Funlab Privacy Policy

The Policy

(a) Welcome and thank you for visiting us.

(b) We, Funlab Holdings Pty Ltd (ACN 606 795 733) and our related entities, Funlab Pty Ltd (ACN 098 034 943), Holey Moley Australia Pty Ltd (ACN 613 584 571), Strike Australia Pty Ltd (ACN 606 795 788), Sky Zone Australia Pty Ltd (ACN 606 795 939), Lucky & Sons Australia Pty Ltd (ACN 100 610 222), Archie Bros Australia Pty Ltd (ACN 621 886 922), Funlab New Zealand Limited (Company number 6649793), Funlab USA Inc., a Delaware corporation (EIN 32 061 3856), Funlab USA Operations (EIN 98-1698652), Funlab Texas Operations LLC (EIN 92-3333736) and each of our other related entities and subsidiaries that are incorporated from time to time (collectively, "Related Entities") shall be collectively referred to as "Funlab", “we”, “us”, or “our”.

(c) The website located at https://www.fun-lab.com/ and other related platforms (https://www.holeymoley.com.au/; https://www.holeymoley.co.nz/; https://www.strikebowling.com.au/; https://www.archiebrothers.com.au/; https://www.archiebrothers.co.nz/; https://www.hijinxhotel.com.au/; https://www.ladidarts.com.au/; https://www.luckyandsons.com.au/; https://www.holeymoley.com/; https://www.hijinxhotel.com/; and https://www.playback96.com.au/; and digital properties made available on the website (collectively, "Sites") are owned and operated by us. You can find this Privacy Policy on these Sites.

(d) Through these Sites or the provision of our products or services at any of our physical locations, Funlab may, from time to time, collect personal information from its customers (“Guests”) and other parties (such as job candidates and personnel of our suppliers) with whom we deal for a variety of reasons, including to enable us to improve the nature of the services we provide.

(e) We understand individuals' concerns regarding privacy and take seriously our privacy obligations in respect of all personal information we collect and handle.

(f) To safeguard your personal information, Funlab is committed to protecting your privacy through compliance with applicable privacy laws (“Privacy Laws”).

(g) Please read this Privacy Policy (“Privacy Policy”) carefully, as it outlines how we collect, use, disclose and store your personal information.

2. Types of Information we Collect

2.1 Type and Nature of Information

(a) The information we collect in most cases relates to Guests but can relate to  other parties we deal with. Information is gathered for a range of primary purposes, including the provision of ongoing Guest support and the compiling of Guest databases to enable us to more accurately market our goods and services.

(b) Privacy Laws require us to manage personal information in an open and transparent manner. We may collect the following personal information from Site visitors and users of our services. The types of personal information we collect include but are not limited to:

(i) PERSONAL INFORMATION

‘Personal Information’ when used in this Privacy Policy generally means any information that can be used to personally identify you or relates to you (as a reasonably identifiable individual). The type of Personal Information we collect includes things such as name, address, contact details, buying habits, opinions, product preferences and transactional/payment details.

(ii) PUBLIC DATA

On the Sites you may have the ability to comment or participate on blogs, discussion forums or other parts of the Site that allow you to post your comments. We may collect this data on our platform when you choose to comment or participate (“Public Data”). This Public Data includes information such as your comments, your time zone, and any information you input. You should be aware that any information you provide in this manner may be made broadly available for others.

(iii) LOG DATA

(A) We may receive information when you view content on or otherwise interact with our services (“Log Data”). We may receive this Log Data automatically.

(B) This Log Data includes information such as Personal Information from your interaction with us and its content, our services and our advertising, including without limitation device identifiers, device type, high-level geo-location information such as region derived from an IP address, connection information, statistics on page views, traffic to and from the Site, mobile network information, time, date, referring URL, the type of operating system and browser, ad data, IP address, server address, date and time of your visit to our Site, information of documents you download, pages visited, search terms, cookie information, and standard web log data.

(C) The Log Data may be processed for the purposes of operating our Site, providing our services, ensuring the security of our Site and services, maintaining back-ups of our databases and communicating with you.

(iv) ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

For more detailed information on the categories of Personal Information we collect about California residents, and other California-specific information, please visit our Additional Information for California Residents page.

