CCPA Privacy Policy for California Residents

Effective Date: January 2025. Last Updated on: January 2025.

This Privacy Policy for California Residents supplements the information contained in Creation Rights' general Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA's scope (e.g., health information covered by HIPAA, information covered by the Fair Credit Reporting Act, etc.).

We have collected the following categories of personal information from consumers within the last twelve (12) months:

• A. Identifiers: name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, SSN, driver's license number, passport number, or similar identifiers. Collected: YES
• B. California Customer Records: name, signature, SSN, physical characteristics, address, telephone number, passport number, driver's license number, insurance policy number, education, employment, bank account number, credit card number, or other financial, medical, or health insurance information. Collected: YES
• C. Protected classification characteristics: age, race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, disability, sex, sexual orientation, veteran status, genetic information. Collected: YES
• D. Commercial information: records of personal property, products or services purchased or considered, purchasing histories or tendencies. Collected: YES
• E. Biometric information: genetic, physiological, behavioral, biological characteristics. Collected: YES
• F. Internet or other similar network activity: browsing history, search history, information on interaction with website or advertisement. Collected: YES
• G. Geolocation data: physical location or movements. Collected: YES
• H. Sensory data: audio, electronic, visual, thermal, olfactory, or similar information. Collected: YES
• I. Professional or employment-related information: job history or performance evaluations. Collected: YES
• J. Non-public education information: education records. Collected: YES
• K. Inferences: profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, aptitudes. Collected: YES

We obtain the categories of personal information listed above from: directly from you (e.g., from forms you complete or products and services you purchase); and indirectly from you (e.g., from observing your actions on our Website).

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes: to fulfill or meet the reason you provided the information; to provide, support, personalize, and develop our Website, products, and services; to create, maintain, customize, and secure your account; to process your requests, purchases, transactions, and payments; to provide you with support and respond to your inquiries; to personalize your Website experience and deliver content and offerings relevant to your interests; to help maintain the safety, security, and integrity of our Website and business; for testing, research, analysis, and product development; to respond to law enforcement requests and as required by law; as described to you when collecting your personal information; and to evaluate or conduct a merger, divestiture, or other sale or transfer of assets. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these disclosures under written contracts that describe the purposes and require the recipient to keep the personal information confidential. In the preceding twelve (12) months, the Company has not disclosed personal information for a business purpose to the categories of third parties indicated in the chart in the full policy. We may also share your personal information by selling it to third parties, subject to your right to opt-out. In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your request, we will disclose: the categories of personal information we collected about you; the categories of sources for that information; our business or commercial purpose for collecting or selling that information; the categories of third parties with whom we share that information; and the specific pieces of personal information we collected about you (data portability request). We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will review your request and delete or deidentify personal information not subject to an exception. We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete, please submit a request by either: calling us at +1 212-624-2518; or emailing us at team@creationrights.com. Only you, or someone legally authorized to act on your behalf, may make a request. You may only submit a request to know twice within a 12-month period. Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (e.g., proof of ID, proof of authority, proof of guardianship) and describe your request with sufficient detail. We cannot respond to your request if we cannot verify your identity. We will confirm receipt within ten (10) business days and endeavor to respond within forty-five (45) days.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years old. To exercise the right to opt-out, you may submit a request by visiting the "Do Not Sell My Personal Information" link on our Website or by emailing team@creationrights.com. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate or level or quality of goods or services. We may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels, with your prior opt-in consent.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes, we will post the updated notice on the Website and update the effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Creation Rights collects and uses your information, your choices and rights, or wish to exercise your rights under California law, please contact us at:

Phone: +1 212-624-2518
Website: www.creationrights.com/contact
Email: team@creationrights.com
Postal Address: Creation Rights, Attn: Scarbrough Building, 522 Congress Ave., Suite 400, Austin, Texas, 78701, USA

If you need to access this Policy in an alternative format due to having a disability, please contact team@creationrights.com and +1 212-624-2518.