TETON RIDGE PRIVACY POLICY

Last Updated: August 28, 2023

Teton Ridge, LLC, its brands, affiliates, and subsidiaries (“Teton Ridge,” “we,” “our,” or “us”) respects the privacy of the visitors to our digital properties and to our Western lifestyle and sports events, and we are committed to protecting your privacy through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy describes how Teton Ridge collects, uses, discloses, and otherwise processes your personal information when you visit our websites, including www.tetonridge.com, profantasyrodeo.com,https://www.americanrodeo.com, and any other of our websites or digital properties that link to, or post this Privacy Policy  (the “Sites”), download and use our mobile/tablet applications (the “Apps”), register for or participate in our events, research, promotions, and sweepstakes conducted by us, or when you communicate or otherwise interact or engage with us or the products and services available through our Sites or Apps (collectively constituting, the “Services”).

By using our Services, you understand and agree that collection and use of your personal information will be handled in accordance with this Privacy Policy. Your use of our Services, and any dispute over privacy, is subject to our Terms of Service, available at https://www.tetonridge.com/legal/terms, including their applicable terms governing limitations on damages and resolutions of disputes. Please read the Terms of Service, this Privacy Policy, and any other applicable policies carefully before you use our Services.

For additional information about the privacy choices you have regarding your personal information, please review the “User Privacy Rights and Choices” section below, as well as the Additional Privacy Information for U.S. Residents,” which includes additional information about privacy rights for residents of certain U.S. states.

 

Table of Contents

1.      Personal Information We Collect

2.      Purposes for Collecting and Processing

3.      Disclosures of Personal Information

4.      Cookies and Other Tracking Technologies

5.      User Privacy Rights and Choices

6.      Security

7.      External Links and Features

8.      Children’s Privacy

9.      Changes to this Privacy Policy

10.    Contact Us

11.    Additional Privacy Information for U.S. Residents

 

1.   Personal Information We Collect

 

As further described below, we may collect personal information directly from you, from third-party sources, and automatically through your use of our Services.

 

Personal Information We Collect Directly From You: While the personal information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following categories of personal information directly from you:

 

·      Contact Information: when you contact us, including if sign up to learn more about our Services, we may collect your name, email address, phone number, or other similar identifiers, the nature of your inquiry, yourmessage, and any other information you so choose to provide.

·      Account and Profile Information: personal information relating to the creation of an account on our Services, such as first and last name, email address, postal address, telephone number, a unique individual password, and/or and any other information used in connection with accessing your account or that you otherwise submit to us through your account;

·       Form Submissions: personal information that you provide by filling in forms that we make available on our Services or when requesting information or assistance;

·       Marketing and Newsletter Sign-ups: if you agree to receive marketing communications from us, we may collect certain contact information and information relating to our newsletter subscription page, such as name and email address;

·       Communications and Interactions: records and copies of your correspondence (including email addresses and other contact information), if you contact us for customer support or other similar purposes;

·       Promotions and Feedback: personal information relating to your participation in any promotions or surveys we offer, including for research or user satisfaction purposes;

·       Payment Information: payment card, transaction or financial account information, billing information, and shipping address, if you make a purchase online or sign up via our order forms;

·       Events and Other Requests: personal information related to your participation in, or registration for, our events as well as other requests that you submit to us related to our Services;

·       Preferences: information about your preferences, including communications preferences, preferences related to your use of Services, and any other preferences or requests you provide when interacting with us;

·       Business Development Information: to assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective vendors, business partners, and agents, including name, company information, contact details, and communications records.

·       Device Permissions: information relating to your use of features of our Service that may ask you to grant us access to location information, contacts, photos, microphone, video camera, or media on your computer or mobile device.

·       Sponsored Events and Publicity: in addition, if you attend a Teton Ridge-sponsored event in the United States and are interviewed, we may collect information such as your name and likeness, which may be used in our marketing or promotional materials.

·       Sweepstakes Information: from time to time, we may sponsor sweepstakes through which eligible entrants may enter to potentially win a prize and in doing so, we may collect personal information required for entry into a sweepstakes, such as name, mailing address, telephone number and email address. Personal information provided for entry into a sweepstakes may be disclosed with any other sweepstakes sponsors or administrators, in accordance with this Privacy Policy. If you win a contest, promotion, or sweepstakes, we may also collect certain tax information and/or waivers and releases, depending on the prize and as required by applicable law.