2.2 Collection of Personal Information

As a provider of a wide range of services, Funlab frequently finds that it is necessary to collect Personal Information during the course of its transactions with you, and we collect such Personal Information via the following means:

(a) activity booking and competition entry forms;

(b) application forms (including online applications to access Wi-Fi internet at some of Funlab’s Related Entities’ entertainment precincts or job applications);

(c) Funlab’s contractors, in relation to services operated by Funlab in conjunction with such contractors;

(d) email;

(e) websites (including, but not limited to, our Sites as well as social media sites such as LinkedIn, Facebook, and in some instances cookies);

(f) online transactions;

(g) networking functions (eg: business cards);

(h) over the phone;

(i) transactional details or other information as required by our third party payment processors;

(j) in-person at our physical locations; and

(k) via the use of Closed Circuit Television (CCTV) or other security surveillance systems (discussed further at section 2.6 below).

2.3 'Sensitive Information'

We may be required from time to time to collect sensitive information from you, but will not do so without your express consent and only to the extent necessary to provide our services or products to you. “Sensitive Information” is given its meaning in the relevant Privacy Laws but generally includes information that relates to an individual’s racial, religious or ethnic origin, health information or political/ philosophical affiliations or beliefs.

2.4 Cookies and Other Similar Technologies

(a) We may use cookies and similar technologies like pixels, web beacons and local storage to collect and store personal and non-personal information about how you use our Sites and our offerings.

(b) Cookies are files that store information on the device on which you are using or accessing our Sites. Essential and functional cookies allow the Sites to function properly and can do things like retain your details and preferences, so you can easily book services or continue your browsing session .  Analytics cookies help us understand how you interact with our Sites, so that we can do things like diagnosing problems and optimizing our Sites.  Marketing and advertising pixels are described more fully below.   

(c) If you do not want to activate certain types of cookies, you can opt-out of receiving them by amending the settings of your Internet browser or your preferences within a cookie banner if you are in a location that serves you one, although you may find that some parts of our Sites will consequently have limited functionality and personalisation if you do so.

(d) ADVERTISING COOKIES AND SIMILAR TECHNOLOGIES

Although we do not use cookies to create a profile of your browsing behaviour on third-party sites, we do use aggregate data from third parties to show you relevant, interest-based advertising. We may track your response to our advertisements, e-mails and content, determine your ability to receive HTML-based e-mail messages, learn how many users open an e-mail and allow our service providers to compile aggregated statistics about an e-mail campaign that we are running, or create criteria to identify other potential customers to advertise to (e.g., “lookalikes”). This information may be shared with third parties to assist them in understanding the performance of advertising in our services.

2.5 Third Party Analytics Tools

(a) We may use third-party analytics tools to:

(i) analyse usage trends on our Sites, including the tracking and reporting of Site traffic, ad conversion tracking, traffic analysis and marketing optimisation; and

(ii) collect this data in aggregate form so that it cannot identify any individual.

(b) Third-party analytics tools collect information such as the web pages you visit, add-ons, and other analytics data that assists us in improving our products and services.

(c) These tools might include, but are not limited to, Google Analytics, Google AdWords conversion tracking, Google Tag Manager, or Facebook Ads conversion tracking. Third-party cookies may be placed on your device by a service provider to us, for example, to help us understand how our products or services are being used. Third-party cookies may also be placed on your device by our business partners to advertise the service to you elsewhere on the Internet. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

While we do not sell Personal Information in exchange for monetary consideration, we do disclose Personal Information for other benefits that could be deemed a “sale” under various Privacy Laws because it is sometimes broadly defined to include activities such as allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.

To manage your preferences with respect to cookies and these technologies, you can customize your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our website may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.

2.6 Closed Circuit Television (CCTV) and security surveillance systems

Funlab uses closed‑circuit television (CCTV) cameras and security surveillance systems throughout all areas of our venues, except for bathrooms. We collect CCTV video footage for safety, security, risk management, and compliance purposes (including for example, for liquor licensing compliance purposes), and to help us investigate incidents, ensure the safety of our guests and team members, and protect our property and assets.

CCTV footage is collected and stored on behalf of Funlab by our third‑party security surveillance providers and are generally retained for approximately 30 days. However, Funlab and its third-party security surveillance providers may retain footage for a longer period where we consider it reasonably necessary for our legitimate business purposes (such as investigating an incident, security investigations, legal matters or disputes, or managing a claim, or where required or permitted by law).

Funlab may access the footage for the purposes described above, and we may disclose CCTV recordings—or copies of them—to law enforcement agencies and regulators (in Australia, New Zealand the United States or elsewhere), or other third parties where required or authorised by law.

