Broadway Across America
  1. Who We Are. Broadway Across America and Broadway Across Canada (collectively, “BAA”), are leading presenters of touring Broadway in North America (“Us”, “We”, “Our”). Our websites include and
  2. Why We Have Instituted This Privacy Policy. BAA has created this Privacy Policy (“Policy”) to be as transparent as possible with regard to how We obtain, maintain, and ultimately use information provided to Us by consumers like You (“You”, “Yours”). The Policy applies to all information provided to Us by You through any means. For purposes of illustration only, this Policy applies to all users of Our websites, Our mobile application(s) (e.g. iPad app), Our services available via telephone and those transactions that take place in person, by postal or electronic mail, or other sites or services where this Policy appears (each a “Site”, or collectively, the “Sites” or “Our Sites”), as well as information collected from our third party ticketing providers’ websites, and systems.
  3. Where this Policy Applies. Transactions that transpire on Our Sites occur, or are deemed to occur, within the United States of America (“USA”). This Policy shall be governed solely by the privacy and other laws and regulations of the USA. BAA makes no representation or warranty that Our Sites or services operate in accordance with the laws of any other nation, or that they or any part thereof, are appropriate for use in any particular nation or political subdivision (collectively referred to as “Nation”). Those who access and use Our Sites from another Nation do so at their own initiative and risk and are responsible for complying with all local laws, rules and regulations of the Nation from which Our Sites are accessed. Your use of Our Sites is Your acknowledgement that Our Sites and the products and services rendered by Us are subject to the laws and regulations of the USA, and You specifically waive any right to pursue claims that may arise under the laws of Your home Nation or the Nation from which You access Our Site.We reserve the right to change, modify, add, or remove (“Change”) provisions of this Policy and We will endeavor to notify You of any such material Change. Any such Change shall be effective immediately. Please check back from time to time to ensure continuing familiarity with the most current version of Our Policy. You can determine whether this Policy has been revised since Your last visit to Our website by referring to the “Last Updated” legend at the bottom of this page.
  4. Your Consent. Please read this Policy carefully. Your use of Our Site or Your use of other means of providing Your PII (as defined below) to Us constitutes Your acceptance of the terms and conditions of this Policy without limitation, qualification or change. Your continued use of Our Sites or Your use of other means of providing Your PII to Us including Our non-electronic services (e.g. in-person box office sale) is Your consent to be bound by the terms and conditions of this Policy and Your promise to abide by the practices We describe herein, in Our printed materials, and in other places on Our Sites. If You do not agree with this Policy or any other policy on Our Sites, or in Our printed materials, do not use Our services or Sites.
  5. What Information We Collect. BAA uses SSL or “Secure Sockets Layer”, an industry standard protocol, for completing online transactions including when We gather information from You.
    1. Personally Identifiable Information. We may collect personal identifiable information (“PII) from You through the use of Our Sites. As used in this Policy, PII is information that specifically identifies You as an individual, such as Your name, residential address, city, state and zip code, birth year, e-mail address and billing information.
    2. Non-Personally Identifiable Information. In addition to the above, We may also collect Non-Personally Identifiable Information (“Non-PII”) on Our Sites. Non-PII is information that does not identify You personally, however, note that Non-PII may be specific to Your device. When You visit and interact with the Site, We and third parties with whom We have contracted to provide services to Us, may collect Non-PII. For example, Non-PII includes Internet protocol addresses and web logs, and other electronic information collected through cookies, pixel tags, and other similar technologies, and information that may be aggregated (as explained below). Non-PII can also include a catalog of Sites visited, the number of visits to, and, average time spent on, the Sites.
  6. How We Collect Information.
    We obtain the information described above as follows:

    1. Directly from You. We collect PII from You when You choose to provide Your PII directly to Us. For example, We collect PII from the forms You complete or in connection with the products and services You purchase on Our Sites. For clarity, this includes purchases you make on any BAA Sites as well as other sites and services where this Policy appears.
