EEMusicClass.com Privacy Policy

The Essential Elements Music Class platform/system is owned and operated by Hal Leonard LLC, and Essential Elements Music Class is a trading name of Hal Leonard LLC. Hal Leonard LLC is committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, in connection with our site (as defined below), will be collected, stored, used, disclosed and otherwise processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Hal Leonard LLC is the controller of your personal data that it collects from you or otherwise receives. This means that it determines the purposes and means of the processing of your personal data. However it will process your personal data in accordance with this policy.

1) Definitions In this policy:

a)  we / our / us  refers to Hal Leonard LLC, a Delaware limited liability company, whose principal address is 7777 West Bluemound Road, Milwaukee, WI 53213, United States; an

b)  personal data means any information relating to an identified or identifiable natural person (a data subject), and includes “personally identifiable information” as that term is used in the United States of America (USA). An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

c) teacher means any teacher or other representative of a school, school district, or private studio.

2) Information we collect about you; policy concerning children

a) Information we collect. We will collect and process the following personal data about you:

i) Information you give us. This is information about you that you give us by contacting us via our website or filling in online forms on our website at eemusicclass.com (our site or our website), by communicating with us by telephone, e-mail or otherwise, or when downloading content from the site.

(1) If you are a teacher: The information you give us may include: your first name and last name; school name and address, or your personal/work name and address if you are not attached to a school; whether you are a music teacher or other music professional; your contact details at the school including phone number and email address, or your other personal/work contact details if you are not attached to a school; or billing/payment information (including cardholder name, daytime phone, billing address, card type, credit card number, other card details and/or PayPal transaction ID). Please be aware that if you fail to provide to us information that we ask for, we may be unable to provide services to you or otherwise to fulfil your requirements. It is important that we hold current information about you, so please provide us with any appropriate updates. Also, we may assign to you a unique personal identifier.

(2) If you are a student: We do not expect that you will, and we ask that you please do not, share any information relating to yourself with us. We may collect information about you in the manner described in Sections 2(a)(ii) and 3 of this policy if you access our services through a link made available to you by your teacher.

ii) Information we collect about you. With regard to each of your visits to our site we will normally automatically collect the following information:

(1)  technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, the connection between an IP address and the teacher providing the link through which that IP address arrives at the site, your login information, and information about your computer or other device being used to connect to our site, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(2)  information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

With respect to teachers (but not students), we also collect records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies in connection with our products and services.

iii) Information we receive from other sources. With respect to teachers (but not students), we work closely with third parties (including, for example, business partners, sub-contractors in technical services, advertising networks, analytics providers, search information providers) who may provide information about you to us.

b) Data concerning children. We may collect personal data relating to students who are children (which we define as individuals aged 12 years old and under) in the manner described in Sections 2(a)(ii) and 3 of this policy if they access our services through a link made available by their teacher.

If you are aged 12 years old or under then you must not provide us with any information through this site.

3) Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For information on the purposes for which we use them see our Cookie Policy.

4) Uses made of the information

a)  We comply with the law. We will only use your personal data to the extent that the law allows us to do so. Under the EU General Data Protection Regulation (the GDPR) we will rely on the following legal bases for processing your personal data:

i)  where it is necessary to perform a contract we have entered into or are about to enter into with you;

ii)  where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those interests. Our legitimate interest means our interest in conducting and managing our business, including supplying products or services ordered, enabling us to provide you and our other customers with the best products and services we can and the best and most secure experience when dealing with us. In assessing our legitimate interests, we make sure we consider and balance any potential impact (both positive and negative) on you and others and your rights;

iii)  where you have given us your consent.

b)  Information you give to us (if you are a teacher). We will use this information to provide customer service and technical support to you; to carry out our obligations arising from any contracts entered into between you and us, or between your school and us; to inform you about new features and tutorials available through our site; to provide you with information about other products and services we offer that are similar to those that you or your school have already purchased or enquired about; to provide your information to our marketing department who may contact you to request feedback and comments on our products or services or to provide information to you which may be of interest to you or to your school; to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you or your school. If you or your school are an existing customer, we will only contact you by electronic means (such as e-mail or SMS) with information about products and services similar to those which were the subject of a previous sale or negotiations of a sale to you or your school. If you or your school are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you will be able to withdraw your consent by contacting eei@halleonard.com; to moderate and publish reviews that you post on our site; in the case of address information, for product research and development. We will also use this information to try to ensure that content from our site is presented in the most effective manner for you and for your computer or other device.