2.7 Guest consent

Wherever required by Privacy Laws, Funlab will obtain the consent of Guests to the collection of Personal Information. In some situations, Funlab will interpret a Guest's actions as indicating that a Guest consents to the collection of Personal Information. This may occur where the Guest has provided Personal Information for a particular purpose and that purpose cannot be achieved without Funlab making use of the Guest's Personal Information.

2.8 What happens if Personal Information is not provided?

You can choose not to provide us with your Personal Information. However, this may mean that:

(a) we will not be able to provide you with our products or services, or be limited in how we can do so;

(b) we may be unable to process and open an account for you; and/or

(c) we will not be able to properly investigate or resolve any complaint you submit.

3. WHY WE COLLECT, STORE AND USE YOUR PERSONAL INFORMATION

(a) We respect your privacy and comply with Privacy Laws.  We collect, store and use your Personal Information  so we can perform our business activities and functions.

(b) We also hold Personal Information which we use and/or disclose for purposes for the following additional purposes:

(i) for internal operations such as record keeping, database management, data analytics or training;

(ii) to send you marketing and promotional messages and other information that may be of interest to you;

(iii) to manage, research and develop our products and services;

(iv) to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;

(v) to administer competitions, rewards, surveys, or other promotional activities or events sponsored or managed by us or our business partners;

(vi) to communicate with you, including by email, phone or text; and/or

(vii) to verify your identity, investigate any complaints about or submitted by you, or if we have reason to suspect that you are in breach of any of our Terms and Conditions, which can be found at the below links:

(A) Strike Bowling: https://www.strikebowling.com.au/terms-of-use

(B) Holey Moley: https://www.holeymoley.com.au/terms

(C) Archie Brothers Cirque Electriq: https://www.archiebrothers.com.au/terms-of-use

(D) B. Lucky & Sons: https://www.luckyandsons.com.au/terms-of-use

(E) Hijinx Hotel: https://www.hijinxhotel.com.au/terms

(F) La Di Darts: https://www.ladidarts.com.au/terms

(G) Holey Moley USA: https://www.holeymoley.com/terms

(H) Hijinx Hotel USA: https://www.hijinxhotel.com/terms

(I) Playback 96: https://www.playback96.com.au/terms

(c) We may also use Personal Information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate:

(i) under applicable law, which may include laws outside your country of residence;

(ii) respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; and

(iii) to protect our rights, privacy, safety, property, or those of other persons.

(d) We may collect Personal Information about you or from your authorised representatives for the purpose of providing you with our services and marketing other services which we consider may be of interest to you or obtaining your feedback. For example, we may send you service-related emails (e.g., updates of Terms and Conditions, news, technical and security notices, and changes and/or updates to features of our offerings and this Privacy Policy).

4. How we collect, use and disclose your Personal Information

(a) Funlab generally collects Personal Information from you in accordance with clause 2.2.

(b) We may also collect your Personal Information from third parties including:

(i) service providers;

(ii) collection agencies and/or credit reporting bodies;

(iii) financial and credit card institutions to process payments, billing providers and payment gateways;

(iv) marketing companies;

(v) referrals who may have referred you to us; and

(vi) organisations with whom we have an agreement to share information for marketing purposes.

(c) By providing Personal Information to us, you agree to us collecting, using, disclosing and storing your Personal Information in accordance with this Privacy Policy. You may choose to deal with us anonymously where possible, such as when you make a general enquiry about our Services. We will allow our Guests to transact with us anonymously or by using a pseudonym wherever that is reasonable and practicable.

(d) We may disclose Personal Information to the following parties:

(i) our employees, Related Entities and employees of those entities;

(ii) our business partners;

(iii) third parties and contractors who provide services to us, including Guest enquiries and support services, manufacturing services, shipping and freight services, debt-recovery functions, information technology service providers, marketing and advertising services;

(iv) payment systems operators.  Funlab uses a third-party payment processor, Stripe, to process transactions made via MasterCard and VISA credit and debit cards, EFTPOS or American Express. Stripe will collect and use your personal information in accordance with its privacy policy;

(v) our sponsors or promoters of any competition which we conduct;

(vi) any third parties authorised by you to receive information held by us; and

(vii) government, regulatory and law enforcement agencies as required, authorised or permitted by law. 