    2. Indirectly from You. We collect Non-PII from observing Your actions on Our Sites including information collected automatically by Our Site’s servers, through cookies, Pixel Tags, and cookies. Additional detail about the manner in which such information is collected is provided below:
      1. IP Protocol Addresses and Web Logs. Our Site’s web servers automatically collect the Internet Protocol (IP) addresses and log files of visitors. Your IP address is an identifying number that is automatically assigned to Your computer by an Internet Service Provider (ISP). This number is identified and logged automatically in Our server log files whenever You visit Our Sites, along with the time(s) of Your visit(s) and the page(s) that You visited. We use Your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site’s servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many sites. In addition to the Non-PII usage of IP Addresses described above We also may link Your IP address to PII for fraud prevention purposes, in which case We will treat such IP address as PII.
      2. Pixel Tags. We and Our service providers may also use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some Site pages and HTML-formatted e-mail messages to track Your use of Our Sites in order to provide You with more useful information and a more personalized experience the next time You visit. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags do not contain any PII and allow Us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when an e-mail has been opened.
      3. Cookies. We and Our third party service providers may use a standard technology called a “cookie” to collect information about how You use the Site. Cookies reside on Your computer and help the Site recognize Your computer’s browser as a previous visitor. On occasion Our Site may also set a “session cookie” which helps Us administer the Site. The session cookie expires when You close Your browser and does not retain any information about You after it expires. If You do not want information collected through the use of cookies, You should be able to modify Your browser preference to provide You with choices relating to cookies. If You choose to reject cookies, You may be unable to use certain Site services (e.g., those services that require You to log on to the Site in order to participate). Understand that technology is ever changing and We move forward and employ the latest forms of technology to assist Us in providing Our customers with better experiences. This includes the use of behavioral advertising and cookies associated therewith.
    3. Third Party Ticketing Sites. We collect your PII from third party ticketing sites. For example, We collect PII from purchases You make which are initiated through BAA’s Sites but are ultimately completed on a third party’s website or system (such as a venue’s website or system), or from purchases to our attractions that are made through a third party ticketing provider. The PII that We collect in connection with Your transactions on such third party’s websites or systems will be treated by Us in accordance with this Policy. Please note that such PII and Your use of the third party’s website or system is also subject to the third party’s own privacy policies. We are not responsible for these third party uses of Your information and encourage You to review the applicable privacy policy on the third party ticketing providers’ websites and systems.
  7. How Information We Collect Is Used. We know You want Your PII information You share with Us to be protected from unauthorized use. That’s why We take appropriate security measures to help safeguard this information from unauthorized access and disclosure. For example, only employees integral to providing You with the product(s) or service(s) You request from Us are permitted to access Your PII, and they may do so for limited reasons. We encrypt credit card numbers and other sensitive information before it is sent from Your computer to Ours. We also use firewalls to help prevent unauthorized access to Your PII.We want for You to feel confident when using Our Site. However, You should know that no system is completely secure. Although We use industry accepted and commercially reasonable efforts to secure Your information, there is always a chance that it will not always remain secure. For example, avoid sending PII through insecure e-mail. We will not ask for You to send Us any financial information via electronic mail.We use Your information, including PII, as noted below:
    1. Site. The information collected may be used to provide You with the Sites, tailor Your Site experience to Your interests, to show You content in which You may be interested and to display the content according to Your preferences. Your information may also be used to analyze, improve, and develop Our Sites, including the features and functionality of such Sites. We may also share Your PII within the BAA business family in order to enhance Your experience on other websites that are part of Our business family or otherwise for Our affiliates’ use in accordance with this policy. To the extent We do so, We make sure that Your PII receives the same level of protection as it does on Our Sites. All companies affiliated with Us are required to comply with applicable privacy and security laws applicable to them and, at a minimum, in any commercial e-mail they send to You, will give You the opportunity to choose not to receive such e-mail messages in the future. Please note that such sharing may involve the collection, use, storage, or disclosure of PII outside the US. FOR CANADIANS: Please note that such sharing may involve the collection, use, storage or disclosure of PII outside of Canada in the U.S. and therefore Your PII may be subject to access under the laws of that jurisdiction.