 

Personal Information We Collect from Third Parties: We may also collect and receive certain personal information about you from third-party sources, such as from business partners, data analytics and marketing providers, social media platforms, and vendor and service providers who provide services or perform functions on our behalf. For example, we may collect your name, contact details, and other similar information from business partners and vendors and service providers for purposes of providing our Services. In addition, we may collect the following information from third-party sources:

 

·       Social Media Information: when you interact with our Services or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The personal information we may obtain depends on your privacy settings on the applicable social media service. When you access our Services through social media channels or when you connect our Services to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.

· Referral Information: we may offer you the ability to invite other users to access or use our Services. In doing so, we may collect and receive certain personal information about you, including from other current or prospective Teton Ridge customers who similarly engage in these activities.

· Lead and Prospect Information: we may receive lead and prospect information from third parties about customers who may be interested in our Services. We may also engage with third parties to enhance or update our customer information. For example, we may receive certain personal information about you from data analytics and marketing providers for marketing and advertising purposes, and for purposes of reaching new customers.

Personal Information Collected Automatically: As you navigate through and interact with our Services, we may use automatic data collection technologies, such as cookies, pixel tags, and other similar technologies, to collect certain personal information about your equipment, browsing actions and patterns, including:

 

· Information About Your Use of the Services: when you browse our Services, our systems may automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, the date and time of your request, links clicked, searches, features used, and other related activities and usage information.

· Device Information: if you access the Service through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID.

· Location Information: we may also collect or derive general location information about you, such as through your IP address.

 

For more information about our use of cookies and other similar technologies, please see the “Cookies and Other Tracking Technologies” section below.

 

2.   Purposes for Collecting and Processing

 

Generally, we may collect, use, disclose and otherwise process the personal information we collect for the following purposes:

 

· To Provide You Our Services: providing our Services, products or events that you request or purchase in connection with the Services, including to allow you to maintain your account with us and to otherwise run our day-to-day operations;

· To Provide You with Service-Related Communications: contacting you regarding the administration of any features or functions of the Services you have registered to use, and notifying you about changes to our Services, our policies, terms, or any products or services we offer or provide though our Services;

· To Provide Customer Support or to Respond to You: providing you with notices about your account, account troubleshooting and technical support purposes, and responding to your questions or other requests;

· To Send You Marketing and Promotional Materials: contacting you with newsletters, marketing or promotional materials and other information that may be of interest to you based on the Services that you already use or the offerings that you have already purchased or inquired about, unless you have opted not to receive such information;

· To Conduct Marketing and Advertising: conducting our marketing and advertising campaigns and in support of our marketing and advertising efforts;

· For Internal Use and Service Improvement: to better understand how users access and use the Services, and for other research and analytical purposes, such as accumulating and reporting aggregate, statistical information in connection with the Services and user activity, including determining which features and services users like best to help us operate, enhance, and improve our Services;

· To Enforce Compliance with Our Agreements or Policies: to protect the Services and our business operations, including to protect our rights or those of our stakeholders; to you secure and safe while using our Services, which requires us to process your personal information in accordance with this Privacy Policy to combat spam, malware, malicious activities, fraud, or security risks as part of our ongoing maintenance and enforcement of our security measures, and carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;

· To Maintain Legal and Regulatory Compliance: to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, responding to a subpoena, warrant, court order, or other legal process, as well as processing personal information to pay our taxes, fulfill our business obligations, for compliance with employment and recruitment laws, or as necessary to manage risk under applicable law;

· For Event Planning Purposes: for event planning and other management-related purposes, such as event registration and attendance, connecting you with other event attendees and Teton Ridge users, and contacting you about relevant events, presentations, and our Services, including for purposes of facilitating special events, sweepstakes, contests, and promotions, which may have their own specific rules to participate;

· For Customization: saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services); tracking your return visits to and use of the services; tailoring your experience on the Service; and/or otherwise customizing what you see when you visit and use the Services;

· For Research Purposes: to administer surveys and questionnaires, such as for market research or user satisfaction purposes, and for other research purposes, including to provide anonymous reporting for internal and external clients and business partners;

· Defending Our Legal Rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect our rights or interests, including in the context of anticipated or actual litigation with third parties;

· Compliance and Legal Process: to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority;

· Auditing, Reporting, and Other Internal Operations. to conduct financial, tax and accounting audits, audits and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes;

· General Business and Operational Support: to assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions; and

· With Your Consent: for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.