(f) We retain your Personal Information for as long as needed:

(i) to provide our products and services to you;

(ii) fulfill the purposes outlined in this Privacy Policy; and

(iii) to comply with our legal obligations, resolve disputes, and enforce any agreements.

Criteria we will use to determine how long to retain your Personal Information include the nature and length of our relationship with you; our legal rights, obligations, and retention requirements; and if we have an ongoing business purpose for retaining your Personal Information.

(g) When you provide your Personal Information to us, you acknowledge that your Personal Information may be disclosed outside of your home jurisdiction and we will take reasonable steps to ensure that any overseas recipient will deal with such Personal Information in a way that is consistent with applicable Privacy Laws. For further information regarding overseas disclosure, please see clause 10.

5. Data Security

We hold your Personal Information in electronic form in secure databases owned and operated by our third-party service providers. We manage the security of your Personal Information by using SSL encryption.

We take reasonable steps including technical and organisational measures to protect the Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. While we take reasonable steps to ensure your Personal Information is protected from loss, misuse, unauthorised access, modification or disclosure by using measures such as firewalls, data encryption, virus detection methods, and password restricted access, security measures over the Internet can never be guaranteed. This means that we cannot guarantee the security of your Personal Information. In the event of a breach, we will attend to the required reporting arrangements.

Funlab requires its employees and contractors to perform their duties in a manner that is consistent with Funlab’s legal responsibilities in relation to privacy, including those in this Privacy Policy. We note that we take reasonable steps to ensure that Personal Information is only accessible by people who have a genuine "need to know" as well as "right to know."

6. Notifiable Data Breaches

(a) In the event that there is a data breach and we are required to comply with the notification of eligible data breaches provisions under applicable laws , we will take all reasonable steps to contain the suspected or known breach where possible and follow the following process set out in this clause.

(b) We will take immediate steps to limit any further access or distribution where possible. In accordance with applicable law, we may be required to perform assessment(s) regarding whether there are reasonable grounds to suspect that the data breach is likely to result in serious harm to any individuals involved.  We will follow the risk assessment and notification requirements, if any, of applicable law.

(d) Where notification is required by applicable law, we will provide a statement to each of the individuals whose data was breached or who are at risk. The statement will contain details of the breach and recommendations of the steps each individual should take, including any credit monitoring services if required by applicable law. We will also provide a copy of the statement to applicable data protection regulators to the extent required by applicable law.

7. Your Privacy Rights

Depending on where you are located, you may have some of the following types of privacy rights afforded to you under privacy laws. To exercise your applicable privacy rights, please see Clause 16.  

Right to Access

The right to request that Funlab disclose certain information to you about its collection and use of your Personal Information, including categories of Personal Information, categories of sources, categories of third parties your Personal Information was disclosed to, purposes for collecting Personal Information, and specific pieces of Personal Information Funlab collected about you. 

Right to Correct

The right to request correction or amendment to your Personal Information.  Funlab relies on you to update or correct inaccurate or outdated Personal Information.

Right to Deletion

The right to request deletion of your Personal Information.  Funlab will delete Personal Information as required by Privacy Law but in some situations Funlab might be required or permitted to retain your Personal Information.

Right to Object to, Restrict, or Limit Certain Types of Processing

Depending on where you are located, you may have the right to object to, restrict, or limit some of the types of processing activities as mentioned in this Privacy Policy,

Right to Opt Out of Sale or Share

Depending on where you are located, you may have the right to opt out of the “sale” of your Personal Information (as defined by Privacy Laws) and the “sharing” of your Personal Information for the purposes of cross-context behavioural advertising.  Funlab does not exchange Personal Information for money, but some laws may treat sharing for ads or analytics as a “sale,” so you may opt out of that activity.

Right to Portability

Depending on where you are located, you may have the right to request a portable, machine-readable version of your Personal Information.

Right to Opt Out of or Limit the Processing of Sensitive Personal Information

Depending on where you live, and whether Funlab processes your Sensitive Personal Information, you may have the right to opt out of or limit Funlab’s processing of that Sensitive Personal Information.

8. MINORS

Where required by applicable law, or Funlab is aware that it is gathering information from a minor, Funlab will obtain consent from a legal guardian for the collection of the information. Where applicable law permits, Funlab has adopted the position proposed that an individual under the age of 18 is able to give their consent when they have a sufficient understanding and maturity to understand what is being proposed. In such case, Funlab's staff will make a determination as to the minor's understanding of why the Personal Information is being collected and capacity to consent and make their own privacy decisions, before deciding to collect that information. The best interests of the minor will also be taken into consideration to determine whether the collection is fair and reasonable.