c) Information we collect about you. We will use this information:

i)  to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

ii)  to improve our site to try to ensure that content is presented in the most effective manner for you and for your computer or other device;

iii)  as part of our efforts to keep our site safe and secure;

iv)  with respect to teachers (but not students), to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

v)  with respect to teachers (but not students), to make suggestions and recommendations to you and other users of our site about products or services that may interest you or them or the schools you or they represent;

vi)  with respect to teachers (but not students), to provide you or your school with the most relevant information, promotions and products during your visit to our site.

d) Information we receive from other sources. We will use this information to combine with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

5) Disclosure of your information

a) You agree that we have the right to share your personal data with selected third parties (and agree that third parties may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites) including any third parties referenced in our COPPA Privacy Policy and including:

i)  entities that assist us in providing customer service and technical support to you in relation to the site;

ii)  entities who provide services to us in relation to marketing, in order to assist us in marketing to you or your school as described above. However this only applies if you are a teacher;

iii)  cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting;

iv) our website developer in relation to this site, for the purposes of further developing this site;

v) analytics and search engine providers that assist us in the improvement and optimisation of our site; and

vi) credit card processors and other payment services providers, for the purposes of effecting payments by or to you.

Google Analytics.  Please note in particular that our site uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Do Not Track. The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

b) We will disclose your personal data to third parties:

i) if Hal Leonard LLC or all or substantially all its assets or the relevant part of its assets are acquired by a third party, in which case personal data held by it about its customers or service users (or the relevant customers all service users) and individuals representing those customers or service users will be one of the transferred assets and we may disclose your personal data in connection with any such transaction; or

ii) if we are under a duty to disclose or share your personal data in order to: comply with any legal obligation, including without limitation lawful requests by public authorities such as to meet national security or law enforcement requirements, and including with regulators and other authorities who require reporting of processing activities in certain circumstances; or to enforce or apply our standard terms and conditions of business and other agreements; or to protect the rights, property, or safety of Hal Leonard LLC, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;

iii) if we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding; or

iv) to our Corporate Affiliates; for purposes of this privacy policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Hal Leonard LLC, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

6) Where we store your personal data

a) All information you provide to us is stored on secure servers. These may be located anywhere in the world, including the USA. See below concerning international transfers of personal data.

b)  Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. This may include encryption of some information.

c)  We will also use reasonable efforts intended to ensure that third parties to whom we disclose your personal data take appropriate measures to ensure the security of your personal data and do not use it except for the purposes for which we disclose it to them.

7)  International transfers of personal data

a)  We may share your personal data within the group of companies of which Hal Leonard LLC is a member. This may involve transferring your personal data outside the European Economic Area (EEA), including to the USA.

b)  Many of our external third parties to whom we transfer your personal data as described above are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

c)  We may transfer your personal data out of the EEA, including without limitation in the following contexts:

i)  Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; or

ii)  The transfer is necessary for the performance of a contract between you and us or between your school and us.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8)  Retention of personal data

a)  We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected your personal data.

b)  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If by law we are required to retain any information about our customers or their interactions with us, we will retain your personal data insofar as required to comply with such law.

c) We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9) Your legal rights

a) Under certain circumstances, you have the right to:

i)  Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

ii)  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

iii) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data in certain other circumstances, namely where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

iv)  Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

v)  Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

vi)  Request the transfer of your personal data to you or to another person or entity. In that case we will provide to you, or to the person or entity to whom you wish us to transfer your personal data, your personal data in a structured, commonly used, machine- readable format.

vii) Withdraw consent at any time where we are relying on consent to process your personal data. However this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

viii)Lodge a complaint with the UK Information Commissioner’s Office (ICO) or another applicable regulator. If you have any complaints about the way in which we process your personal data please do contact us, as set out below, as we would appreciate the opportunity to resolve your complaint.

b) If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us using the contact details provided below.