    2. Communications. When You complete a ticket purchase, becoming a customer of Us, You will be automatically enrolled to receive future communications from Us including Our newsletter. Unless You opt out, We may use Your PII to send You information about Us, Our services, as well as promotional material on behalf of companies within Our business family and select partners, where and as long as permitted by applicable law.
    3. Administrative Matters. We reserve the right to contact You in the event of a change in the Policy or to notify You of other administrative matters in connection with the Site or Our business (e.g., contacting You to facilitate, complete or confirm a transaction), where permitted by applicable law. Where this information facilitates, completes or confirms a transaction with Us, or where this information may be otherwise important to Your use of the Site, You may not opt-out of receiving such communications, except where applicable law requires.
    4. Fulfillment of Requests. We may use Your PII to fulfill the purpose for which such PII was provided (e.g., to confirm Your registration, maintain Your account, or fulfill Your purchase). Once You have registered with Our Site, forms may sometimes be pre-populated with Your PII in order to facilitate a transaction between You and Us on subsequent visits.
    5. Internal Business Purposes. We may also use the information We collect for Our internal business purposes, such as for data analysis, for audits, for fraud prevention, for testing, research, and product development, to help maintain the safety, security, and integrity of Our Sites, products and services, databases and other technology assets, and business, to diagnose problems with Our servers and to administer the Site in general, and for other internal purposes.
    6. Purchases. From time-to-time We may offer merchandise and/or other products or services for sale from one of Our e-commerce partners. To the extent the merchandise and/or ticket purchase services are offered by one of Our e-commerce partners, such e-commerce partner will be collecting and using the PII You provide. For more information regarding Your transactions with Our e-commerce partners, please refer to the section entitled “Transactions With E-Commerce Partners, Vendors and Advertisers” below.To the extent that We are offering the purchase services, when You make a purchase through the Site, We will collect Your credit card number or other payment account number (for example, Your PayPal account number), billing address (including zip code) and other information related to such purchase (collectively, “Payment Information”) from You. We will use the Payment Information for billing and fulfillment purposes. We may also use Your Payment Information to allow Us to confirm Your purchase, deliver tickets and/or receipts to You, respond to customer service requests, review and enforce limits on the number of tickets purchased per event and to help prevent credit card fraud. By providing Your Payment Information, You are authorizing Us to share such information with certain third parties for these purposes (e.g., to process Your credit card or payment account number and to send You products You have ordered).
    7. Online Surveys and Sweepstakes. On occasion, We may conduct online surveys and/or offer sweepstakes on the Site (each referred to as a “Promotion”), and We may collect PII when doing so. We may use Your PII to contact You regarding Your Promotion entry, or to contact You if You win a Promotion (if applicable), where permitted by applicable law. You should carefully review the Promotions rules (if applicable) in which You participate through the Site, as they may contain additional important information about Our use of Your PII. To the extent such rules conflict with this Policy, such rules will govern that particular Promotion.
    8. Advertising. Any ads appearing on Our Sites may be delivered to You by Our third party advertising partners. In the course of serving advertisements to Our Sites, Our third-party advertiser may place or recognize a unique cookie on Your browser. Further, We may, and may work with third parties to use information collected on Our Sites and elsewhere through the use of cookies and similar methods in order to serve You with relevant advertisements (including on other services) or to determine that You have seen Our advertisements (including on other services). For example, if You view information on Our Sites regarding a particular product, We may target advertising to You on other websites and services (such as unaffiliated websites and social media services) about the same or other related products. This method of advertising is sometimes called “behavioral advertising” or “interest-based advertising.” We believe that such advertising is helpful because You will see advertisements that are relevant to Your interests. However, if You would like to opt-out of these interest-based advertisements, please follow the opt-out process described below under “Opt-Out Policy.”
    9. Consent. Please note that if You specifically consent to additional uses of Your PII, We may use Your PII in a manner consistent with that consent.
  8. How Information We Collect Is Disclosed
    1. Affiliate Communications and Third Party Communications. Unless You opt out, We may share Your PII with Our affiliates, including venues, promoters or sponsors of events, artist representatives and fan clubs, teams, leagues and others who are involved in or bring You events. When You buy or sell tickets or bid in an auction on Our Site (or try to do these things), You consent to allow Us to provide Your PII to these event providers and their contractors. We share this information so these event providers may send You announcements and notifications of events, products or services that might be of interest to You, where permitted under applicable law. For further information, please see the “Opt-Out Policy” section below.
