Do Not Sell My Personal Information

Updated August 7th, 2023

Unless otherwise defined in this California Privacy Notice ("Notice"), all terms defined in the Privacy Policy and all other terms defined in the California Consumer Privacy Act of 2018 ("CCPA") retain the same meaning when used in this Notice.

Scope

This Notice supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California ("consumers" or "you").

This Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the CCPA.

Personal information disclosures

When we use the term "personal information" in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of this Notice, personal information does not include:

• De-identified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
• Publicly available information from government records.
• Information about job applicants, employees and other of our personnel.
• Information about employees and other representatives of third-party customers or entities we may interact with.

Collection, Disclosure, and Sale of Personal Information

In the last 12 months, we have collected and disclosed for a business purpose the following categories of personal information:

• Identifiers, such as your name, email address, postal address, account username/password, and telephone number. We disclose this information to our e-commerce platform, our subscription management provider, our sales and customer support teams, and our marketing providers.
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as contact information and payment information. We disclose this information to our e-commerce platform, our subscription management provider, our sales and customer support teams, and our marketing providers.
• Protected Classification Characteristics, such as age and gender. We disclose this information to our sales and customer support teams and our marketing providers.
• Commercial Information, such as shopping history and other information relating to your hobbies, interests and shopping behavior. We disclose this information to our e-commerce platform, our subscription management provider, our sales and customer support teams, and our marketing providers.
• Internet/Network Information, such as your IP address, cookie, advertising, or device identifier, browser type, operating system, Internet service provider, the data and time of your visit, browsing and shopping history, and information related to your interaction with our emails and advertisements. We disclose this information to our analytics and marketing providers.
• Geolocation Data, such as location information from your device or estimated based on your IP address. We disclose this information to our analytics and marketing providers.
• Sensory Information, such as recordings of phone calls between you and us, where permitted by law. We disclose this information to our customer support team.
• Other Personal Information, including loyalty program data, information you post in a public space on our services (such as testimonials) or on our social media pages or otherwise provide to us, information from your social media profile and information posted on your page, information you submit to us, including messages submitted through the services or when you attend one of our events or contact our sales or customer support teams, and information you submit to us when you enter a promotion (including photos, videos, and other user-generated content).
• Inferences, such as predictions about your interests and preferences.

We may from time to time engage in data transfers that constitute a "sale" under the CCPA. The categories of personal information that may be sold are Identifiers, California Customer Records, Commercial Information, Internet/Network Information, Geolocation Data, Other Personal Information and Inferences. In addition, as is common practice among companies that operate online, we permit third parties to collect certain personal information directly from you when you visit or interact with our Services. Please see our Privacy Policy to learn more about these third-party data collection practices.

Sources of personal information

As described in our Privacy Policy, we collect personal information directly from you when you provide it to us, automatically using cookies and other tracking technologies, as otherwise described in that policy, and by combining personal information we may otherwise obtain.

Purposes for collecting personal information

We collect, use, sell, or disclose personal information about you for the purposes described in our Privacy Policy.

Recipients of personal information

As described in the Onward Transfer section of our Privacy Policy, we share personal information internally and with a variety of third parties.

For a list of the categories of personal information that we have disclosed to third parties for a business purpose or that we have sold to third parties during the previous 12 months, please refer to the list above in the Collection, Disclosure and Sale of Personal Information section of this California Privacy Notice.

Your California privacy rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

• Right to Know: The right to request any or all of the following information relating to the personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold (if any) and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or, if applicable, selling the personal information.
• Right to Request Deletion: The right to request the deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Opt-Out of Personal Information Sales: The right to direct us not to sell personal information we have collected about you to third parties.
• Right to Opt-In to Personal Information Sales: If you are under the age of 16, you have the right to authorize us, or have your parent or guardian authorize us, to sell personal information about you.
• "Shine the Light": California’s "Shine the Light" law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures.

How to exercise your California privacy rights

To exercise your right to know, deletion, or "Shine the Light"

Submit a request to:

privacy@atlaspearl.com

We will need to verify your identity before processing most requests, which may require us to obtain additional personal information from you. You do not need to create an account with us to submit a request, but please provide your account username (if any), name, email address and mailing address in the request, as well as an explanation of the rights you wish to exercise. We will only use the personal information provided in connection with a California consumer rights request to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.

If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf.

In certain circumstances, we may decline a request to exercise the rights described above.

To exercise your right to opt-out of personal information sales

To initiate your request to opt out of personal information sales, please contact us at privacy@atlaspearl.com. To the extent our third-party advertising and analytics providers’ collection of information from users of our Platform and other online services constitutes a "sale" under the CCPA, please refer to our Privacy Policy for more information about the choices and opt-out options you have in relation to those practices. By visiting privacyrights.info or optout.privacyrights.info, you can also opt out from "sales" of this type of personal information by businesses that participate in the DAA’s CCPA Opt-Out Tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at youradchoices.com/appchoices.

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at howdy@atlaspearl.com.

Financial incentives

From time to time, we may offer you certain financial incentives permitted by law (such as coupons, samples, and sweepstakes or contest rewards) in exchange for the collection, retention, or sale of certain personal information about you, including Identifiers (such as your full name and email address), California Customer Records (such as your birth date and contact information) and Commercial Information (such as information specific to your experiences with our Platform). When necessary, we will provide information about the specific terms of the financial incentive, such as the type of personal information required to be disclosed, retained or sold in exchange for the benefit you may receive, and instructions on how to opt in or opt out, on the webpage or form where the financial incentive is made available.

How to contact us

If you have questions about this Notice or need to access this Notice in an alternative format, please contact us at howdy@atlaspearl.com.

Changes in policy

From time to time, we may change our Notice. We will notify you of any material changes to our Notice as required by law. We will also post an updated copy of this Notice on our Platform. Please check our Notice periodically for updates.

This policy was last modified on August 7th, 2023.