۶Ƶ GLOBAL PRIVACY POLICY

Last Updated: December 2024

DEFINITIONS

In this document:

  • “Personal Information” means information which identifies or is reasonably capable of being associated with you or your household (or, as applicable, your employer).
  • “Privacy Policy” means the current version of this ۶Ƶ Global Privacy Policy.
  • “We” or “۶Ƶ” means Transaction Network Services, Inc., and includes its global operating entities, affiliates, and their subsidiaries. Transaction Network Services, Inc., the global headquarters of the company group, is a USA-based corporation registered in Delaware, USA under Delaware Registration No. 3053051. Its principal office is located at Suite 100, 10740 Parkridge Blvd., Reston, Virginia, 20191 USA. Information on ۶Ƶ entities and locations around the globe can be found under the Our Locations section of the About ۶Ƶ
  • “You” refers to you, acting individually or on behalf of your employer.

PRIVACY COMMITMENT

۶Ƶ is committed to respecting the privacy of individuals’ Personal Information, protecting the security of any Personal Information that we collect, and ensuring that Personal Information is processed in accordance with applicable data protection law. This Privacy Policy is intended to describe our practices regarding Personal Information we collect from you or about you on our websites online, offline via written or verbal communications with us, mobile applications (“apps”), social networking presence, or from other sources. While this Privacy Policy broadly describes the practices we have adopted across ۶Ƶ globally, local laws vary and some jurisdictions may place restrictions on our processing activities.  Therefore, our actual practices in some jurisdictions may be more limited than those described herein to enable us to comply with local requirements. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

We recommend that you read the entire Privacy Policy to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Policy, you can click on one of the links below to jump to a specific section:

Personal Information Collection and Purpose

Information We Collect by Automated Means

With Whom We Share Your Personal Information

Automated Decisions About You

International Transfers of Personal Information

Protection of Personal Information

Retention of Personal Information

Your Personal Information Rights

Children

State Required Notices

How to Contact Us

Personal Information Processed by ۶Ƶ on Behalf of Its Customers

External Websites

Privacy Policy Updates

PERSONAL INFORMATION COLLECTION AND PURPOSE

We may collect Personal Information from you through our websites or by other means (such as email, fax, mail, phone, mobile applications, third party applications, our parent, subsidiary, or affiliate companies, business partners, and other third parties such as commercial data vendors and public databases). The principal ways you may provide the information and the types of information you may submit, as well as the ways we may use the information are listed below:

Business Alerts, Newsletters, and Other Communications – You may provide Personal Information such as your name and contact details to receive business alerts, newsletters and other communications (including emails). It is in our legitimate business interests to use the information you provide to send you the communications and information you have requested and to communicate with you about our products and services, unless prohibited by local data protection law. If you no longer want us to send you business alerts, newsletters or communications, you may unsubscribe at any time by contacting us via the contact information provided in the “How to Contact Us” section of the Privacy Policy.

Business Purposes – You may choose to provide, or we may obtain, your Personal Information at trade shows, industry forums, or similar types of events. It is in our legitimate business interests to use this information so that we can manage our business relationships and carry out marketing and sales activities, unless prohibited by local data protection law.

You may also choose to connect to us via social networking services (e.g., Facebook, Twitter, or LinkedIn). When you connect to us via a social networking service, take part in our discussion boards, or other forms of social media that are linked to our websites, we may collect your Personal Information that you have provided to that service in accordance with the service’s applicable Terms of Use and your privacy settings within that social networking service.

Careers – Individuals from all over the world apply for jobs with ۶Ƶ through ۶Ƶ Careers or similar websites, third-party job posting sites, or job fairs. The information job seekers provide through this process may be maintained by third-party service providers. This information may be maintained in locations within the United States, accessible to our global recruiting team, and be shared with our corporate affiliates for the purpose of evaluating you for positions within ۶Ƶ. The information submitted by job seekers, such as name, contact details, and any other information relevant to the application is used to evaluate their qualifications for employment and to contact them regarding possible employment opportunities. It is in our legitimate business interests to use this information in the selection process and to communicate with you, and it will be necessary to provide us with this information so we can assess your application. For those individuals who accept an employment offer from ۶Ƶ, information you provided during the recruitment process may be used in the pre-hire process and entered into your employee profile within our HR systems. This information will be used for human resources administration, reporting and management, and legal/regulatory compliance. You may request to update or modify your information as needed.

To allow ۶Ƶ to meet certain government recordkeeping and reporting obligations, job seekers may choose to provide sensitive personal information, such as race, gender, disability status or ethnic background. This information will not be considered in evaluating candidates’ qualifications for employment.