    2. Service Providers. We work with third parties who provide services including but not limited to data analysis, order fulfillment, credit card processing and other services of an administrative nature. We want for You to know that We reserve the right to share Your PII with such third parties for the purpose of enabling these third parties to provide such services to Us so that We may provide Our services and/or merchandise. We take reasonable steps to ensure these third parties treat PII in a manner comparable to how We do so.
    3. Online Surveys/Sweepstakes. We may share PII collected in connection with Promotions conducted through Our Sites with the third-party sponsor(s) and/or the prize provider(s) of any such Promotions (irrespective of whether such Promotions are hosted by Us), or otherwise in accordance with the rules applicable to such Promotion. You should carefully review the rules, if any, of each Promotion in which You participate through the Site, as they may contain additional important information about a sponsor’s or other third parties’ use of Your PII. To the extent such rules conflict with this Policy, the rules of the particular Promotion shall apply.
    4. Other Purposes. We also may disclose Your information:
      1. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or another government agency; to establish or exercise Our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, We may raise or waive any legal objection or right available to Us.
      2. When We believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Our company, Our users, Our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce Our Site terms and conditions or other agreements or policies.
      3. In connection with a substantial corporate transaction, such as the reorganization or sale of Our business, a divestiture, merger, consolidation or asset sale, or in the unlikely event of bankruptcy.
      4. We reserve the right to share Non-PII, with third parties, for example, advertisers, who are not part of the Our family on an aggregate or other basis that does not disclose any of Your PII. In some instances, We may combine Your Non-PII with PII (such as embedding e-mail addresses in cookies). If We do combine any Non-PII with PII, the combined information will be treated as PII. This “combined” PII is not shared with third parties, except as described in this Policy.
  9. Collection of Information by Affiliates and Other Third Parties
    1. Co-Branded Pages. We may enter into relationships with business partners, sponsors, and affiliates wherein a co-branded site is delivered to You (referred to here as “co-branded pages”). These might include, for example, pages that share Our name and that of another entity. An example being “Acme powered by Broadway Across America”. There may be a specific privacy policy on any such co-branded page. Any PII that You provide when signing up at any co-branded page may be collected by, or shared with, Our partner, affiliate or sponsor. We have no control over, and are not responsible for, how such PII is used by such partner, affiliate, or sponsor. If You want to learn more about other entities’ privacy practices, please review the sites and privacy policies of those third parties.
    2. Transactions With E-Commerce Partners, Vendors and Advertisers. When You provide PII to one of Our Site’s e-commerce partners, vendors or advertisers, this transaction will occur in connection with the site of the e-commerce partner, vendor or advertiser, not on the Site, and, as such, the PII You provide is collected pursuant to and controlled by the privacy policy located on that site. BAA is not responsible for the privacy policies of Our e-commerce partners, vendors, or advertisers and We encourage You to familiarize Yourself with the applicable privacy policy of the e-commerce site with which You transact business or to contact the operator of such site for more information.Please be aware that at times, at the request of or on behalf of Our e-commerce partners, vendors or advertisers, BAA may “pre-populate” forms with Your PII for Your review, and, if You so choose, for submission to such e-commerce partners, vendors or advertisers. Accordingly, We encourage You to review each pre-populated form carefully before agreeing to submit Your PII to determine who is seeking to collect Your information, and to familiarize Yourself with the applicable privacy policy governing use of any PII collected about You.The third party collecting Your PII will share such PII with Us so that We can review Your information and, if applicable, respond to Your query or job application. Please note that We have no obligation to respond to all queries or job applications submitted. Any PII that We receive from such third party will be treated in accordance with this Privacy Policy.