9. Competitions, Contests and Sweepstakes

Personal Information gathered during competitions, contests and sweepstakes conducted by Funlab or any other means where your Personal Information is provided to us via one of the Sites run by Funlab will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry or on the relevant Sites.

10. Overseas Disclosure

(a) If we share your Personal Information overseas, we will take steps which are both reasonable and practicable to ensure that the overseas recipient handles such information in accordance with Privacy Laws.

(b) We may disclose your Personal Information to recipients located outside of your home jurisdiction, including the following:

(i) our data hosting and cloud based IT service providers;

(ii) our offices (including their employees, staff, officers and agents) located in New Zealand and The United States of America; and/or

(iii) other third parties operating in jurisdictions including Bangladesh, New Zealand, Philippines, Singapore, Sweden, the United Kingdom and the USA.

(c)  We will only transfer Personal Information about an individual to someone who is in a foreign country if:

(i) we reasonably believe that the recipient of the information is subject to a law, or binding scheme, which effectively overall upholds principles for protection of the information that are substantially similar to Privacy Laws and there are mechanisms that an individual can access to take action to enforce that law or binding scheme;

(ii) we have taken such steps as are reasonable in the circumstances to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with Privacy Laws;

(iii) or, where required by Privacy Laws, the individual has been expressly informed that if they consent to the transfer, paragraph (a) will not apply, and the individual consents to the transfer.

11. DIRECT MARKETING

(a) With your consent (express or implied) as required by applicable law, we may send you direct marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, over the phone, via SMS or via email, in accordance with applicable marketing laws, . If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

(b) In addition, at any time, you may opt-out of receiving marketing communications from us by contacting us or by using the opt-out facilities provided (e.g. an unsubscribe link, or responding with the appropriate command like “STOP” or “UNSUBSCRIBE” via text), or by updating your personal details on our website using the link provided on this page (if available). We will then ensure that your name is removed from our mailing list within the timeframe required by applicable law.

(c) If you receive communications from us that you believe has been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided in clause 16 below.

12. Automated Individual decision-making (including profiling)

(a) In the ordinary course of our business, we do not use Personal Information to make decisions that are substantially based on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between us, or is not authorised by applicable law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or is not based on your explicit consent.

(b) If your Personal Information is used for automated decision making with legal or similarly significant effect, you have the right to request meaningful information from us about how such decisions are made.

(c) If you wish to exercise your rights please contact us.

13. Third Party Sites

(a) Our Sites may contain hyperlinks to other websites, apps, social media platforms, or banner advertising to or from third-party websites. These links are provided for convenience and may not remain current or be maintained.

(b) We do not endorse any of these third parties, their products or services, or the content on these websites.

(c) These websites are not subject to our privacy standards, policies and procedures. Therefore, we recommend that you make your own enquires about their privacy practices.

(d) We are in no way responsible for the privacy practices or content of these third-party websites, so we encourage you to read those privacy policies before using those websites.

14. Assignment, change of control and transfer

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner. 

15. Changes to the Privacy Policy

We may update this Privacy Policy at any time and from time to time. Any changes will be effective when posted on these Sites. Your continued use of the Sites will indicate your acceptance of any changes to the Privacy Policy. All Personal Information, collected both before and after any changes take effect, will be subject to the terms of the revised Privacy Policy (for which you will be taken to have provided consent) unless you indicate otherwise by contacting the office Funlab’s Privacy Officer as per the details in clause 16. We urge you to refer back to this page regularly and especially prior to providing us with any Personal Information. 

16. Contact Us and Exercise Your Privacy Rights

If you would like to exercise any of your privacy rights, have any feedback or questions about this Privacy Policy, any privacy related dealings with us or a possible breach of your privacy or would like further information about our information management practices, you can contact Funlab’s Privacy Officer, care of the following details:

Email: privacy@fun-lab.com

By telephoning any of the Guest Services phone numbers below: 

Country

Brand

Phone Number

Australia

 

Holey Moley

1300 727 833 

 

Archie Brothers

1300 888 386 

 

B Lucky & Sons 

1300 058 259 

 

Strike

1300 787 453 

 

Hijinx Hotel 

1300 897 224 

 

La Di Darts 

1300 897 223 

New Zealand

Holey Moley

0800 727 833 

 

