Privacy Policy

Last Updated: January 11, 2024

Wizer Feedback Ltd., together with its subsidiaries and affiliated companies (collectively “Wizer“, “we“, “us” or “our“) respect your privacy and recognize that your privacy is important.

This privacy policy (“Privacy Policy“) explains the Wizer’s practices regarding the collection, processing, usage and transfer of certain data, including Personal Data (as defined below), from its users accessing to and using its proprietary intelligent automated research platform and digital research wizard (“Platform“ and “Customer” respectively), from its website’s visitors and job applicants (“Visitor” and collectively with the Customer will be referred as “you” or “your”), and provides you with a detailed explanation regarding your rights and how you can exercise them. 

This Privacy Policy is an integral part of the Wizer’s Master Service Agreement or our Terms and Conditions, as applicable depending on your interaction with us. 

Note you are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. 

This Privacy Policy applies to all individuals world-wide, however, certain jurisdictions require that applicable disclosures will be provided in a certain way and format, and therefore additional notices apply as follows: 

Additional Information to California Residents: In the event you are a California resident– please also review our CCPA Privacy Notice to learn more about our privacy practices with respect to the California Consumer Privacy Act.

Additional Information to Colorado Residents: In the event you are a Colorado resident – please also review our CPA Notice to learn more about our privacy practices and your rights under the Colorado Privacy Act.

Additional Information to Connecticut Residents: In the event you are a Connecticut resident– please also review our CDPA Notice to learn more about your rights under the Connecticut Data Privacy Act.

Additional Information to Virginia Residents: In the event you are a Virginia resident– please also review our VCDPA Notice to learn more about our privacy practices and your rights under the Virginia Consumer Data Protection Act.

Additional Information to Utah Residents: In the event you are a Utah resident – please also review our UCPA Notice to learn more about your rights under the Utah Consumer Privacy Act.

  1. Policy Amendments 

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website and reflected in the “Recently Updated” heading. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

  1. Data Controller and Data Protection Officer

Wizer Feedback Ltd., incorporated under the laws of the State of Israel, is the “Data Controller” (as such term is defined under the GDPR or equivalent data protection legislation) of the Personal Data collected from you with regards to your access to and use of our Platform and this website.

If you have any question, inquiry, request or concern related to this Privacy Policy or the processing of your Personal Data, you may contact us and our privacy team as follows:

  1. Data Processed by Wizer

We may collect two types of information from you, depending on your interaction with us: 

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your actions in the Website or Services (such as session duration). 

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data” or “Personal Information” as defined under the applicable data protection law). 

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations: 

Type of DataPurposes and OperationLawful Basis under the GDPR
Visitors
Online Identifiers and Telemetry Data:When you interact with the website, we collect and generate online identifiers such as your Internet Protocol address (“IP”), and additional identifiers allowing us to individually identify you, such as a Cookie ID which is assigned to your device (“Online Identifiers“).Further, additional information is collected regarding your “website online behavior”. Such information includes the pages you viewed, click stream data, access time stamp, etc. (collectively “Telemetry Data“)Online Identifiers and certain Telemetry Data are used in particular to operate the website and enable its proper functionality, for security and fraud prevention purposes, debugging and to resolve technical problems. For example, in order to automatically recognize you by the next time you enter the website or to confirm you are a real person. Online Identifiers and Telemetry Data are indirectly processed by third-parties marketing and analytic tools, for analytic and marketing purposes. We process this data to understand how Visitors use our website and to measure effectiveness of some marketing campaigns we run in order to track conversions, build targeted audience, and market our services to people who have taken some action on the website. Online Identifiers which are collected through cookies we implement, which are strictly necessary for the proper and basic operation of the website or fraud prevention will be processed in our legitimate interest. Telemetry Data which are collected through third-party tracking technologies, including any targeting and marketing cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management. You may withdraw consent at any time by using the cookie preference settings as available in the footer of the website, or by managing opt-out through your browser or device.
Contact Information:If you voluntarily contact us for support or other inquiries, or if you register to receive our newsletter (to the extent available), book a demo, or otherwise, you will be required to provide us with certain information such as your name, email address, organization name, etc. In addition, you can choose to provide us with additional information as part of your correspondence with us (“Contact Information”).Respond To a Query:We collect your Contact Information to provide you with the support you requested or to respond to your inquiry.We process the Contact Information in order to provide you the requested support, subject to our legitimate interest. 
Newsletter and Demo:If you registered to receive our newsletter or booked a demo, we will use you Contact Information in order to provide you with the requested service.When we process your Contact Information in order to send you our newsletter or provide you with the demo, we do so based on your consent which can be withdrawn at any time using the “unsubscribe” link within the communications we sent you.
Improve the Services:The correspondence with you may be processed and stored by us in order to improve our customer service and in the event, when we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). When we process your Contact Information on order to improve our customer services, we do so based on our legitimate interest.
Direct Marketing:When you contact us, we may use your email address in order to send you service communications and marketing promotions, such as new features, additional offerings, special opportunities or any other information we think you will find valuable (“Direct Marketing”).When we process your email address in order to send you Direct Marketing, we do so based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly. 
Keep a suppression list:We will further use your email address, if applicable, under our suppression list, when you request to opt-out to ensure we comply with such preference and choice.We will keep you email address for purpose of maintaining a suppression list based on our legitimate interest.
Additional Features:In the event you choose to provide feedback, post on our website or social media pages, you may be required to provide us with certain additional information such as your role, country, company name, etc.We will use this information for the purpose of providing you with the services that you requested.We process this information subject to our legitimate interest.
Recruitment: When you apply for a job at Wizer, we will process your CV (and the information included therein), as well as additional information such as your contact information (name, email address and phone number), information regarding your education and skills, employment history, and your photo (to the extent provided by you).
Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability.
In addition, we may collect other information from public and online sources, referees, background checks where applicable, and former employers and combine such data with the data you provided us (collectively, “Recruitment Data”).
We will use your Recruitment Data to process your job application and for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements.Following the completion of the recruitment process, we may further retain and store the Recruitment Data (including other interactions with us under such process) as part of our internal records keeping, including for legal defense from any future claim, as well as, and subject to applicable law requirements, to contact you in the future for other position we believe you qualify for.
If you are hired, your Recruitment Information will be kept on our HR systems as part of your employment and our corporate management.
We process Recruitment Data subject to our legitimate interest.
In some cases, for example, where we will ask you to provide diversity and inclusion data, we will process such data based on our obligations in employment and the safeguarding of your fundamental rights.
 