10) Other websites

Our site may, from time to time, contain links to and from the websites or apps of our partner networks, advertisers and affiliates. If you follow a link to any of these websites or apps, please note that these websites and apps have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites or apps.

11) Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

12) Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@eemusicclass.com.

13) Privacy Notice for California Residents

This Section 13 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the "CCPA")) under the CCPA. This Section 13 shall apply to you only if you are a California resident.

As used in this Section 13, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to another business or a third party for monetary or other valuable consideration.

“Selling” does not include (i) disclosing consumer information to a third party at your direction, provided the third party does not sell the consumer information except in accordance with the CCPA, (ii) where you intentionally interact with a third party through our products or services, provided the third party does not also sell the consumer information, (iii) using or sharing your consumer information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on Hal Leonard LLC’s behalf and provided that the service provider does not further collect, sell or use the consumer information except as necessary to perform the business purpose, or (iv) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Hal Leonard LLC, provided that information is used or shared consistently with the CCPA.

Where noted in this policy, until January 1, 2021, the CCPA exempts consumer information reflecting a written or verbal business-to-business communication ("B2B consumer information") from some its requirements, provided that such exemptions shall not apply from and after January 1, 2021.

13)1. Consumer Information Collected: We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents, devices or households ("consumer information"). Consumer information does not include deidentified or aggregated information, publicly available information from government records, or any other information that is excepted from the definition of "personal information" under the CCPA, or any information that is otherwise not regulated by the CCPA. In particular, we have collected the following categories of consumer information from California residents, households or devices within the last twelve (12) months:

Category

Examples

Business or commercial purposes for which we collect and use consumer information

A. Identifiers.

If you are a teacher: name; school name and address, or personal/work name and address if you are not attached to a school; and contact details at the school including phone number and email address, or other personal/work address, email address, and telephone number if you are not attached to a school; we may assign a unique identifier to you.

For the business and commercial purposes described in Sections 3 and 4 of this policy.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

If you are a teacher: name, telephone number; address; school name and address, if applicable; and billing/payment information (including cardholder name, daytime phone, billing address, card type, credit card number, other card details and/or PayPal transaction ID).

For the business and commercial purposes described in Sections 3 and 4 of this policy.

C. Commercial information.

If you are a teacher: records of personal property, products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies in connection with our products and services.  

For the business and commercial purposes described in Sections 3 and 4 of this policy.

D. Internet or other similar network activity.

Technical information, including the IP address used to connect your computer or other device to the Internet, the connection between an IP address and the teacher providing the link through which that IP address arrives at the site, your login information, and information about your computer or other device being used to connect to our site, including browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform, information about your visit, including the full URL, clickstream to, through, and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

For the business and commercial purposes described in Sections 3 and 4 of this policy.

E. Professional or employment-related information.

If you are a teacher: whether you are a music teacher or other music professional, in addition to information as above.

For the business and commercial purposes described in Sections 3 and 4 of this policy.

F. Inferences drawn from other personal information.

If you are a teacher: inferences reflecting personal preferences, characteristics, predispositions and behavior.

 For the business and commercial purposes described in Sections 3 and 4 of this policy.

13)2. Use of Consumer Information; Categories of Sources: We use consumer information for the business or commercial purposes described in the table above and in the manner described in Sections 2, 3 and 4 of this policy with respect to personal data.

Regarding the categories of sources from which consumer information is collected, if you are a teacher, we collect consumer information that you submit to us. We also receive information that is otherwise collected when you use the site, including as described in Sections 2(a)(ii) and 3 of this policy.

Additionally, with respect to teachers (but not students), we work closely with third parties (including, for example, business partners, sub-contractors in technical, analytics providers and search information providers) who may provide information to us regarding our services to you, including as described in Section 2(a)(iii) of this policy.

13)3. Disclosures of Consumer Information for a Business or Commercial Purpose: Hal Leonard LLC may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in Section 5 of this policy with respect to personal data. In the preceding twelve (12) months, we have disclosed the categories of consumer information described in the table below (as further described in Section 13.1) for a business or commercial purpose to the following categories of third parties (as further described in Section 5 of this policy):

Category

Categories of third parties to whom we have disclosed consumer information for a business or commercial purpose in the preceding twelve (12) months.

