Privacy Policy

Willis Piano Music is not a separate entity but is a trading name of Hal Leonard LLC. Hal Leonard LLC is committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be collected, stored, used, disclosed and otherwise processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Hal Leonard LLC is the controller of your personal data that it collects from you or otherwise receives. This means that it determines the purposes and means of the processing of your personal data. However it will process your personal data in accordance with this policy.

1. Definitions

   In this policy:

   1. we / our / us refers to Hal Leonard LLC, a Limited Liability Company, whose principal address is 7777 West Bluemound Road, Milwaukee, WI 53213, United States; and
   2. personal data means any information relating to an identified or identifiable natural person (a data subject), and includes "personally identifiable information" as that term is used in the United States of America (USA). An "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Information we collect about you; policy concerning children

   1. We will collect and process the following personal data about you:

      1. Information you give us. This is information about you that you give us by contacting us via our website or filling in online forms on our website at https://www.willispianomusic.com (our site or our website),by communicating with us by telephone, e-mail or otherwise, by ordering products or services from us, or by posting reviews on our site. The information you give us may include: your name, e-mail address and phone number; your address/shipping address (including city, state/province, ZIP Code and country code); your billing/payment information (including cardholder name, daytime phone, billing address, card type, last 4-digits of the credit card number, and/or PayPal transaction ID - Note that no sensitive credit card information, such as credit card number, card security code, and expiration date is stored in our systems, nor does it flow through any of our processes. All credit card information is processed by our PCI compliant payment processor, PayPal.); where relevant, your job title, company/employer name and work contact details including phone number and address; and, if you are a music teacher or other music professional, in addition to information as above, details of the type of music you teach or your professional role, and your membership of any teaching association or other organization for music professionals. Please be aware that if you fail to provide to us information that we ask for, we may be unable to provide products or services to you or otherwise to fulfill your requirements. It is important that we hold current information about you, so please provide us with any appropriate updates.

      2. Information we collect about you. With regard to each of your visits to our site we will normally automatically collect the following information:

         1. technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, your login information, and information about your computer or other device being used to connect to our site, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
         2. ii. information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

         We also collect records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and use of promotion codes, in connection with our products and services.

      3. Information we receive from other sources. This includes information we receive about you if you use any of our other websites we operate or other services we provide. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) who may provide information about you to us. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
   2. We do not knowingly collect personal data relating to children. If you are under the age of 18 please do not use this website or order products or services from us. Please, instead, ask an adult, such as your parent or guardian, to do these things for you.

3. Cookies

   Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information the cookies we use and the purposes for which we use them see our Cookies Policy.

4. Uses made of the information

   1. We comply with the law. We will only use your personal data to the extent that the law allows us to do so. Under the EU General Data Protection Regulation (the GDPR) we will rely on the following legal bases for processing your personal data:

      1. where it is necessary to perform a contract we have entered into or are about to enter into with you;
      2. where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those interests. Our legitimate interest means our interest in conducting and managing our business, including enabling us to provide you and our other customers with the best products and services we can and the best and most secure experience when dealing with us. In assessing our legitimate interests, we make sure we consider and balance any potential impact (both positive and negative) on you and others and your rights;
      3. where you have given us your consent.

   2. Information you give to us. We will use this information:

      1. to process an enquiry received from you, or to respond to an expression of interest from you in one or more of our products and services;
      2. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request or purchase from us;
      3. to collect payments for any products or services you purchase from us;
      4. to moderate and publish reviews that you post on our site;
      5. to provide you with newsletters;
      6. to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
      7. to provide you with information about other products and services we or our Corporate Affiliates (as defined below) offer that are complimentary to or related to those that you have already purchased or enquired about. This may include products and services that we or our Corporate Affiliates make available through one or more of our other websites or the websites of such Corporate Affiliates;
      8. to provide your information to our marketing department who may contact you to request feedback and comments on our products or services or to provide information to you which may be of interest to you;
      9. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (such as e-mail or SMS) with information about products and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you will be able to withdraw your consent by contacting privacy@willispianomusic.com;
      10. to notify you about changes to our products or services;
      11. to try to ensure that content from our site is presented in the most effective manner for you and for your computer or other device;