 

3.   Disclosures of Personal Information

 

We may disclose the personal information we collect for the purposes described above and in the following circumstances:

 

· Within Our Corporate Organization. We may disclose your personal information with any subsidiaries and affiliates in order to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis.

· Service Providers. We may employ other companies and individuals to facilitate our Services, provide services on our behalf, perform service-related business activities, or assist us in analyzing how our Services are used. These service providers provide us support services such as website hosting, online store platforms, customer relationship management, order fulfillment and shipping, email and postal delivery, analytics, sweepstakes, surveys, marketing services, videoconferencing, auditors, consultants, and legal counsel. The service providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

· Marketing and Analytics Providers. We may also disclose your personal information, such as device and browsing, and activities and usage information, to marketing and advertising networks, data analytics providers, and other companies who provide marketing or analytics services on our behalf. For more information see the “Cookies and Other Tracking Technologies” section below.

· Corporate Transactions. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.

· As Required by Law and to Protect Lawful Interests. We may disclose your personal information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of Teton Ridge or our customers.

· Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms of Service. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

· With Promotional Partners or Co-Sponsors. If we partner on a promotion or sponsorship with an unaffiliated third party, we may disclose your information, for instance, with the promotional partner or sweepstakes administrator. Teton Ridge also partners with other businesses to offer our products and Services, and we may disclose personal information to those business partners.

· With Your Consent. We may disclose your personal information for any purpose not described above that we notify you of or that we obtain your consent for.

 

Notwithstanding anything else described in this Privacy Policy, we may use and disclose aggregate, deidentified, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes.

 

4.   Cookies and Other Tracking Technologies

 

We and our third-party providers may use cookies, pixel tags, embedded scripts, local storage objects, log files, and other similar technologies (collectively, “Tracking Technologies”) to collect personal information automatically as you interact with the Services. We use this information to, for example, personalize your experience with our Services, to assess, secure, protect, optimize, and improve the performance of our Services, as well as for marketing, advertising, and analytics purposes. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services.

 

To manage your preferences regarding Tracking Technologies, please see the “User Privacy Rights and Choices” section below.

 

 

· Cookies. Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser to allow us to recognize your browser and remember certain information. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track aggregate and statistical information about user activity within the Services or deliver content and advertising tailored to your interests.

· Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

· Analytics. We and our third-party providers may use automated devices, applications, tools, and analytics to monitor and analyze the use of our Services. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

· Behavioral Remarketing. We also use remarketing services to advertise on third-party websites to you after you visit our Services. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Services. Subject to applicable law, we may disclose certain customer list information (such as your name, email address and other contact information, which in most cases is hashed when it is shared) with third parties to target ads and content to you and others with similar interests. In some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns.

· Third-Party Advertising. We work with third-party ad networks, analytics, marketing partners, and others (“third-party ad companies“) to personalize content and display advertising on our Services, as well as to manage our advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites, and to evaluate the success of such ads and content.

· Cross-Device Tracking. We and our providers may use the personal information we collect about you within our Services and on other third-party websites and services to help us and these third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Services.

· Location-Based Services. If you enable location-based services on your computer or mobile device in connection with your use of the Services, you expressly consent to Teton Ridge collecting the geolocation (which may include specific longitude and latitude) of your device. This information will be used as set forth in this Privacy Policy, including to provide specific advertising content or messages based on your location.

 

5.   User Privacy Rights and Choices

 

We make available several ways for you to manage choices about your personal information, including preferences regarding cookies, advertising, whether you want to receive marketing and promotional content from us, and other choices regarding your personal information.

 

· Cookie Settings. If you wish to prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Users of our Site who disable cookies will be able to browse the Site, but some features may not function.

· Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Site, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices tool (https://youradchoices.com/appchoices) in order to help control interest-based advertising on apps on your mobile device. Opting out of participating third party ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Site. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

· Browser Signals. To the extent required by applicable law, if our Site detects that your browser is transmitting an opt-out preference signal, such as a “global privacy control” (or GPC) signal, we will apply that signal to opt that particular browser on your device out of targeting cookies on our Site. If you come to our Site from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well.

