CA Privacy Notice

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Updated as of August 4, 2023

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Trusted Media Brands, Inc. ( “we,” “us,” or “our”) with respect to the products and services we and our Family of Publications (as defined in such Privacy Policy) offer to consumers (including both offline and online orders of subscriptions to magazines and other products and services) (collectively the “Service”) and applies solely to visitors, users, and others who reside in the State of California.

California Consumer Privacy Act (“CCPA”)

The following is a description of our personal information practices for the 12-month period prior to the date of update of this notice set forth above as well as our current practices unless otherwise noted. See our applicable privacy policies and notices at the point of collection for more information on our practices.

Collection, Use and Disclosure of Personal Information

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

Publicly available information.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like health or medical information covered by HIPAA.

We collect the following categories of personal information from consumers for the uses described below

Category	Purposes for Collection, Use and Disclosure
A. Identifiers – such as name, postal address, email address, Internet Protocol address, or other similar identifiers	To provide you with and to improve the Service and other products and services To communicate with you For advertising and marketing purposes, including interest-based advertising
B. Personal information under subdivision (e) of California Civil Code Section 1798.80. – such as name, address, and financial information. Some personal information included in this category may overlap with other categories	To provide you with and to improve the Service and other products and services To communicate with you For advertising and marketing purposes, including interest-based advertising
C. Protected classification characteristics under California or federal law – such as age (40 years or older), marital status, gender	To provide you with and to improve the Service and other products and services For advertising and marketing purposes, including interest-based advertising
D. Commercial information – such as products or services purchased, obtained, or considered, or other purchasing histories	To provide you with and to improve the Service and other products and services To communicate with you For advertising and marketing purposes, including interest-based advertising
E. Internet or other similar network activity – such as information on a consumer’s interaction with a website, application, or advertisement	To provide you with and to improve the Service and other products and services To communicate with you For advertising and marketing purposes, including interest-based advertising
F. Audio, electronic, or similar information – such as recordings of customer care calls	To provide you with and to improve the Service and other products and services To communicate with you
G. Geolocation data – such as IP address	To provide you with and to improve the Service and other products and services To communicate with you For advertising and marketing purposes, including interest-based advertising
H. Professional- related information – such as your professional email address, phone number or other contact information	To provide you with and to improve the Service and other products and services To communicate with you For advertising and marketing purposes, including interest-based advertising
I. Inferences drawn from above personal information – such as a profile reflecting a person’s preferences, characteristics, and predispositions	To provide you with and to improve the Service and other products and services To communicate with you For advertising and marketing purposes, including interest-based advertising
J. Sensitive personal information* – such as precise geolocation and information, information concerning a consumer’s health, race, ethnicity, and philosophical beliefs *This has only been processed in the preceding 12 months.	To provide you with and to improve the Service and other products and services To communicate with you

We may also use or disclose all of the categories of personal information above for one or more of the following business purposes:

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in our Privacy Policy
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We may disclose your personal information for a business purpose to the following recipients:

Our affiliates
Vendors
Other parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from our customers. For example, from documents that our customers provide to us and through information we collect from our customers in the course of providing our Service to them.
Directly and indirectly from activity on our websites. For example, from submissions through our websites or website usage details collected automatically.
From service providers and third parties that provide information to companies like us about our customers and prospective customers, such as list rental and data marketing companies.
With respect to inferences, we may combine information we have obtained from various sources, using our own methods.

Sale and Sharing of Personal Information

We may sell or share personal information we collect about you to third parties, including marketing, analytics, and advertising partners. We sell and/or share the following categories of personal information:

Category A:
Identifiers

Category B:
Personal information under subdivision (e) of California Civil Code Section 1798.80

Category C:
Protected classification characteristics under California or federal law

Category D:
Commercial Information

Category E:
Internet or other similar network activity

Category G:
Geolocation data

Category H:
Professional-related information

Category I:
Inferences drawn from above personal information

We do not knowingly sell or share the personal information of consumers who we are under 16 years of age.