Archie Brothers

0800 888 386

United States

Holey Moley

310-209-8581

 

Hijinx Hotel

310-209-8581

 

By post to:

Privacy Officer

Funlab Holdings Pty Limited

90-94 Nicholson Street

Abbotsford, VIC, Australia, 3067

Where we offer online account management facilities, Guests can use this capability to control aspects of their account, including amending or updating certain Personal Information. You may also exercise some of your opt out rights by amending the settings of your Internet Browser or your preferences within a cookie banner if you are in a location that serves you one.  You may also notify us at any time that you do not wish to receive marketing or promotional material by contacting us directly or through the “Unsubscribe” mechanism in our marketing or promotional emails.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. We may need to verify your identity before fulfilling certain requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making certain requests on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right under Privacy Law to appeal such decision, you will be notified of our appeal process in our response to your request.

Further information on privacy:

(i) in Australia can be obtained from the OAIC at www.privacy.gov.au;

(ii) in New Zealand, can be obtained from the Privacy Commissioner at https://www.privacy.org.nz/

(iii) in California, can be obtained from State of California Department of Justice at https://oag.ca.gov/privacy/ccpa;

(iv) in Colorado, can be obtained from the Attorney General website at https://coag.gov/resources/colorado-privacy-act/; and

(v) in Texas, can be obtained from the Attorney General website at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint/consumer-privacy-rights/texas-data-privacy-and-security-act.

This Privacy Policy was last updated on 19 March 2026, Version 2.0.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

1. Categories of Personal Information and Recipients

Please see the chart below for detailed information about the categories of Personal Information we have collected from California residents during the twelve months preceding the date on which this Privacy Policy was last updated and the categories of recipients, and third parties to whom we “sell” or “share” Personal Information (as those terms are defined in the California Consumer Privacy Act (“CCPA”)).

Categories of Personal Information

 

Categories of Recipients

 

Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

 

Third-party marketers and other third parties that set cookies and other online tracking technologies on our Site.

 

 

California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, etc.

 

We do not Sell or Share this category of Personal Information.

 

 

Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion.

 

We do not Sell or Share this category of Personal Information.

 

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.

 

Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement.

 

Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.

Geolocation data, such as your IP address.

Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.

 

Sensory data including audio, electronic, visual, thermal, olfactory, or similar information.

 

We do not Sell or Share this category of Personal Information.

Professional or employment-related information.

 

Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.

 

Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99)

 

We do not Sell or Share this category of Personal Information.

Inferences drawn from any of the information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

We do not Sell or Share this category of Personal Information.

Sensitive Personal Information as set forth in Cal. Civ. Code § 1798.140, including social security number, driver’s license number, state identification card, or passport number; citizenship or immigration Information; racial or ethnic origin; account access credentials (like usernames or account numbers combined with password or other security/access code to access an account).

 

We do not Sell or Share this category of Personal Information.

2. Sale and Share

While we do not sell Personal Information in exchange for monetary consideration, we do disclose Personal Information for other benefits that could be deemed a “sale” under CCPA because it is sometimes broadly defined to include activities such as allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.  All other “sales” or “sharing” is described in the chart above.

To exercise the right to opt-out of the sharing of Personal Information or any other rights you have under CCPA, you (or your authorized representative) can follow the process in Clause 16 of the Privacy Policy.  You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request. To the extent you direct us to or consent to our disclosure of Personal Information to third parties, such disclosure does not constitute “sharing” or “selling.” 

3. “Shine the Light”

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, if any. To make such a request, please see how to contact us in Clause 16 of the Privacy Policy.  Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

4. Sensitive Personal Information

Sensitive Personal Information consists of: (1) government identifiers, such as Social Security Numbers and drivers’ license numbers; (2) account log-in information (e.g., financial account or credit card numbers in combination with any required access codes or passwords); (3) precise geolocation information; (4) racial or ethnic origin, religious or philosophical beliefs, or union membership; (5) content of postal mail, email, and text messages, unless the business is the intended recipient of the subject communications; (6) genetic data; and (7) biometric information that uniquely identifies a consumer or information concerning a consumer’s health, sex life, or sexual orientation. To the extent we collect information that is considered Sensitive Personal Information under CCPA, it is listed in the chart above.  We do not “sell” or “share” Sensitive Personal Information for the purposes of cross-context behavioral advertising.

5. Financial Incentives

We may offer you certain financial incentives permitted by the CCPA that may result in different prices or rates. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

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