Contact – If you contact us with questions, requests or comments through a “Contact Us” link on our website, by similar means on ۶Ƶ affiliates’ websites, or via the contact information provided in the “How To Contact Us” section of this Privacy Policy, we may process your personal information to verify your identity or to track the inquiry internally to ensure we respond to your questions, requests or comments. If you elect to provide us with this information, it may include your name, email address, and telephone number.

Competitions or Sweepstakes – We may collect Personal Information such as your name and contact details if you wish to voluntarily participate in any competitions or sweepstakes so that we may contact your if you are a winner. We will ask for your consent to process your data for this purpose. You can withdraw your consent at any time by contacting us via the contact information provided in the “How to Contact Us” section of the Privacy Policy.

Contractual Obligations – If you are a vendor, contractor, or customer, we may ask you to provide Personal Information such as your name, contact details, or business and financial details to establish and administer your account, to conduct our business, including providing products and services to you (including support), performing administrative operations, and accounting. In some cases, this Personal Information may be provided to us by your employer, where we are providing your employer with a product or service for which you are the point of contact. We use your information for this purpose so that we can comply with our contractual obligations to you.

Feedback – You may be able to submit feedback on our websites, or to participate in surveys we conduct related to ۶Ƶ, our products and services, or for quality control purposes. If you choose to give us your feedback, we may ask you for your Personal Information. It is in our legitimate business interests to use the information you provide to enhance our websites, evaluate the quality of our products, or to communicate with you about products and services where we are allowed to do so under local data protection law.

IT Systems and Facilities (Logical and Physical Security) – We may collect Personal Information when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations. We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets, and to maintain optimal performance of our IT systems. Likewise, to ensure physical security of our facilities we may, where permitted under local law, document your presence or verify your identity, utilize surveillance systems and/or location tracking while you are on ۶Ƶ property.

Other Uses of Information – We may use the Personal Information you provide to us for internal general business purposes in accordance with our legitimate business interests, unless prohibited by local data protection law. These purposes include administration of our websites, data analytics, product development, fraud prevention and compliance with our legal obligations, standards, policies, and procedures.

We may obtain your explicit consent to collect and use certain types of Personal Information when we are required to do so by law (for example, in relation to our direct marketing activities, or when we process sensitive personal information). If we ask for your consent to process your Personal Information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy.

INFORMATION WE COLLECT BY AUTOMATED MEANS

When you visit and interact with our websites and applications, we may collect “Other Information” that does not inherently reveal your specific identity, in order to learn how to best tailor our websites for our visitors. Examples of what Other Information we may collect and how we and third-party service providers may collect this information include:

Aggregated Information – We may collect, track, and use various types of data that are aggregated, de-identified, or otherwise not reasonably capable of identifying you or being linked with you. For example, we may aggregate user information to calculate the percentage of our users who have a particular telephone area code. Aggregated information is treated in accordance with this Privacy Policy.

Browser and Device Information – Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system name and version, device manufacturer and model, Internet browser type and version and the name and version of the online services (such as the apps) you are using. We use this information to ensure that the online services function properly.

Cookies – Cookies are pieces of information stored directly on your device. Cookies allow us to collect information such as time spent on the online services, pages visited, and other aggregated website traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, and to personalize your experience while online. Without your consent, where required by law, we will only use essential cookies that are necessary for us to ensure proper delivery of our websites’ functionality.

Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the online services or to send you advertisements and marketing emails. We may also use cookies or other technologies to track responses to our online advertisements and marketing emails.  You can opt out of such interest-based advertising using cookies set by participating NAI members at: http://optout.networkadvertising.org/#!/.  Opting out of interest-based advertising does not mean you will no longer see advertising online. It does mean that the company or companies from which you opt out will no longer show ads that have been tailored to your interests.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You can choose whether to accept cookies by changing the settings on your browser or, depending on your jurisdiction, by managing your tracking preferences as noted in a separately posted cookie statement or via a posted cookie manager.  If, however, you do not accept cookies, you may experience some inconvenience in your use of the online services.  For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs.  At this time, we do not respond to browser “Do-Not-Track” signals except in jurisdictions where we are required to do so by law.

IP Address – Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services.  We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our online services.  We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.

Pixel Tags or Similar Technologies – Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some online services to, among other things, track actions of users of the online services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the online services and response rates. We also use tools such as Google Analytics and Facebook Pixels, which use cookies and similar technologies to collect and analyze information about use of our services and report on activities,  trends and personalization of content and ads. These services may collect information regarding the use of other websites apps and online resources.   You can learn about Google’s practices by going to , and opt-out by downloading the Google Analytics opt-out browser add-on, available at . You can learn about Facebook’s practices by going to   and opt-out  by visiting  Ի.

WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

۶Ƶ does not sell any Personal Information for monetary consideration. We may share the categories of Personal Information we obtain about you (as described above) with the categories of third parties described below. We may share your information as disclosed at the time you provide it and/or in the following circumstances:

Business Transfers – We may share your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Policy.  Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

Corporate Affiliates – We may share the information you provide internally and with other ۶Ƶ companies for purposes described in this Privacy Policy. We do this to run our business more efficiently and to have a better understanding of our customers across business lines.

Law Enforcement Agencies, Courts, Regulators, Government Authorities or other Third Parties – We may transfer and share your information to third parties (i) to comply with a legal obligation, (ii) when we believe in good faith that the law requires it, (iii) at the request of governmental authorities conducting an investigation, (iv) to verify or enforce our policies, Terms of Use and other agreements or to protect the rights, property, or safety of ۶Ƶ, our customers, or others (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity or (vii) otherwise to protect the rights, property, safety, or security of third parties, users of our services or the public.

Sharing With Your Consent – Our services may present you with the opportunity to opt in to receive information or marketing offers from third parties or to otherwise consent to the sharing of your Personal Information with third parties. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third-party subject to the privacy notice and business practices of that third party, unless prohibited by local data protection law.

Third-Party Service Providers – In order to carry out your requests, to make various features, services and materials available to you through the services, to respond to your inquiries, and for other purposes described in the “Personal Information Collection and Purpose” section of this Privacy Policy, we may share your Personal Information or usage information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that: host or operate our sites; analyze data; provide customer service; manage payments; advertisers; sponsors or other third parties that participate in or administer our promotions; provide marketing or promotional assistance; assist with risk management, compliance, legal and audit functions. These service providers are not authorized by us to use or disclose the data except as necessary to perform services on our behalf or comply with legal requirements.

AUTOMATED DECISIONS ABOUT YOU

We may make automated decisions about you using your personal information in the following circumstances:

  • Automated processing may be used when evaluating large numbers of applicants for job vacancies. For these purposes we would request that you create a profile and answer some job-related questions to evaluate your skills as compared to the published job requirements.  An algorithm may then be used to determine which candidates will be allowed to proceed to the next step within the selection process. We consider this data and process to be relevant because it will assist us to select the applicant most suitable for our vacancies.  The outcome of the evaluation may have an impact on whether you are offered a role for the vacancy to which you applied.

You can contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy to request further information about automated decision-making, object to our use of automated decision-making, or request an automated decision to be reviewed by us if required by local law.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

۶Ƶ is a global provider of electronic transaction and communication solutions – headquartered in the United States – that does business in many countries. In connection with the purposes set forth in this Privacy Policy, we may store Personal Information at, and transfer Personal Information to, other ۶Ƶ affiliates and subsidiaries, our service providers, and other third parties that may be in countries outside of your own. By using our websites, or by providing us with any information, you consent to the collection, processing, maintenance and transfer of such information outside of your own country where privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen. Where any such storage or processing takes place, appropriate controls are in place to ensure that your Personal Information is protected. Where we are required to do so by the applicable laws, we ensure that before transferring your Personal Information outside your country of residence we comply with the requirements of applicable laws, such as the adoption of contractual agreements with the other party. For more information on the appropriate safeguards in place, please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy.

PROTECTION OF PERSONAL INFORMATION

The security of your Personal Information is important to us. We maintain reasonable administrative, technical and/or physical safeguards and appropriate security measures to protect Personal Information from loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide. Our employees as well as our service providers who have access to Personal Information are obligated to protect it and keep it confidential. However, we cannot guarantee the security of your Personal Information, as no system or electronic data transmission is completely secure. If an incident is reported affecting your information, we will investigate and comply with all required reporting obligations.

RETENTION OF PERSONAL INFORMATION

We may store your Personal Information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your Personal Information for a period of time that enables us to:

– Maintain business records for analysis and/or audit purposes

– Comply with record retention requirements under the law

– Defend or bring any existing or potential legal claims

– Address any complaints regarding the services

We will delete your Personal Information when it is no longer required for these purposes or where it otherwise is no longer needed for any purpose for which it may have been collected. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

We may also retain certain information obtained from your Personal Information where such information has been aggregated, de-identified, anonymized, or pseudonymized such that it is no longer capable of identifying you.

