7. Notice to California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).

We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we disclose such information in the “Information We Collect”, “How We Use Your Information,” and “When We Disclose Your Information” sections of this Privacy Policy.  We provide additional information required by the CCPA below.

1. Categories of Personal Information we collect, use and disclose

Throughout this Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and disclose such information.  The following are the “categories” of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:

Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history or app usage); general geolocation data from IP addresses and precise geolocation information (if you allow us to collect such information from the Rewards Program App); biometric information that may be collected when visiting one of our venues; audio or visual information; physical characteristics, such as if you voluntarily submit a photo or video; characteristics of potentially protected classifications, such as gender; any user-generated content or feedback that you provide; professional or employment related data; and categories of information considered “sensitive” under California law (such as precise geolocation and biometric information).

1. How we use these categories of personal information.

We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law).

• Our or our service providers’ operational purposes;
• Auditing consumer interactions on our site (e.g., measuring ad impressions);
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• Bug detection and error reporting;
• Customizing content that we or our service providers display on the Services (e.g., contextual ads);
• Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
• Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
• Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third party partners;
• Other uses about which we notify you.

Examples of these types of uses are discussed in our main privacy policy in the “How We Use Your Information” section.  We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device. We may also disclose this information to third parties for legal, compliance or security purposes, or in connection with a business transfer, as described further in “When We Disclose Your Information” above.

1. Sale/Sharing of Personal Information and Limit Use of Sensitive Personal Information

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes.  We “sell” or “share” the following categories of information to third-party advertising partners and vendors that support our advertising efforts (such as advertising analytics services):

Identifiers (such as name, address, email address); commercial information (such as transaction data); internet or other network or device activity (such as browsing history and usage information).

If you would like to opt out of our use of your information for such purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under California law, please visit the Privacy Choices link in the footer of our Site. Note, if you use a cookie blocker such as Ghostery, it may block visibility of this link in your website footer. Alternatively, if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Please note, in the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

1. Additional Privacy Rights

In addition to the rights section before in section D above, California residents may make certain requests about their personal information under the CCPA as set forth in Rights Regarding Your Information above.

California residents can also designate an authorized agent to make access and/or deletion requests on their behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

We will take reasonable steps to verify your identity before responding to a request for access and/or deletion from you or your designated agent.  If we are unable to verify you, we may be unable to respond to your requests.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law.  For example, we need certain information in order to provide the Services to you.

If you are a California resident and would like to exercise any of your legal rights under the CCPA, you can email us at [email protected] with your name and type of request you are making.

1. Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes.  To make such a request, please send an email to [email protected] with your name and the subject line “Shine the Light Opt-Out.”