    3. Third Party Advertising. Any ads appearing on the Site are delivered to You by Our third party advertising partners. In the course of serving advertisements to the Site, Our third-party advertiser may place or recognize a unique cookie on Your browser. Non-PII about Your visits to the Site, such as number of times You have viewed an ad, is used to serve ads to You. Some of these third parties may be advertising networks that are members of the Network Advertising Initiative, which offers a Site to opt out of ad targeting from several advertising companies (
    4. Third Party Links. The Site may contain links to third-party Internet sites, which are not owned or operated by Us. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by Us. If You provide any PII through any such third-party site, Your transaction will occur on such third party’s site and the PII You provide will be collected by, and controlled by the privacy policy of, that third party. We are not responsible for the privacy practices or the content of such third-party Sites, including such Sites’ use of any PII that You provide to them. We strongly encourage You to become familiar with the privacy practices of those sites.
  10. Opt-Out Policy
    1. Communications. When You supply Us with PII, from time-to-time, in Our discretion, You may be asked to indicate whether You are interested in receiving information from Us, about special offers in connection with the Site, from BAA affiliates and/or Our advertisers and partners. Unless You opt out to receive such communications, We may, from time to time, send You such marketing communications. FOR CANADIAN RESIDENTS: Notwithstanding the foregoing, We will not send You such marketing communications by electronic message unless You have expressly consented to receive them and have not withdrawn Your consent in accordance with the following.If You no longer desire to receive the commercial e-mails We send, You will be given the opportunity to opt out of receiving such messages in the future by clicking on the link at the bottom of the e-mail that says “unsubscribe,” “opt out”, or “To update Your email preferences or to be removed from Our lists”. It may take up to 10 days for Us to process an opt-out request. Even if You have unsubscribed from receiving third party promotional e-mails from Us, We may send You other types of important e-mail communications without offering You the opportunity to opt out of receiving them, where permitted by law. These may include customer service announcements, administrative notices and surveys. Please note that opting out of receiving promotional e-mail communications will affect only future communications from Us. If We already provided Your information to a third party before You changed Your preferences or updated Your information, You may have to change Your preferences directly with that third party as well.
    2. Affiliate and Third Party Communications. From time-to-time, You may be provided with the opportunity to opt-in to receive offers directly from third parties. Once You have opted in to such opportunities, unless You opt out to accept any such offer(s), any PII provided to Us for such purposes may be shared with third-party partner(s), to allow such third parties to provide You with valuable information You may enjoy. If You would prefer that We no longer share Your PII with Our affiliates and/or with third parties for their marketing purposes, You may opt-out of such future sharing at any time by following the procedure above, provided however, You may not be able to opt out of certain third party offers that are displayed on Our Site except where applicable law requires.
    3. Interest Based Advertising. The online advertising industry provides a service through which You may opt-out of receiving interest based ads from certain data partners and other advertising partners that participate in self-regulatory programs. You can opt-out of targeted advertising from certain providers at You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) on the NAI website.Please note that by opting out, You will continue to see generic advertising that is not tailored to Your specific interests and activities. The opt-out process through the Digital Advertising Alliance (DAA) relies upon the placement of an opt-out cookie on Your device. To be clear, cookie-based opt-outs must be performed on each device and browser that You wish to have opted-out. For example, if You have opted out on the browser of Your computer, that opt-out will not be effective on Your mobile device. You must separately opt out on each device and each browser. If You delete Your cookies, You will need to opt out again. For targeted advertisements delivered through mobile apps, You can install the DAA’s AppChoices app on Your device to opt-out of targeted advertising by certain providers and can also select a system level advertising preference feature on Your device (such as “Limit Ad Tracking” on Apple devices or “Opt-out of Interest-based ads” on Android devices). Please note that We do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
  11. Use of This Site by Children Under the Age of 13 Prohibited. BAA is a family oriented business. We adhere to the principles set forth in the Children’s Online Privacy and Protection Act (“COPPA”), as amended, and ask You, if a parent or guardian of minor children, to familiarize Yourself with the prescribes of COPPA. Our Sites are not developed with the intention that they will be used by minors and specifically, they are not directed to children age thirteen (13) or younger (or under sixteen (16) in the case of California residents). We request that any such person under the age of thirteen (13) (or under sixteen (16) in the case of California residents) years old not use Our Sites. If a parent or guardian believes that his or her child may have provided Us with PII, for example, by misrepresenting his or her age, that parent or guardian should contact Us at with the particulars of the information We are alleged to have collected. If We determine that Your child under the age of thirteen (13) years old (or under sixteen (16) in the case of California residents) has provided Us PII We will immediately delete all such information. For additional information regarding the use of the Internet by minors visit for tips from the Federal Trade Commission on protecting kids’ privacy online
  12. Accessing, Updating or Deleting Information Collected About You. You control the PII that You have provided to Us by way of the Sites. For example, on You may do so by linking to the “My Account” page and following the instructions to “Manage My Account” and modify Your user information. To the extent that such information is stored in Our databases, We will respond to Your changes as soon as reasonably possible. Please note that although this information will not be available on Our Sites after You delete it, the information may remain stored indefinitely in Our backup and archival records for legal and accounting purposes.