YOUR PERSONAL INFORMATION RIGHTS

You have choices about how ۶Ƶ collects and uses your data. You can exercise your Personal Information rights by contacting ۶Ƶ as noted in the “How to Contact Us” section below or by clicking . We will respond to you within the time limits established by applicable law.

Namely, you have the following rights in connection with processing of your Personal Information performed by ۶Ƶ, subject to applicable law:

  • access your Personal Information;
  • correct the Personal Information we hold about you;
  • erase or delete your Personal Information;
  • restrict our use of your Personal Information;
  • object to our use of your Personal Information;
  • withdraw your consent for us to use your Personal Information, if applicable;
  • receive your Personal Information in a usable electronic format and transmit it to a third party (right to data portability);
  • opt out of the processing of your Personal Information for purposes of targeted advertising, certain profiling, or the sale of your Personal Information; and
  • lodge a complaint with your local data protection authority or privacy regulator (if applicable).

Subject to applicable law, you may appeal our decision with respect to a request you have submitted by contacting ۶Ƶ as noted in the “How to Contact Us” section below.

CHILDREN

Our products and services, as well as our websites, are not directed to nor intended for use by minors. We do not knowingly collect any Personal Information from children under the age of 16.

STATE REQUIRED NOTICES

California: If you are a California resident and have provided us with your Personal Information, you may ask us to refrain from sharing your Personal Information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes. Please tell us your preference by contacting us via the contact information in the “How to Contact Us” section of this Privacy Policy. Scroll down to view our California Consumer Privacy Notice.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or how ۶Ƶ handles your Personal Information, please contact us by email at privacy@tnsi.com, or write to us at:

Transaction Network Services Inc.
Attention: Data Protection Officer

10740 Parkridge Boulevard, Suite 100, Reston, Virginia 20191, United States

PERSONAL INFORMATION PROCESSED BY ۶Ƶ ON BEHALF OF ITS CUSTOMERS

۶Ƶ does not collect, or otherwise have access to, Personal Information sent or received by its customers in the course of them using ۶Ƶ’ processing technology solutions (‘transactional Information’). When our customers collect information from their end users through our products and services, this Privacy Policy does not apply to that collection of information. This is because our customers, as data controllers, are directing the collection of that information, and ۶Ƶ has no direct relationship with our customer’s end users. ۶Ƶ does not control our customers’ collection or use of the end users’ information.

To learn how a ۶Ƶ customer, such as a relevant financial institution, card or account provider, or merchant through which a transaction was processed, uses the information it collects through ۶Ƶ’ products or services, please see that customer’s privacy policy. If you are an end user who seeks access, or who seeks to correct, amend, or delete inaccurate data, or if you are an end user of one of our customers and would no longer like to be contacted by that customer, please contact them directly.

EXTERNAL WEBSITES

Our websites may contain links to external websites. If you use those links to leave our website and visit a website operated by an entity not within ۶Ƶ, we have no control over that website, and we cannot be held responsible for the collection, use, or protection of your Personal Information on that external website. If you provide information on and use third party services or websites, the privacy policy and terms of service on those sites are applicable. The collection, protection, use, sharing, processing, and retention practices regarding Personal Information on such external websites may be different than the practices described herein. We encourage you to read the privacy policies of websites that you visit before submitting Personal Information.

PRIVACY POLICY UPDATES

This Privacy Policy is periodically reviewed and updated. The date of the last update to this Privacy Policy appears at the top of this document. We reserve the right to modify this policy at any time without prior notice. When the notice is updated, we will provide information about any substantial changes we have made, as well as the date of the update.

California Consumer Privacy Notice

Last Updated: December 2024

This California Consumer Privacy Notice for California residents (“Notice”) supplements the ۶Ƶ Privacy Policy and applies only to the Personal Information collected online and offline of California consumers (excluding ۶Ƶ employees, contractors and other personnel).

This Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”). Your rights and our obligations under CCPA are explained below.

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated Date of this Notice), the following types of Personal Information:

  • Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology, telephone number, online identifier, internet protocol address, email address, account name, and other similar identifiers.
  • Additional Data Subject to Cal. Civ. Code § 1798.80: Education, credit card number, debit card number, and other financial information.
  • Protected Classifications: Characteristics of protected classifications under California or federal law, such as national origin, age, sex, gender, marital status, religion, ancestry, and veteran status.
  • Commercial Information: Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
  • Geolocation Data
  • Sensory Information: Audio, electronic, visual, and similar information.
  • Employment Information: Professional or employment-related information such as résumé or contact information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information.