   3. Information we collect about you. We will use this information:

      1. to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      2. to improve our site to try to ensure that content is presented in the most effective manner for you and for your computer or other device;
      3. to allow you to participate in interactive features of our service, when you choose to do so;
      4. as part of our efforts to keep our site safe and secure;
      5. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
      6. to make suggestions and recommendations to you and other users of our site about products or services that may interest you or them;
   4. Information we receive from other sources. We will use this information to combine with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

5. Disclosure of your information

   1. You agree that we have the right to share your personal data with selected third parties including:

      1. entities that provide customer service applications to us to better enable us to respond to your requests for information or assistance;
      2. business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, for example suppliers of shipping services to fulfill your orders for physical products;
      3. credit card processors and other payment services providers, for the purposes of effecting payments by or to you;
      4. entities who provide services to us in relation to marketing, in order to assist us in marketing to you as described above;
      5. advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
      6. cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; and
      7. analytics and search engine providers that assist us in the improvement and optimisation of our site.

      Google Analytics. Please note in particular that our site uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site "How Google uses data when you use our partners' sites or apps", currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google's website, including its list of currently available opt-out options presently located at For information on opting out of Google Analytics, we encourage you to visit Google's website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

      Do Not Track. The term "Do Not Track" refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

   2. We will disclose your personal data to third parties:

      1. if Hal Leonard LLC or all or substantially all its assets or the relevant part of its assets (e.g. those associated with its Willis Piano Music business) are acquired by a third party, in which case personal data held by it about its customers (or the relevant customers) will be one of the transferred assets; or
      2. if we are under a duty to disclose or share your personal data in order to: comply with any legal obligation; or to enforce or apply our standard terms and conditions of business and other agreements; or to protect the rights, property, or safety of Hal Leonard LLC, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
      3. if we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding; or
      4. to our Corporate Affiliates; for purposes of this privacy policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Hal Leonard LLC, whether by ownership or otherwise; and control means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

6. Where we store your personal data

   1. All information you provide to us is stored on secure servers. These may be located anywhere in the world, including the USA. See below concerning international transfers of personal data.
   2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. This includes encryption of some information.
   3. We will also require third parties to whom we disclose your personal data to take appropriate measures to ensure the security of your personal data and not to use it except for the purposes for which we disclose it to them.

7. International transfers of personal data

   1. Many of our external third parties to whom we transfer your personal data as described above are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

   2. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

      1. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
      2. Where we use providers based in the United States of America, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

      Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Retention of personal data

   1. We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected your personal data.
   2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of that personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If by law we are required to retain any information about our customers or their interactions with us, we will retain your personal data insofar as required to comply with such law.
   3. We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

   1. Under certain circumstances, you have the right to:

      1. Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
      2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data in certain other circumstances, namely where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
      5. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
      6. Request the transfer of your personal data to you or to another person or entity. In that case we will provide to you, or to the person or entity to whom you wish us to transfer your personal data, your personal data in a structured, commonly used, machine-readable format.
      7. Withdraw consent at any time where we are relying on consent to process your personal data. However this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
      8. Lodge a complaint with the UK Information Commissioner's Office (ICO) or another applicable regulator. If you have any complaints about the way in which we process your personal data please do contact us, as set out below, as we would appreciate the opportunity to resolve your complaint.
   2. b. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us using the contact details provided below.

10. Other websites

    Our site may, from time to time, contain links to and from the websites or apps of our partner networks, advertisers and affiliates. If you follow a link to any of these websites or apps, please note that these websites and apps have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites or apps.

11. Changes to our privacy policy

    Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

12. Contact

    Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@willispianomusic.com.

California Consumer Privacy Act Policy

13. Privacy Notice for California Residents: This Section 13 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the "CCPA")) under the CCPA. This Section 13 shall apply to you only if you are a California resident.

    As used in this Section 13, "sell" (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to another business or a third party for monetary or other valuable consideration.