Where you provided your consent, we will process your Recruitment Data in order to contact you with further job offers which we believe you might be interested in.
Customers
Contact Information:If you voluntarily contact us for support or other inquiries, you will be required to provide us with certain information such as your name, email address, organization name, etc. In addition, you can choose to provide us with additional information as part of your correspondence with us (“Contact Information”).Further, in order to access the Platform and use the Services, you will be required to register and open an account. During the registration process you will be requested to provide us with your Contact Information and additional information on the company you represent. Respond To a Query:We collect your Contact Information to provide you with the support you requested or to respond to your queries.When we process your Contact Information in order to provide you with the requested support, we do so in order to fulfill our contractual obligations and provide the support services, all as agreed in the MSA or other agreement governing your access to the Platform and use of our service.
Improve the Services:The correspondence with you may be processed and stored by us in order to improve our customer service and in the event, when we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).When we process your Contact Information on order to improve our customer services, we do so based on our legitimate interest.
Account Creation:We will use your Contact Information in order to create your account.When we process your Contact Information in order to create your account, we do so in order to fulfill our contractual obligations and provide the services, all as agreed in the MSA or other agreement governing your access to the Platform and use of our service.
Direct Marketing:When you contact us, we may use your email address in order to send you Direct Marketing.When we process your email address in order to send you Direct Marketing, we do so based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly. 
Keep a suppression list:We will further use your email address, if applicable, under our suppression list, when you request to opt-out to ensure we comply with such preference and choice.We will keep you email address for purpose of maintaining a suppression list based on our legitimate interest.
Payment Details:As part of the services, you may need to provide us with your payment details including credit card and bank account information (“Payment Details”).  We use your Payment Details for billing purpose, for the purpose of enabling you to use the services. We process your Payment Details for the purpose of performing our contract with you.
Telemetry Data:When you access to our Platform and use the services, we automatically generate, collects and process information on how you use interact with the Platform and use the services. Such information includes the click streams within Platform, the features used, duration, the credentials (access logs that identify your email, user name, and credentials), crash data and analytics, etc. (“Telemetry Data”).We use the Telemetry Data to help us understand how our users are using the services and how to better provide and improve our services. Obtaining such data assist us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers, decide how to improve the service based on the results obtained from this processing.  We process the Telemetry Data subject to our legitimate interest.
Respondents Data
When sharing a survey through our services, certain data regarding such respondents will be collected.We act as the processor when we collect and process Respondents Data, which is processed on behalf of our Customer, in order to provide our services.The lawful basis for processing the Respondents Data is obtain by our Customers.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in Section 7 “Cross-Border Data Transfer” below is based on the same lawful basis as stipulated in the table above.  

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the website and services and to enforce our policies and agreements, as well as to protect the security or integrity of our databases and the services, and to take precautions against legal liability. Such processing is based on our legitimate interests. 

  1. How We Collect Information

Depending on the nature of your interaction with us through the website, we may collect information as follows:

  1. Cookies and Similar Tracking Technologies

When you access to or use the website and the Platform, we use “cookies” or similar tracking technologies, which store certain information on your device (i.e., locally stored). The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are used by us for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and advertising. You can find more information about our use of cookies here: www.allaboutcookies.org.

Please note, most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that once you choose to opt out or disable cookies, some features of the website may not operate properly, and your online experience may be limited.