· Communication Preferences. In order to provide our Services, we may send you communications related to your transactions, security, or the administration of the Sites and/or our Apps. From time to time, we may also send you other messages or updates about Teton Ridge, our Services, our events, and our other products and offerings. If you do not wish to receive non-transaction or security-related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or by contacting us as specified in the “Contact Us” section below.

· Account Information. You can review and update some of the personal information we maintain about you by logging into your account and updating your account and profile information.

 

Residents of certain jurisdictions may have additional rights to their personal information, as set forth below in the “Additional Privacy Information for U.S. Residents”.

 

6.   Security

 

We have implemented safeguards designed to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Please be aware that despite our best efforts, no data security measures can guarantee security. The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone or re-use the same password on different services.

 

7. External Links and Features

 

Our Services may contain links to third-party websites or features or provide certain third-party connections or integrated services. Any access to and use of such linked websites, features, or third-party connections or integrated services is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection, use, and disclosure of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features or third-party connections or integrated services.

 

8.   Children’s Privacy

 

Teton Ridge’s Services are not directed toward children under the age of thirteen (13), and we do not knowingly collect any personal information from children under the age of 13. If we learn that personal information has been collected on the Services from persons under the age of 13 in violation of applicable law, then we will take the appropriate steps to delete this information. If you are parent or legal guardian and believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

 

9.   Changes to this Privacy Policy

 

This Privacy Policy is current as of the date set forth above. We may change, modify or amend this Privacy Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information we have previously collected from you, we will notify endeavor to provide you with notice, such as by emailing you or by posting prominent notice on our Site or within the Services.

 

10. Contact Us

 

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact us at [email protected].

 

11. Additional Privacy Information for U.S. Residents

 

A. Additional Information for Certain U.S. States

 

Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations and exceptions. These rights may include:

 

· Right to Access. To confirm whether we are processing your personal data and to access such personal data and obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format.

· Right to Correct. To correct inaccuracies in your personal data.

· Right to Delete. To delete personal data provided to or obtained about you.

· Rights to Opt-Out. To opt out of certain types of processing, including:

o   if applicable, to opt out of the sale of their personal information.

o   to opt out of our use of their personal information for purposes of targeted advertising.

o   If applicable, to opt out of our processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

· Right to Appeal. If we deny your request, you may appeal our decision by contacting us at [email protected]

 

You may submit a request to exercise your applicable state privacy rights through our online web form, available at https://privacy.tetonridgeplus.com or by contacting using the contact information provided below.

 

B. Additional Information for California Residents

 

This section of the Policy provides additional information for California residents and describes our information practices pursuant to applicable California privacy laws, including the California Consumer Privacy Act (the “CCPA”). To the extent you are a resident of California, and we collect “personal information” subject to CCPA, the following applies. This section does not address or apply to our handling of our handling of publicly available information or personal information that is otherwise exempt under the CCPA.

 

Categories of Personal We Collect and Disclose. While our processing of personal information varies based upon our relationship and interactions with you, the table below generally identifies the categories of personal information we may have collected about California residents in the past twelve (12) months, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.

 

Categories of Personal Information

Third Party Disclosures for Business or Commercial Purposes

Identifiers: including direct identifiers, such as name, alias, email address, phone number, address, and other contact information; account name and password; unique personal identifier, online identifier, IP address, or other similar identifiers.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· advertising networks

· data analytics providers

· social networks

·       internet service providers, operating systems and platforms

·       others as required by law

Customer Records:including personal information, such as name, account name, contact information, and financial or payment information that individuals provide us in order to purchase or obtain our Services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and Services,

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· advertising networks

· data analytics providers

· internet service providers, operating systems and platforms

· others as required by law

Commercial Information: includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· advertising networks

· data analytics providers

· social networks

· internet service providers, operating systems and platforms

· others as required by law

Internet and Electronic Network Activity Information: including, but not limited to, browsing history, search history, and information regarding interactions with our Sites, Apps, or advertisement on our Services, including other usage data related to your use of any of our Services or other online services. 