    "Selling" does not include (i) disclosing consumer information to a third party at your direction, provided the third party does not sell the consumer information except in accordance with the CCPA, (ii) where you intentionally interact with a third party through our products or services, provided the third party does not also sell the consumer information, (iii) using or sharing your consumer information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on Willis Piano Music's behalf and provided that the service provider does not further collect, sell or use the consumer information except as necessary to perform the business purpose, or (iv) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Willis Piano Music, provided that information is used or shared consistently with the CCPA.

    Where noted in this privacy policy, until January 1, 2021, the CCPA exempts consumer information reflecting a written or verbal business-to-business communication ("B2B consumer information") from some its requirements, provided that such exemptions shall not apply from and after January 1, 2021.

    1. Consumer Information Collected: We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents, devices or households ("consumer information"). Consumer information does not include deidentified or aggregated information, publicly available information from government records, or any other information that is excepted from the definition of "personal information" under the CCPA, or any information that is otherwise not regulated by the CCPA. In particular, we have collected the following categories of consumer information from California residents, households or devices within the last twelve (12) months:

       Category	Examples	Business or commercial purposes for which we collect and use consumer information
       A. Identifiers.	Name; e-mail address; telephone number; and address (including city, state/province, ZIP code and country code).	For the business and commercial purposes described in Sections 3 and 4, of this privacy policy.
       B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name; e-mail address; telephone number; address (including city, state/province, ZIP code and country code); and billing/payment information (including cardholder name, billing address, card type, last 4-digits of the credit card number, and/or PayPal transaction ID.	For the business and commercial purposes described in Sections 3 and 4, of this privacy policy.
       C. Commercial information	Records of personal property, products or services purchased, obtained, or considered; and/or other purchasing or consuming histories or tendencies, and use of promotion codes, in connection with our products and services.	For the business and commercial purposes described in Sections 3 and 4, of this privacy policy.
       D. Internet or other similar network activity.	Technical information, including the IP address used to connect your computer or other device to the Internet; your login information; information about your computer or other device being used to connect to our site, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full URL, clickstream to, through and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.	For the business and commercial purposes described in Sections 3 and 4, of this privacy policy.
       E. Professional or employment-related information.	Job title; company/employer name; work contact details, including phone number and address; and, if you are a music teacher or other music professional, details of the type of music you teach or your professional role, and your membership of any teaching association or other organization for music professionals.	For the business and commercial purposes described in Sections 3 and 4, of this privacy policy.
       F. Inferences drawn from other personal information.	Inferences reflecting personal preferences and predispositions.	For the business and commercial purposes described in Sections 3 and 4, of this privacy policy.

    2. Use of Consumer Information; Categories of Sources: We use consumer information for the business or commercial purposes described in the table above and in the manner described in Sections 3 and 4 of this privacy policy with respect to personal data.

       Regarding the categories of sources from which consumer information is collected, we collect consumer information that you submit to us. We also receive information that is otherwise collected when you use our website, including as described in Sections 2(a)(ii) and 3.

       We may receive information about you if you use any of our other websites we operate or other services we provide. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) who may provide information about you to us.

    3. Disclosures of Consumer Information for a Business or Commercial Purpose: Willis Piano Music may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in Section 5 of this privacy policy with respect to personal data. In the preceding twelve (12) months, Willis Piano Music has disclosed the categories of consumer information described in the table below (as further described in Section 13.1) for a business or commercial purpose to the following categories of third parties (as further described in Section 5 of this privacy policy):