  1. Data Sharing – Categories of Recipients with Whom We Share Personal Data

We share your Personal Data with third parties, including with trusted partners or service providers that help us to manage our business operation, website, etc. You can find here information about the categories of such third-party recipients. ‍

CATEGORY OF RECIPIENTDATA THAT WILL BE SHAREDPURPOSE OF SHARING
Service providers
All types of Personal DataWe may disclose Personal Data to our trusted agents and service providers (including, but not limited to, our Cloud service provider, our analytics service provider, our CRM provider, etc.) so that they can perform requested services on our behalf. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services. 
Affiliated companiesAll types of Personal Data We may share certain information with our affiliated companies, which will provide us with certain required services and, for internal compliance and measurement.  
Any acquirer of our businessAll types of Personal DataWe may share all types of Personal Data in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In such event, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Governmental agencies or authorized third partiesSubject to law enforcement authority request.We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or security of Wizer, our customers, partners, or others.We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.
  1. Cross-Border Data Transfer

Due to our global business operation, your Personal Data may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different to the laws of your country. However, in all cases, we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer.

Specifically, if and where Personal Data collected within the EU is transferred outside the EU to countries which were not granted with an adequacy decision by the European Commission and therefore do not provide an adequate level of protection to your Personal Data while it is transferred to such third-country, such transfer is subject to and made pursuant with the standard contractual clauses

Additionally, if and where Personal Data collected within the UK is transferred outside the UK to countries which were not granted with an adequacy decision by the UK Information Commissioner Office (‘ICO’) and therefore do not provide an adequate level of protection to your Personal Data while it is transferred to such third-country, such transfer is subject to and made pursuant with the UK standard contractual clauses.

  1. Data Retention

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. 

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

  1. Privacy Rights

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed. 

In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table: 

Right to be informed You have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy.
Right to know; access rightsYou have the right to confirm whether we collect Personal Data about you, know which Personal Data we specifically hold about you, and receive a copy of such or access it. if you wish to receive a copy of the Personal Data, please submit a Data Subject Request form (“DSR”) as available here.
Right to correction/ rectificationYou have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. Please submit a DSR as available here.
Right to be forgotten; Right to deletionIn certain circumstances, you have the right to delete the Personal Data we hold about you. For specifications regarding this right and its exclusions, or if you wish to ask to exercise this right, please submit a DSR as available here.
Right to portabilityYou have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please submit our DSR as available here.
Right to opt out under the EU and specifically in the US the right to opt out from: (i) selling personal data; (ii) right to opt out from targeted advertising; and (iii) right to opt out from profiling and automated decision makingCookies and specifically opt out from sale of personal data for targeted advertising, monetary gain or profiling, or share or sale of personal information for analytic or marketing: When you no longer wish for cookies to track your behavior for analytic or marketing purposes, you are able to change your preferences as detailed above under Section 5 or contact us directly at: wizer.dpo@getwizer.com. Newsletter: You have the right to withdraw consent when you no longer wish to be in our newsletter list.Further, you are able to install privacy-controls in the browser’s settings to automatically signal the opt-out preference to all websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control, where applicable, subject to your jurisdiction, as a valid request to opt-out of the sharing of information linked to your browser.Note you may have the right to authorize another person acting on your behalf to opt out (including by technical tools and opt out signals).
Right to appeal or lodge a complaint If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK. 
Non-discriminationSuch discrimination may include denying a service, providing a different level or quality of service, or charging different prices. We do not discriminate our users and visitors. 
  1. Security

We take great care in implementing and maintaining the security of our website Visitors’ and Customers’ Personal Data. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any such.

We have implemented technical, physical and administrative security measures to protect the Personal Data we process. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: wizer.dpo@getwizer.com, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

  1. ‍Children’s Data

The website and Platform are not intended for individuals under the age of eighteen (18). Accordingly, we do not knowingly solicit Personal Data from or market to children as defined under applicable law. We request that such individuals do not provide Personal Data. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us through the means of contact detailed herein.

  1. JURISDICTION-SPECIFIC NOTICES
    • A – ADDITIONAL INFORMATION FOR COLORADO RESIDENTS

This section applies to Colorado residents acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context). 

Under the Colorado Privacy Act (“CPA”), Wizer is required to provide a privacy notice that identifies the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 9 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising, if applicable. 

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at wizer.dpo@getwizer.com, and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/ 

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

This section applies to Connecticut residents acting only as an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity).

Under the Connecticut Data Privacy Act (“CDPA”), Wizer is required to provide you with a clear and accessible privacy notice that includes the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 9 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising, if applicable. 

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension. If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at wizer.dpo@getwizer.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

This section applies to Virginia residents acting only as an individual or household context (and not in an employment or commercial context).

The Virginia Consumer Data Protection Act (“VCDPA”) requires Wizer to disclose the following: In Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 9 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising, if applicable. 

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at wizer.dpo@getwizer.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

This section applies to Utah residents acting only as an individual or household context (and not in an employment or commercial context).

Under the Utah Consumer Privacy Act (“UCPA”), Wizer is required to provide you with a clear and accessible privacy notice that includes the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 9 to this Privacy Policy details and discloses your rights if and to the extent applicable under the UCPA. 

We will respond to your request within 45 days after receipt of your request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, we will provide with the reasoning for our refusal. 

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

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