A. Identifiers.

      1. entities that assist us in providing customer service and technical support to you in relation to the site;


      1. entities who provide services to us in relation to marketing, in order to assist us in marketing to you or your school as described above. However this only applies if you are a teacher;


      1. cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting;


      1. our website developer in relation to this site, for the purposes of further developing this site;


      1. analytics and search engine providers that assist us in the improvement and optimisation of our site;


      1. Corporate Affiliates;


      1. credit card processors and other payment services providers, for the purposes of effecting payments by or to you.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), provided that this disclosure shall only apply to data elements that are listed in Section 13.1.B but that are not also listed in Section 13.1.A (Identifiers). 

 credit card processors and other payment services providers, for the purposes of effecting payments by or to you.

C. Commercial information.

      1. cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; and

 

      1. our website developer in relation to this site, for the purposes of further developing this site.

D. Internet or other similar network activity.

      1. cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting;


      1. our website developer in relation to this site, for the purposes of further developing this site; and


      1. analytics and search engine providers that assist us in the improvement and optimisation of our site. 

E. Professional or employment-related information.

      1. entities who provide services to us in relation to marketing, in order to assist us in marketing to you or your school as described above. However this only applies if you are a teacher;


      1. cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; and


      1. our website developer in relation to this site, for the purposes of further developing this site.

F. Inferences drawn from other personal information (however this only applies if you are a teacher).

      1. entities who provide services to us in relation to marketing, in order to assist us in marketing to you or your school as described above;


      1. cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; and


      1. our website developer in relation to this site, for the purposes of further developing this site.

13)4. Sales of Consumer Information: In the preceding twelve (12) months, Hal Leonard LLC has not sold, nor does it or will it sell, consumer information.

13)5. California Residents’ Rights and Choices: The CCPA provides California residents with specific rights regarding their consumer information. This Section 13.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.

13)5.1. Access to Specific Information and Data Portability Rights: You may have the right to request that Hal Leonard LLC disclose certain information to you about our collection and use of your consumer information over the past 12 months. Once we receive and confirm your verifiable consumer request (in the manner described in Section 13.6 below), to the extent required by the CCPA, we will disclose to you:

13)5.1.1. The categories of consumer information we collected about you.

13)5.1.2. The categories of sources for the consumer information we collected about you.

13)5.1.3. Our business or commercial purpose for collecting that consumer information.

13)5.1.4. The categories of third parties with whom we share that consumer information.

13)5.1.5. The specific pieces of consumer information we collected about you (also called a data portability request).

13)5.1.6. If we disclosed your consumer information for a business or commercial purpose, a list of disclosures for a business or commercial purpose, identifying the consumer information categories that each category of recipient obtained.

We will not provide the foregoing access and data portability rights for B2B consumer information prior to January 1, 2021.

13)5.2. Deletion Request Rights: You have the right to request that Hal Leonard LLC delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you (if you are a California resident) in the manner described in Section 13.6 below (“verifiable consumer request”), we will delete (and direct our service providers to delete) your consumer information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

13)5.2.1. Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

13)5.2.2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

13)5.2.3. Debug products or services to identify and repair errors that impair existing intended functionality.

13)5.2.4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

13)5.2.5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

13)5.2.6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

13)5.2.7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

13)5.2.8. Comply with a legal obligation.

13)5.2.9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will not provide the foregoing deletion rights for B2B consumer information prior to January 1, 2021.

13)6. Exercising Access, Data Portability, and Deletion Rights:

13)6.1. To exercise the access, data portability, and deletion rights described in Section 13.5 above, please submit a verifiable consumer request to us by either: (1) calling us (800) 637-2852; or (2) contacting us at eei@halleonard.com. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use consumer information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We use the following process to verify consumer requests:

• Email Verification

• Additional account identification questions if needed.;

13)6.2. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

13)7. Non-Discrimination

13)7.1. We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:

13)7.1.1. Denying you goods or services.

13)7.1.2. Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

13)7.1.3. Providing you a different level or quality of goods or services.

13)7.1.4. Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Last revised and effective as of: 8-31-2020