       Category	Categories of third parties to whom we have disclosed consumer information for a business or commercial purpose in the preceding twelve (12) months.
       A. Identifiers	entities that provide customer service applications to us to better enable us to respond to your requests for information or assistance; business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, for example suppliers of shipping services to fulfil your orders for physical products; credit card processors and other payment services providers, for the purposes of effecting payments by or to you; entities who provide services to us in relation to marketing, in order to assist us in marketing to you as described above; advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others; cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; analytics and search engine providers that assist us in the improvement and optimization of our site; and Corporate Affiliates.
       B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), provided that this disclosure shall only apply to data elements that are listed in Section 13.1.B but that are not also listed in Section 13.1.A (Identifiers).	credit card processors and other payment services providers, for the purposes of effecting payments by or to you.
       C. Commercial information	entities that provide customer service applications to us to better enable us to respond to your requests for information or assistance; business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, for example suppliers of shipping services to fulfil your orders for physical products; credit card processors and other payment services providers, for the purposes of effecting payments by or to you; entities who provide services to us in relation to marketing, in order to assist us in marketing to you as described above; advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others; cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; analytics and search engine providers that assist us in the improvement and optimization of our site; and Corporate Affiliates.
       D. Internet or other similar network activity	entities that provide customer service applications to us to better enable us to respond to your requests for information or assistance; business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, for example suppliers of shipping services to fulfil your orders for physical products; credit card processors and other payment services providers, for the purposes of effecting payments by or to you; entities who provide services to us in relation to marketing, in order to assist us in marketing to you as described above; advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others; cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; analytics and search engine providers that assist us in the improvement and optimization of our site; and Corporate Affiliates.
       E. Professional or employment-related information.	entities that provide customer service applications to us to better enable us to respond to your requests for information or assistance; business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, for example suppliers of shipping services to fulfil your orders for physical products; credit card processors and other payment services providers, for the purposes of effecting payments by or to you; entities who provide services to us in relation to marketing, in order to assist us in marketing to you as described above; advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others; cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; analytics and search engine providers that assist us in the improvement and optimization of our site; and Corporate Affiliates.
       F. Inferences drawn from other personal information.	entities that provide customer service applications to us to better enable us to respond to your requests for information or assistance; business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, for example suppliers of shipping services to fulfil your orders for physical products; credit card processors and other payment services providers, for the purposes of effecting payments by or to you; entities who provide services to us in relation to marketing, in order to assist us in marketing to you as described above; advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others; cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; analytics and search engine providers that assist us in the improvement and optimization of our site; and Corporate Affiliates.

    4. Sales of Consumer Information: In the preceding twelve (12) months, Willis Piano Music has not sold, nor does it or will it sell, consumer information.

    5. California Residents' Rights and Choices: The CCPA provides California residents with specific rights regarding their consumer information. This Section 13.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.

       1. Access to Specific Information and Data Portability Rights: You may have the right to request that Willis Piano Music disclose certain information to you about our collection and use of your consumer information over the past 12 months. Once we receive and confirm your verifiable consumer request (in the manner described in Section 13.6 below), to the extent required by the CCPA, we will disclose to you:

          1. The categories of consumer information we collected about you.

          2. The categories of sources for the consumer information we collected about you.

          3. Our business or commercial purpose for collecting that consumer information.

          4. The categories of third parties with whom we share that consumer information.

          5. The specific pieces of consumer information we collected about you (also called a data portability request).

          6. If we disclosed your consumer information for a business or commercial purpose, a list disclosing disclosures for a business or commercial purpose, identifying the consumer information categories that each category of recipient obtained.

          We will not provide the foregoing access and data portability rights for B2B consumer information prior to January 1, 2021.

       2. Deletion Request Rights: You have the right to request that Willis Piano Music delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you (if you are a California resident) in the manner described in Section 13.6 below ("verifiable consumer request"), we will delete (and direct our service providers to delete) your consumer information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

          1. Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

          2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

          3. Debug products or services to identify and repair errors that impair existing intended functionality.

          4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

          5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

          6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

          7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

          8. Comply with a legal obligation.

          9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

          We will not provide the foregoing deletion rights for B2B consumer information prior to January 1, 2021.

    6. Exercising Access, Data Portability, and Deletion Rights:

       1. To exercise the access, data portability, and deletion rights described in Section 13.5 above, please submit a verifiable consumer request to us by either: (1) calling us at 1-800-524-4425; or (2) contacting us in accordance with Section 12. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use consumer information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We use the following process to verify consumer requests:

          • Email Verification
          • Additional account identification questions if needed.

       2. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

    7. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:

       1. Denying you goods or services.

       2. Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

       3. Providing you a different level or quality of goods or services.

       4. Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Cookie Policy

Information about our use of cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after 30 days.

Last updated: July 28^th, 2020