Privacy Policy

Last updated June 27, 2025. Recent changes include: n/a.

Summary

This policy explains the rights of Colorado residents regarding the collection, use, sale, and sharing of their

personal data under the Colorado Privacy Act (CPA), effective July 1, 2023. We may update and make

changes to this policy, so we encourage you to review it periodically.

1. Personal Data We Collect About You. We collect information to provide goods and services to you, to help

improve your customer experience, and for other business purposes. We may collect the following categories of

consumer personal data:

• Identifiers: Information that identifies, relates to, describes, or is capable of being associated with, a

particular individual such as name, signature, address, telephone number, etc.

• Payment Information: Account numbers, credit or debit card numbers.

• Commercial information: Purchase and transaction history.

• Demographic Information. Age, gender, date of birth.

• Profile information. Any form of automated process performed on personal data to evaluate, analyze, or

predict personal aspects related to an identified or identifiable individual's economic situation, health,

personal preferences, interests, reliability, behavior, location or movements.

2. Why We Use Your Personal Information.

• We use your Identifiers and Payment Information for maintaining or servicing accounts, providing

customer service, processing or fulfilling orders and transactions, verifying customer information,

processing payments;

• We use your Commercial Information and Demographic Information for advertising or marketing;

3. Categories of Personal Data We Share with Third Parties.

We do not sell your information to third parties. Ever.

We share the following categories of personal information with third parties for the following specified

purposes:

• We share Identifiers, Payment Information, and Commercial Information for the purpose of processing

payments and bookings, issuing refunds, or bookkeeping/accounting/auditing.

We may share Commercial Information, Demographic Information, and Profile Information for the purposes

of advertising and marketing.

We may share any information provided for the purposes of legal or regulatory compliance.

We limit information shared with service providers to what is necessary to fulfill the services.

4. Who We Share Your Personal Data With. We may share your personal data with:

• Third parties that provide support services to us, including our banking partners, marketing agencies,

analytics providers, web hosts, payment processors, fraud prevention providers, shipping services

providers, product vendors, and other. We limit information shared with service providers to what is

necessary to fulfill the services

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• Third parties for other legitimate business purposes, including our insurers and brokers, credit reporting

agencies, third-party advertisers;

• Third parties approved by you, including social media sites you choose to link your account to or third-

party payment providers;

• Law enforcement and other government agencies and regulatory bodies to comply with our legal and

regulatory obligations.

We only allow our service providers to handle your personal data if we are satisfied, they take appropriate

measures to protect your personal data. We also impose contractual obligations on service providers,

contractors, and third parties to ensure they can only use your personal data to provide services to us and

to you.

We may also need to share some personal data with other parties, such as potential buyers of some or all

of our business or during a re-structuring. We will typically anonymize information, but this may not always

be possible. The recipient of the information will be bound by confidentiality obligations.

5. Your Rights Under the CPA and How to Exercise Them. Residents of Colorado have certain personal

data rights under the Colorado Privacy Act (CPA).

You have the right to:

• Opt-out of the processing of your personal data for purposes of:

○ Targeted advertising

○ Sale of personal data

○ Profiling that produces legal or significant effects on you

• Access your data and to confirm that your data is being processed by us.

• Request deletion of your data held by us.

• Request correction of your data held by us.

• Receive your requested data in a usable and transferable form.

• Non-discrimination or retaliation for exercising any of these rights.

• Designate an agent to exercise your rights on your behalf.

• Appeal if your request is denied.

Responding to Requests. We are required to respond without undue delay but within 45 days of receipt of

your request. Depending on factors such as the type and complexity of the request, we may extend the

time for response once for 45 additional days, as long as we notify you within the original 45 days.

If we decline to take action regarding your request, we must notify you without undue delay, but within 45

days of the receipt of the notice and provide information on our appeal process. We are required to provide

justification and provide information on the appeal process within a reasonable time after the

communication of the decision to decline.

You can request information under the CPA free of charge once per year. For a second or subsequent

request within a 12-month period, we may charge an amount that is the same for the provision of a public

record, which is $0.25 per standard page, or a fee not to exceed the actual cost of providing a copy,

printout, or photograph of the record in a format other than a standard page.

How to Exercise Your Rights: If you would like to access your data, confirm that your data is being

processed by us, request deletion of your data, request correction of your data, or receive your requested

data in a usable and transferable form, you can do so by emailing us at: [contact information].

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If you wish to exercise your opt-out rights, you can do so emailing us at [contact information]. If your

request to exercise your rights is declined, you may appeal by contacting us at [contact information].

If you need to contact us for any reason, you can do so here: [contact information].

• Please note that you may only make a CPA-related data access or data portability disclosure request for

free once within a 12-month period. Subsequent requests may result in fees as noted above.

• If you choose to contact us directly by email, you will need to provide us with:

○ Enough information to identify you (e.g., your full name, address and customer or matter reference

number);

○ Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility

or credit card bill); and

○ A description of what right you want to exercise and the information to which your request relates.

• We are not obligated to make a data access or data portability disclosure if we cannot verify that the

person making the request is the person about whom we collected information or is someone authorized to

act on such person's behalf.

• Any personal data we collect from you to verify your identity in connection with you request will be used

solely for the purposes of verification.