Retention of Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information (which includes the categories of personal information set forth in the chart and sections above) for as long as needed to fulfill the purposes we collected it for, as required to satisfy any legal obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we obtained your personal information for, and whether we can achieve those purposes through other means. For certain types of personal information, we will only maintain it for a limited duration. For other types of personal information, we may retain your information to provide you customer service and maintain our relationship with you after you have received your Service. Rather than delete your data, we might de-identify it by removing identifying details.

Your Rights and Choices

The CCPA provides California consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights under the CCPA.

Do Not Sell or Share

You have the right to opt out of the sale or sharing of your personal information. Once we receive your consumer request, we will refrain from selling or sharing personal information we collected about you.

Do Not Sell or Share

List Rental. You have the right to opt out of the sale of your personal information through our promotion lists sold to third parties. You can opt out of this selling of your personal information by visiting trustedmediabrands.com/ccpa-form-ca-residents/ and completing the online form. Once we receive and confirm your request, we will refrain from selling personal information we collected about you in this context.

Access to Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information. This includes:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. For example, we may deny a deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that 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, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Correction Request Rights

You have the right to request that we correct inaccuracies in your personal information. Please note you can visit our online customer care center to change your address, manage your subscriptions and payments, and more.

Sensitive Personal Information

We do not use sensitive personal information for the purpose of inferring characteristics about you, or for any other reasons besides our limited business purposes. For this reason, we do not treat sensitive personal information we collect as subject to a request to limit use of sensitive personal information and, therefore, we do not offer a way for you to submit such a request.

Exercising Do Not Sell or Share, Access and Deletion Rights

To exercise the do not sell or share, access, correction and deletion rights described above, please submit a request to us as set forth below.

Visit https://www.trustedmediabrands.com/ccpa-form-ca-residents and complete the online form
Write to us at Trusted Media Brands Legal Dept, 485 Lexington Ave., 9 th Floor, New York, NY 10017, Attn: CCPA Consumer Rights Request. Please make sure to include your full name, street address with Zip code, email address, and the California consumer right you wish to exercise

You can also call us at 1-888-337-0907 to submit a verifiable consumer request to exercise the access, correction and deletion rights described above. Upon your submission of an access, correction or deletion request, we will start the process to verify your identity, meaning we need to make sure you are the person about whom we may have collected personal information or a person who has been duly authorized to make the request on behalf of the consumer. Our verification process includes matching the information provided with information maintained in our customer database and systems, unless the request has already been granted or denied. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

For all requests, follow the instructions that you will be provided to help us respond to your requests. Please note:

Only you, or an authorized agent verified to act on your behalf, may make a request related to your personal information.
You may only make a request for access twice within a 12-month period.
Your request must clearly state which California consumer right you wish to exercise and, where applicable, provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
We may require an authorized representative both to verify their identity and submit proof they have been authorized by the consumer to act on the consumer’s behalf.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a consumer request to respond to a consumer request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 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, or by mail or electronically. If you do not have an account with us, we will deliver our written response by mail or electronically. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will provide your personal information in a standard CSV file.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded, in which case we may limit the response and/or condition it on payment of our costs. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

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

Changes to this Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will update the date of this notice below. Please bookmark this page and check it periodically. We will post any changes online.

If you have any questions about this privacy notice, please contact us at [email protected]

"Shine the Light" Law

California’s “Shine the Light” law requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt out of such information-sharing. We have such a policy in place. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, you may do so as set forth in our Privacy Policy under “Notice of Your Choices about Our Use and Sharing of Personally Identifiable Information”. To find out more about your opt-out rights and how we comply with this law, please contact us as set forth in that section of our Privacy Policy.

"Online Eraser" Law

California residents under the age of eighteen (18) who have registered to use our Service, and who posted content or information on our Service, can request removal by contacting us as described above. We will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.