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Your California Privacy Rights

Last updated 3/17/2022

Purpose and General Principles

The purpose of this California Consumer Privacy Act (CCPA) policy is to provide timely notice, at or before the point of collection, to California residents, also known as “Consumers, regarding the categories of personal information collected online or and how we use their personal information. This policy provides instructions for how Consumers can exercise their right to deletion and a right to receive a copy of their information. Our Website Privacy Policy further describe our policies and practices related to your privacy.

Personal information is defined by the CCPA as any information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked, directly or indirectly, with a resident or household.

Non-Personal Information

Personal Information does not include publicly available information lawfully made available from federal, state, or local records and de-identified or aggregated consumer information. Aggregated information includes Internet Protocol addresses, browser type, device type, operating system, page views, referring URLs, destination URLs, dates and times of site visits, and other information collected primarily for statistical purposes.

Personal Information We Collect or Disclose

We collect information from you and about you to:

  • provide you personalized experiences,
  • send you recommendations on products and services of interest to you,
  • manage, analyze, and measure our content and advertising,
  • understand who visits our website, and
  • improve our services, including new service development through your access or use of our website.

Categories of Personal Information We Collect and Share About Consumers

Below are the categories of personal information about consumers we collect and/or disclose to third-parties or service providers for a business purpose.

Category Name Category Description Do We Disclose for Business Purposes?
Contact and Identification Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. Yes
Consumer Records

Information that identifies relates to, describes, or can be associated with, a particular individual, including but not limited to: a name, physical characteristics or description, address, telephone number, education, employment, medical information, or health insurance information.

This information will not include publicly available information lawfully made available to the public from federal, state, or local governments.

Some personal information in this category may overlap with other categories.

Purchase History and Tendencies Records of personal products or services purchased, obtained, or considered, or other purchasing or consumer histories or tendencies. Yes
Biometric Information Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as keystroke, or other physical patterns, sleep, health, or exercise data. Yes
Internet or Other Electronic Network Activity Information Browsing history, search history, information regarding a consumer's interaction with an Internet Web site, application, or advertisement. Yes
Geolocation Data Geographical (latitudinal and longitudinal) location can be used to identify an electronic device’s physical location, such as a mobile phone or smart meter. Yes
Sensory Data Audio, electronic, visual, thermal, olfactory, or similar information. Yes

Consumer Personal Information Rights

California residents have rights to their data. And, California law restricts certain business practices, listed below. Please refer to the “Contact Us” section with questions.

Right to Deletion

California residents have the right to request deletion of their personal information collected about them, subject to certain exemptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal 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: 

  • Complete the transaction for which we collected the personal information, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech ensures another consumer's right to exercise their free speech rights or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) pursuant to Chapter 3.6, beginning with Section 1546 of Title 12 of Part 2
  • Enable solely internal uses reasonably aligned with consumer expectations based on your relationship with us, following this Policy.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information compatible with the context in which you provided it.

Submitting Requests (Know or Delete)

Your Information

If you are a California resident, you may exercise your right to know or the right to delete your information by submitting an online request or calling us at 866-229-9807.  We will confirm receipt of a request within 10-business days and respond to the request within 45-calendar days from the time the request is received.

Verification Process Used for Consumer Requests

Before fulfilling your request, we must authenticate your identity. We will match our system information with what you provided at the time of the request. If you are a non-customer (third party), we may a third-party authentication service to confirm your information.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you for exercising any of your CCPA rights.

Retention of Personal Information

We retain your Personal Information for as long as reasonably necessary to fulfill the transactions you have requested or legitimate business purposes, such as complying with our legal obligations, including United States federal, state, and local laws. As retention periods vary for different types of Personal Information, based on business purpose, actual retention periods vary

Contact Us

For questions regarding this policy, please contact us using one of the following methods:

Lupine Marketing LLC.



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