  13. Security of Your PII. We employ reasonable security measures consistent with standard industry practice, for PII collected through Our Sites, including physical, electronic and operational measures to maintain security and prevent unauthorized access. While We take reasonable and appropriate steps to safeguard PII under Our control, unfortunately, no data transmission over the Internet or method of storing data can be guaranteed to be one hundred percent secure. As such, We cannot guarantee that PII supplied by You will not be accessed on Our servers, or intercepted while being transmitted to Us over the Internet. We assume no liability for any damages You may suffer as a result of interception, alteration or misuse of information during such transfers. If You have reason to believe that there has been any breach of the security of the Site, please contact Us at
  14. Limitation of Liability. BAA will not under any circumstances be liable to You for any consequential, incidental or special damages (including but not limited to lost profits) arising out of Your use of Our Sites, even if apprised of the likelihood of such damages occurring. Notwithstanding the foregoing, BAA’s liability is limited to the actual cost of any product or service purchased by You through Our Sites.
  15. Contacting Us Regarding Our Sites. If You have any questions concerning this Policy, Our privacy practices or Your PII, You may send them by e-mail to Please note that e-mail communications will not necessarily be secure; accordingly You should not include credit card information or other sensitive information in Your e-mail correspondence with Us. You must send any official correspondence to:John Gore Theatrical Group, Inc.
    1619 Broadway, 9th Floor
    New York, New York 10019
    Attention: General CounselAny question You may have regarding Your privacy on Our Sites should be made in writing and sent to, general information regarding protecting Your data online, refer to the Federal Trade Commission’s website located at
  16. Information, Notices, and Rights Applicable to California Residents Only. California law provides California residents with specific rights regarding their “personal information.” This section describes the rights that California residents have and explains how to exercise those rights, subject in all cases to any limitations set forth under applicable California laws, including the California Online Privacy Protection Act and the California Consumer Privacy Act (“CCPA”).
      1. California Online Privacy Protection Act
        In accordance with the California Online Privacy Protection Act, California residents have the right to request information about how We share certain categories of personal information with third parties. California law gives You the right to send Us a request at a designated address to receive the following information:

        1. the categories of information We disclosed to third parties for their direct marketing purposes during the preceding calendar year;
        2. the names and addresses of the third parties that received that information; and
        3. if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

        If You are a California resident and wish to make such a request, please submit Your request in writing to

      2. California Consumer Privacy Act
        1. Information We Collect
          We collect information (some of which may also constitute PII) that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The CCPA refers to such information as “personal information”. Our Sites collect the following categories of personal information from California residents within the last twelve (12) months: identifiers, personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), commercial information, internet or other similar network activity, protected classification characteristics under California or federal law (e.g., age, gender), geolocation data, and inferences drawn from other personal information. Please refer to the sections entitled “What Information We Collect”, “How We Collect Information”, “How Information We Collect Is Used” and “How Information We Collect Is Disclosed” for more detail about the information collected, the purposes for which and sources from where We collect personal information, and the third parties with whom We share personal information. Please note that information that we collect that is not maintained in a manner that can be reasonably linked to a California resident or household, is not considered personal information.
        2. Sharing of Personal Information: We may disclose Your personal information to a third party for a business purpose or sell certain personal information, subject to Your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). We may share Your personal information with certain third parties as described above under “How Information We Collect Is Used” and “How Information We Collect Is Disclosed”.
