentiality of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

Data retention

We usually retain your Personal Data only for the minimum period necessary for the purposes set out in this Notice. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.  The criteria for determining the duration for which we will retain your Personal Data are as follows: the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once the retention of your Personal Data is no longer reasonably necessary for the purposes outlined above, we will either:

• Permanently delete or destroy the relevant Personal Data;
• Anonymize the relevant Personal Data; or
• If deletion or anonymization is not possible, securely store the Personal Data and isolate it from further active Processing until deletion or anonymization is possible.

Your privacy choices

Where we have your consent for the processing of your Personal Data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.

We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using Personal Data we maintain and Personal Data our third-party partners obtain from your activity over time and across non-affiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the Personal Data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform.

In addition to taking the steps set forth in the Cookies and similar technologies section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

• Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs.
• Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program.
• Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative’s self-regulatory program.
• Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services.  Instead, it means that the online ads you do see from relevant program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

Certain of our third-party providers and partners offer additional ways that you may exercise control over your Personal Data, or automatically impose limitations on the way we can use Personal Data in connection with the services they provide:

• Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as your mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.
• Google Analytics: Google Analytics allows us to better understand how our customers interact with our services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/.

You may also be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

Direct marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, or Services that may be of interest to you. If we provide Sites, Apps, or Services to you, we may send information to you regarding our Sites, Apps, or Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under Applicable Law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, or Services you have requested.

Children’s data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any Personal Data either directly or by other means. If a child under the age of 13 has provided Personal Data to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Data from our systems. If we learn that any Personal Data we collect has been provided by a child under the age of 13, we will promptly delete that Personal Data.

Contact details

Contact details for Luxon are as follows:

Luxon Pay, LLC, a Delaware limited liability company with company number 20254216183 whose registered office is 10233 S Parker Rd Ste 300, Parker, CO 80134.

Email: support@luxon.com

Definitions

• “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
• “Applicable Laws” means any applicable statutes, laws, ordinances, orders, judgments, decrees, rules or regulations issued by any government authority, and any judicial or administrative interpretation of any of these;
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Non-Personal Data” means any information which does not enable a specific individual to be identified either directly or indirectly and that is not associated with an identified or reasonably identifiable individual.
• “Personal Data” has the meaning as set out at the beginning of this Notice.

• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the controller.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under Applicable Law.
• Services has the same meaning as defined in clause 4.1 of the Luxon Terms and Conditions.
• “Site” means any website operated, or maintained, by us or on our behalf.

State-Specific Disclosures

These disclosures supplement the information contained above by providing additional information about our Personal Data Processing practices relating to individual residents of certain states in the United States.

Nevada Residents

If you are a resident of the state of Nevada, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by emailing us at support@luxon.com.

California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia Residents

If you are a resident of the state of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia in the United States the following supplementary disclosures apply to you:

Personal data disclosures, sales and targeted Advertising

We disclose all of the categories of Personal Data we collect to the categories of recipients set forth in the Disclosure of Personal Data to third parties section above. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws:

• Ad networks and advertising partners: IP address.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your state privacy choices section below).

Please note we do not sell the Personal Data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.

Sensitive Personal Data

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws:

• Government ID numbers, including social security number, driver’s license number, state identification card number, or passport number.
• Account log-in, financial account, debit card or credit card number in combination with any required security or access code, password or credentials allowing access to an account.
• Citizenship

We only use or disclose Sensitive Personal Data where reasonably necessary and proportionate for the purposes of providing products and performing services you have requested, verifying and improving the products and services we provide, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process Sensitive Personal Data without the purpose of inferring characteristics about the relevant individual, and we do not sell Sensitive Personal Data or process or otherwise share Sensitive Personal Data for the purpose of targeted advertising.

Automated decision-making and profiling

We use automated systems for transaction monitoring to highlight and potentially block suspicious transactions and for know-your-customer purposes. If any of these systems produce legal or similarly significant effects, you may request human review by contacting support@luxon.com.

Your state privacy choices

You have many rights that you may be able to exercise in relation to your Personal Data. These rights may apply under a number of different state laws.

Subject to Applicable Law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the Personal Data we have collected about you, including:
  • The categories of Personal Data collected;
  • The categories of sources of the Personal Data;
  • The purposes for which the Personal Data were collected;
  • The categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom this Personal Data were disclosed;
  • The categories of Personal Data shared for targeted advertising purposes (if any), and the categories of recipients to whom the Personal Data were disclosed for these purposes; and
  • The categories of Personal Data sold (if any) and the categories of third parties to whom the Personal Data were sold.
• Right to Access & Portability: The right to obtain access to the Personal Data we have collected about you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• Right to Correction: The right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.

• Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data.

• Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes.
• Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share Personal Data for certain targeted advertising purposes.
• Right to Deletion: The right to have us delete Personal Data we maintain about you.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in the Contact details section above. Please note that:

• In some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• Where your request requires the establishment of additional facts (e.g., your state of residency) we will investigate your request reasonably and promptly, before deciding what action to take.

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Additional California-Specific Disclosures

The following disclosures only apply to residents of the state of California.

California categories of Personal Data

California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data described in the Categories of Personal Data we Process section:

• Identifiers, such as name, address, and contact information.
• Customer records, such as financial account information and government-issued identity documents.
• Protected classification characteristics, such as nationality.
• Commercial information, such as transaction information and history, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet / network information, such as IP address or device information.
• Geolocation information, such as coarse location derived from IP.
• Sensory information, such as audio or visual information such as recordings of calls, CCTV videos and selfies for identity verification.
• Professional/employment information, such as job title, employer, location, proof of salary and/or earnings.
• Sensitive Personal Data, such as citizenship status and government-issued identifiers.
• Other Personal Data, such as any other information you contribute, submit, or upload.

Shine the Light

California’s ”Shine the Light” law (Civil Code § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of Personal Data to third parties for their direct marketing purposes. It is company policy that we do not disclose Personal Data to third parties for their direct marketing purposes if a consumer has exercised their right to opt out.  To opt out of having your Personal Data disclosed to third parties for their direct marketing purposes, please follow the instructions for opting out of targeted advertising and Personal Data sales above.