CCPA Privacy Notice

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA“), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA.

Except for the right to opt-out and the right of non-discrimination, this section does not apply to California residents with whom we transact or communicate solely in the context of providing or receiving a product or service to or from a company that employs such residents or engages such residents as contractors. This section also does not apply to personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of X-trodes or any affiliated entities.

CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT, DISCLOSE, AND SELL

We have set out in our Privacy Policy the categories of Personal Data (“personal information” as defined under the CCPA) about California residents that we collect, which include: (A) Identifiers, (B) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), (F) Internet or other similar network activity, and (I) Professional or employment-related information. As noted below, we do not sell your personal information or disclose it to third parties for a business purpose. We may disclose each of these categories of personal information to our service providers, who are not permitted to use your personal information except as necessary for performing services on our behalf. We collect these categories of personal information from the sources and for the purposes described in our Privacy Policy under the heading “Types of Data We Collect and Purpose of Processing“. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation.

CALIFORNIA CONSUMER RIGHTS

California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.

Right to Opt-out of Sale of Personal Information (“Do Not Sell”)

California residents have the right to opt-out of sale of their personal information. Please note, we do not sell your personal information.

Requests for Copy, Deletion and Right to Know

Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see “Submitting Requests” for instructions on how to exercise your rights.

Deletion: the right to request deletion of personal information that we have collected about you, subject to certain exemptions.

Copy: the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.

Right to Know (Collection): Where we have collected personal information about you, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling your personal information; and the categories of third parties/with whom we have disclosed or shared your personal information.

Right to Know (Disclosure and Sale): Where we have sold or disclosed for a business purpose your personal information, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories of personal information that we have disclosed or shared with a third party for a business purpose.

Submitting Requests. You can exercise your rights by emailing us at: contact@xtrodes.com. Once you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information or use identity verification services to assist us. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to an appropriate degree of certainty. We will make every reasonable effort to respond to you within 45 days after we receive a verified request. If we are unable to meet this timescale, we will respond as soon as possible over the next 45-day period.

INCENTIVES AND DISCRIMINATION

The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information.

If consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data.