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· advertising networks

· data analytics providers

· social networks

· internet service providers, operating systems and platforms

· others as required by law

Location Data: including general location information about a particular individual or device.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· advertising networks

· data analytics providers

· social networks

· internet service providers, operating systems and platforms

· others as required by law

Audio, Visual, and Other Electronic Data: including electronic or visual information, such as your photograph, profile image, or electronic signature, information collected via call recordings, webinars, videos, and other event recordings.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· internet service providers, operating systems and platforms

· others as required by law

Professional Information: if applicable, we may also collect information related to your job title, company name, business email, business phone number, and any other business or professional-related information.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· advertising networks

· data analytics providers

· internet service providers, operating systems and platforms

· others as required by law

Inferences: includes inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, behavior or attitudes.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· advertising networks

· data analytics providers

· social networks

· internet service providers, operating systems and platforms

· others as required by law

Protected Classifications: we may collect some information that is considered a protected classification under California/federal law, including your gender and date of birth.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· others as required by law

Sensitive Personal Information: in limited circumstances, we may collect precise geolocation, racial or ethnic origin, personal information concerning a consumer’s health, driver’s license number, or other similar government identifiers.

· advisors and agents

·  regulators, government entities and law enforcement

· affiliates and subsidiaries

· others as required by law

 

Sales” and “Sharing” of Personal Information. The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) the following categories of personal information to third party ad companies and analytics providers: identifiers; internet and electronic network activity information. We do so in order to improve and evaluate our advertising campaigns, monitor and measure performance of our Services, and better reach customers and prospective customers with more relevant ads and content. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.

 

Sources of Personal Information. In general, we may collect personal information from the following sources: directly from individuals; automatically through our Services; from affiliates and subsidiaries; from third parties, service providers, and our business partners; and from marketing/advertising agencies, analytics firms, social networks, operating systems and platforms.

 

Purposes for Collecting, Using, and Disclosing Personal Information. As described in more detail above, we collect, use, disclose, and otherwise process the personal information we collect for the following business or commercial purposes and as otherwise directed or consented by you:

 

·       To provide you our Services

·       To provide you with service-related communications

·       To provide customer support or to respond to you

·       To send you marketing and promotional materials

·       To conduct marketing and advertising

·       For internal use and Service improvement

·       To enforce compliance with our agreements or policies

·       To maintain legal and regulatory compliance

·       For event planning purposes

·       For customization

·       For research purposes

·       Defending our legal rights

·       Compliance and legal process

·       Auditing, reporting, and other internal operations

·       General business and operational support

·       With your consent

 

Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use, or disclose “sensitive personal information” except as reasonably necessary (i) to perform our Services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.

 

Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we will retain your account information for as long as you have an active account with us and additional information as necessary to comply with our tax, accounting and recordkeeping obligations, to provide you with the services you have requested, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your personal information, we may deidentify or aggregate it and use it in compliance with the CCPA.

 

CCPA Rights. The CCPA provides California residents with specific rights regarding personal information. If you are a California resident, you may have the following rights regarding your personal information, subject to certain conditions and exceptions:

 

· Right to Know/Access. With respect to the personal information we have collected about you, you have the right to request:

o   The categories or personal information we collected about you;

o   The categories of sources from which the personal information is collected;

o   Our business or commercial purposes for collecting, selling, or sharing personal information;

o   The categories of third parties to whom we have disclosed personal information; and

o   A copy of the specific pieces of personal information we have collected about you.

· Right to Correct. You have the right to request that we correct inaccuracies in your personal information.

· Right to Delete. Subject to certain exceptions, you have the right to request we delete personal information we have collected from you.

· Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA.

· Right to NonDiscrimination. You have the right not to be subject to discriminatory treatment for exercising your rights under the CCPA. 

 

Exercising CCPA Rights. California residents may exercise their CCPA privacy rights as set forth below:

 

·       Right to Know, Delete, and Correct. California residents may submit CCPA requests to access/know, delete, and correct their personal information by using our online webform at https://privacy.tetonridgeplus.com calling us at 844-737-6336 or emailing us at: [email protected].

 

Before responding to your request, we must first verify your identity using the personal information you recently provided to us. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

 

You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

 

·       Right to Opt-Out of Sales and Sharing. To exercise your right to opt-out of the “sale” or “sharing” of your personal information, click the “Do Not Sell or Share My Personal Information” link at the bottom of our Services. Please note that submitting an opt out request will only opt you out of disclosures that are considered “sales” or “sharing” under the CCPA, but it will not opt out of other disclosures, such as to our service providers.

 

In addition, if we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your personal information. If you come to our Site or use our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well. More information about GPC is available at: https://globalprivacycontrol.org/.

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