Privacy Center

In this supplemental California Privacy Notice (“California Privacy Notice” or “Notice”), we, At With Reach UK Ltd., we and our affiliates and subsidiaries (collectively referred to as “Reach”), disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and other California specific requirements. This Notice applies solely to California residents and their Personal Information covered by California law.

California law gives residents of that state certain rights, including: a right to be notified of (and to request more information about) our data collection practices; the categories of data we process; the categories of third parties with whom data is shared; the right to request disclosure (up to twice per year) of the personal information we have about you or have had within the last 12 months: the right to delete that information (under certain circumstances); the right to know if your data is being sold; the right to know what personal information is being sold and to opt-out of such sales (if applicable); the right to receive a copy of your information in a “portable” form so that you may transfer it to other services; and, the right to not be discriminated against for exercising these rights. This Notice provides details on how we honor those rights and the process for exercising them.

Regardless of your location and jurisdiction, we may, at our sole discretion, choose to extend these rights to all individuals, and to comply with reasonable requests in the manner detailed below. We do not charge for these services. Where you are entitled to exercise a right, we will respond to your request within the timeframe set out by applicable law (for California residents this is typically within forty-five (45) days). Where we provide answers on a voluntary basis, we will provide a response within a timeframe that we deem reasonable.

This Notice is part of, and must be read in the context of, our Privacy Notice.

Collecting Your Personal Information

We collect, and have collected, Personal Information from the following categories within the last twelve (12) months:

• Identifiers, such as name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.

• Personal Information as listed in the California Customer Records statute, such as name, signature, Social Security number, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. (Some Personal Information included in this category may overlap with other categories.)

• Biometric information such as facial recognition, fingerprints, photo analysis, or other means of authentication and security-related identity verification which may be enabled by certain devices or security measures.

• Commercial information, such as records of products or services purchased or obtained.

• Internet or other similar network activity pertaining to use of our websites, such as browsing history, search history, information on your interaction with a website, application, or advertisement.

• Professional or employment-related information, such as current or past job history or performance evaluations for our employees and job applicants.

We obtain the categories of Personal Information listed above directly from you, such as from documents or forms you provide to us, or indirectly from you or from third parties, such as where we collect Personal Information through the course of providing services.

How We Use Your Personal Information

We may use or disclose your Personal Information for one or more of the following business purposes:

• To fulfill or meet the reason for which the Personal Information is provided.

• To provide you with information, products or services that you request from us.

• To provide you with email alerts, event registrations and other notices concerning Our products or services, or events or news, that may be of interest to you.

• To carry out Our obligations and enforce Our rights arising from any contracts entered into between you and us.

• To improve Our website(s) and present its contents to you.

• For research, analysis and product development.

• As necessary or appropriate to protect the rights, property or safety of us or others.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your Personal Information directly or as otherwise set forth in the CCPA.

We will not use the Personal Information we collect for materially different, unrelated, or incompatible purposes than those listed above without providing you notice.

Third Parties

We may share your Personal Information with affiliates, service providers and authorized agents for a business purpose. These third parties are restricted from using your Personal Information in any way other than for a business purpose.

In the preceding twelve (12) months, we have shared the following categories of Personal Information with the third parties listed above for a business purpose:

• Identifiers (as described above);

• Categories of Personal Information (as defined above);

• Protected classification characteristics under California or federal law;

• Commercial information;

• Biometric information;

• Internet or other similar network activity; and

• Professional or employment-related information.

We have not sold any Personal information in the past twelve (12) months.

Your Rights over Your Personal Information

The CCPA provides You with specific rights regarding Your Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we provide certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and verify your request, we will provide you with certain information such as the categories of your Personal Information collected, the sources of your Personal Information, and the business purposes for collecting your Personal Information and any additional information as required by the CCPA.

You have the right to request that we delete your Personal Information subject to certain exceptions. Once we receive and verify your request, we will delete, and direct our service providers to delete, your Personal Information from our records, unless an exception applies. These exceptions may include where the Personal Information is necessary to complete the transaction for which we collected the Personal Information, take actions reasonably anticipated within the context of our ongoing business relationship with you, comply with our legal or contractual obligations including retention of records for billing, tax, or other required recordkeeping under applicable regulations, or make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.

Making Requests

To make such a request, please send an email to compliance@withreach.com and please include the phrase “Personal Information Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. You may also send us a written request to:

Reach USA: Fibercove, 1700 S. Lamar Blve #338, Austin TX 78704

At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes.

Only you, or a person duly authorized on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and

• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described above:

• Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to the mailing address indicated above; and

• Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA upon providing us with satisfactory evidence of their power of attorney status in accordance with Probate Code 4303(a).

You may only make a request twice within a twelve (12) month period. Each request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or that you have duly authorized the person making the request on your behalf. Your request must contain sufficient detail that allows us to properly understand, evaluate, and respond to it. In some instances, we may not be able to comply with your request, in which case we will respond with the reasons that prevent us from complying.

We will not discriminate against you for exercising any of your rights under the CCPA.

Updates and Changes

We may update this Policy from time to time. When We do update it, for Your convenience, We will make the updated Policy available on this page. Changes and additions to the Policy are effective from the date on which they are posted. Please review the Policy from time to time to check whether We have made any changes to the way in which We use Your Personal Information.

California Online Privacy Protection Act

As required by the California Online Privacy Protection Act (“CalOPPA”) and the California Business and Professions Code, this Privacy Statement identifies the categories of personally identifiable information (as that term is defined above and under CalOPPA) that we collect through our Site about individual consumers who use or visit our Site and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about CalOPPA at http://consumercal.org/california-online-privacy-protection-act-caloppa/.

Automated Decision Making

Automated decision making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention. You have the right to opt-out of the automated decision making by a business. We do not use automated decision making to process your personal information in a manner that affects your rights or interests. Should we change this practice, we will update this notice accordingly and provide you with all notifications and opportunities to opt-out as may be required by law before such changes will take effect.

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