Further information for Virginia consumers
This part of the document uses the term “personal data” as defined in the VCDPA.
Categories of personal data processed
Categories of personal data we collect
We collect the following categories of personal data: identifiers, commercial information and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How we use the data we collect: sharing of your personal data with third parties
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across non-affiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
Access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
Correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
Request the deletion of your personal data. You have the right to request that we delete any of your personal data.
Obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
Opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny services, charge you a different price, or provide a different level or quality of services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfil your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.