We may use (and may have used during the 12-month period prior to the Last Updated Date of this Notice) your Personal Information for the purposes described in the ۶Ƶ Privacy Policy and for the following business purposes:

  • Performing services: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytics services, providing storage, or providing similar services
  • Marketing: Providing advertising and marketing services
  • Auditing: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Short Term Use: Short Term Use: Short-term, transient use such as non-personalized advertising shown as part of your current interaction with us
  • Security Purposes: Helping to ensure security and integrity
  • Debugging: Debugging to identify and repair errors that impair existing intended functionality
  • Internal R&D: Undertaking internal research for technological development and demonstration
  • Safety: Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them
  • Career Opportunities: Managing career opportunities with us
  • Business Partners: Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel

We do not collect or process sensitive Personal Information for purposes of inferring characteristics about individuals.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We retain Personal Information as described in the “Retention of Personal Information” section of our Privacy Policy.

Sources of Personal Information

During the 12-month period prior to the effective Last Reviewed date of this Notice, we may have obtained Personal Information about you from the following categories of sources:

  • Directly from you, such as when you complete forms on our website, attend an event, or interact with social media and/or social networking services
  • From your devices, such as when you visit our website
  • Our parent, subsidiary and affiliated entities
  • Our partners and service providers (including, for example, business partners, analytics vendors, advertising campaigns, and search information providers

Sale or Sharing of Personal Information

We do not sell your Personal Information in exchange for monetary compensation. We may share your Personal Information by allowing certain third parties (such as online advertising services) to collect Personal Information via automated technologies on our websites. This kind of sharing may be considered a “sale” or “sharing” of Personal Information under California law. You have the right to opt out of these types of disclosures of your information.

Disclosure of Personal Information

We may disclose (and may have disclosed during the 12-month period prior to the Last Updated date of this Notice) your Personal Information with certain categories of third parties, including as described in our Privacy Policy and below, including for the business purposes described above.

CATEGORIES OF PERSONAL INFORMATION CATEGORIES OF THIRD PARTIES
Identifiers –       ۶Ƶ affiliates and subsidiaries

–       Vendors, partners, and service providers

–       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)

–       Law enforcement agencies, courts, regulators and government authorities

–       Marketing Partners

Additional data subject to Cal. Civ. Code § 1798.80 –       ۶Ƶ affiliates and subsidiaries

–       Vendors, partners, and service providers

–       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)

–       Law enforcement agencies, courts, regulators and government authorities

Commercial information –       ۶Ƶ affiliates and subsidiaries

–       Vendors, partners, and service providers

–       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)

–       Law enforcement agencies, courts, regulators and government authorities

–       Marketing Partners

Online activity –       ۶Ƶ affiliates and subsidiaries

–       Vendors, partners, and service providers

–       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)

–       Law enforcement agencies, courts, regulators and government authorities

–       Marketing Partners

Employment information –       ۶Ƶ affiliates and subsidiaries

–       Vendors, partners, and service providers

–       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)

–       Law enforcement agencies, courts, regulators and government authorities

Geolocation data –       ۶Ƶ affiliates and subsidiaries

–       Vendors, partners, and service providers

–       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)

–       Law enforcement agencies, courts, regulators and government authorities

California Consumer Rights

You have certain choices regarding ۶Ƶ’ use and disclosure of your Personal Information, subject to relevant exception under applicable law, as described below.

  • Access: You may have the right to request, twice in a 12-month period, that we disclose to you the Personal Information we have collected, used, disclosed and sold or shared about you.
  • Correction: You have the right to request that we correct the Personal Information we maintain about you, if that information is inaccurate.
  • Deletion: You have the right to request that we delete certain Personal Information we have collected from you.
  • Limit Use and Disclosure: You have the right to limit use and disclosure of sensitive personal information we may maintain about you.
  • Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your Personal Information or the sharing of your Personal Information for cross-context behavioral advertising purposes.
  • Shine the Light Request: If you are a California resident and have provided us with your Personal Information, you may ask us to refrain from sharing your Personal Information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes.

How to Make a Request

You may make a request to exercise your rights under CCPA through any of the following channels:

You may opt out of sale or sharing of Personal Information by contacting ۶Ƶ as noted in the “How to Contact Us” section of the Privacy Policy. To help protect your privacy and maintain security, we will take steps to verify your identity before actioning your request. If you request access to, correction of or deletion of your Personal Information, we may require you to provide certain information to help us identify you. In addition, if you ask us to provide you with specific pieces of Personal Information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

To submit a request as an authorized agent on behalf of a consumer, please contact ۶Ƶ as noted in the “How to Contact Us” section of the Privacy Policy.

If you designate an authorized agent, we may require proof of identity and authority before actioning your request.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.