          • Disclosures of Personal Information for a Business or Commercial Purpose: In the preceding twelve (12) months, We have disclosed identifiers, personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), commercial information, internet or other similar network activity, geolocation data, protected classification characteristics under California or federal law (e.g., age, gender) and inferences drawn from other personal information for a business or commercial purpose.
          • Sales of Personal Information: In the preceding twelve (12) months, We have sold identifiers, personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), commercial information, internet or other similar network activity, geolocation data, protected classification characteristics under California or federal law (e.g., age, gender) and inferences drawn from other personal information.
        3. California Specific Rights, Choices and Opt-Outs: The CCPA provides California residents with specific rights regarding their personal information. This section describes the rights that You have under CCPA if You are a California resident and explains how You can exercise those rights.
          1. Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that We disclose certain information to You about Our collection, use, disclosure or sale of Your personal information over the past 12 months. Once We receive and confirm Your verifiable consumer request (see Exercising Access, and Deletion Rights), and subject to certain limitations that We describe below, We will disclose such information to You. You have the right to request any or all of the following:
            • The categories of personal information We collected about You.
            • The categories of sources from which the personal information is collected.
            • Our business or commercial purpose for collecting or selling that personal information.
            • The categories of third parties with whom We share that personal information.
            • The specific pieces of personal information We collected about You
            • The categories of personal information about You that We have sold or disclosed for a business purpose.
          2. Right to Request Deletion. You have the right to request that We delete any of Your personal information that We have collected from You and retained, subject to certain exceptions. Once We receive and confirm Your verifiable consumer request (see Exercising Access, and Deletion Rights), We will delete (and direct Our service providers to delete) Your personal information from Our records. However, We may retain personal information that has been de-identified or aggregated. Furthermore, We may deny Your deletion request if retaining the information is necessary for Us or Our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting as illegal activity.
          3. Exercising Access and Deletion Right. To exercise the access and deletion rights described above, please submit a request to Us by either:

            Only You, or a person or business entity registered with the California Secretary of State that You authorize to act on Your behalf (an “authorized agent”), may make the requests set forth above. If You use an authorized agent to make a request, You must provide the authorized agent written permission to do so, and We may require that You verify Your identity directly with us. You may also make a request on behalf of Your minor child.

            The request should include Your contact information and describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it. In addition, We may ask You to provide additional information that allows Us to reasonably verify that You are the person about whom We collected the personal information or an authorized representative.

            For more information about verification, see Response Timing and Format. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

          4. Response Timing and Format. We will respond to consumer requests in a reasonably timely manner. If We require extra time to respond, We will inform You of the reason and extension period in writing. In order to protect the security of Your personal information, We will not honor a request if We cannot verify Your identity or authority to make the request and confirm the personal information relates to You. The method used to verify Your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by You to the personal information that We already have. Any disclosures We provide will only cover the 12-month period preceding Our receipt of Your request. We are not obligated to provide the information set forth above under “Right to Know About Personal Information Collected, Disclosed or Sold” more than twice in a 12-month period. We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing Your request.
          5. Personal Information Sales Opt-Out and Opt-In Rights
            You have the right to direct Us to not sell Your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us through the following link:, You may submit an opt-out request by emailing Us at You use an authorized agent to exercise the right to opt-out, You must provide the authorized agent written permission to do so, and We may deny the request if the authorized agent does not submit proof that it has been authorized by You to act on Your behalf. You may change Your mind and opt back in to personal information sales at any time by emailing Us at or through any other instructions We provide to You at the time We offer You the ability to opt-in. Please note that certain transactions or the use of certain products or services may require a sale of personal information.
          6. Non-Discrimination. We will not discriminate against You for exercising any of Your CCPA rights, including, but not limited to, by:
            • Denying You goods or services.
            • Charging You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
            • Providing You a different level or quality of goods or services.
            • Suggesting that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

            However, We may offer You certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to Your PII’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program, if any, requires Your prior opt in consent, which You may revoke at any time.

    Last Updated: July 6, 2020

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