Supplemental Privacy Notice

We obtain this information from the various categories of sources:

• Directly from you. For example, from information you provide to inquire about our services.
• Indirectly from you. For example, from observing your interactions on our website.

2.) How We Use, Disclose, Share, and Sell Information We Collect. 

• Disclosing Personal Information

Pursuant to our Privacy Policy, in the preceding twelve months, we have disclosed the following categories of personal information to service providers to process on our behalf:

• Identifiers
• Personal information categories listed in the California Customer Records statute
• Protected classification characteristics under California or federal law
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Professional or employment-related information
• Inferences drawn from other personal information
• Sensitive personal information

• Sharing Personal Information for Personalized Advertising

Pursuant to our Privacy Policy, while Company does not share personal information for its own cross-context behavioral advertising, Company does facilitate other companies’ sharing of personal information for their advertising purposes. This enables the retailer to generate advertisements that are tailored to your particular preferences and interests. In the preceding twelve months, we have shared the following categories of personal information to retailers:

• Identifiers
• Personal information categories listed in the California Customer Records statute
• Protected classification characteristics under California or federal law
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Inferences drawn from other personal information
• Sensitive personal information

• Selling Personal Information 

Pursuant to our Privacy Policy, in the preceding twelve months, Company has sold marketing-related personal information to its partner-retailers as part of its lead generation and management services, including the following categories of personal information:

• Identifiers
• Personal information categories listed in the California Customer Records statute
• Protected classification characteristics under California or federal law
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Inferences drawn from other personal information
• Sensitive personal information

The Company does not sell personal information pertaining to minors under the age of 16.

3.) Your Rights.

• Right to Access and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, selling, or sharing the personal information.
• The categories of third parties with whom we disclose that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• Whether we sold, shared, or otherwise disclosed your personal information for a business purpose.

• Right to Delete 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us to:

• Complete the transaction for which we collected the information. 
• Provide a good or service that you requested.
• Take actions reasonably anticipated, given our ongoing business relationship.
• Fulfill a written warranty or product recall conducted under federal law.
• Perform our contract with you.
• Protect against malicious, deceptive, fraudulent, or illegal activity.
• Debug products to identify and repair errors that impair existing functionality.
• Exercise free speech or ensure that other consumers may exercise their free speech.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed public interest research if deletion may seriously impair the research’s achievement and if you previously provided informed consent.
• Use the information internally, as reasonably expected by consumers.
• Use the information internally, compatible with the law and context you provided it.
• Comply with a legal obligation.

• Right to Correct

You have the right to request that we correct inaccurate personal information, taking into account the nature of the personal information and the purposes for processing the personal information. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information.

• Right to Non-Discrimination

We will not discriminate against you for exercising any of these rights. Unless permitted by California law, we will not:

• Deny you goods or services.
• Provide you a different level or quality of goods or services.
• Charge you different prices or rates for goods or services, including granting discounts or benefits, or imposing penalties.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by California law that can result in different prices, rates, or quality levels. Any permissible financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior affirmative consent, which you may revoke at any time.

• Right to Opt Out of the Sale of Personal Information

To opt out of our sale of your personal information, please follow the instructions provided in the “Exercising Your Rights” section of this document.

• Right to Opt Out of Sharing Personal Information for Personalized Advertising 

To opt out of the sharing of your personal information, please follow the instructions provided in the “Exercising Your Rights” section of this document.

• Right to Limit the Processing of Sensitive Personal Information

To limit the processing of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests our services, please follow the instructions provided in the “Exercising Your Rights” section of this document.

• Rights Under California’s “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents that use our website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

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Colorado

Last Updated: April 1, 2024

This supplements the information contained the Privacy Policy and applies solely to individuals who reside in the State of Colorado. To exercise any of the rights described below consistent with applicable law, please follow the instructions provided in the “Exercising Your Rights” section of this document. 

1.) How We Collect, Use, Disclose, and Sell Information. 

We collect information that is linked or reasonably linkable to an identifiable individual and does not include de-identified data or publicly available information (“personal information“). For more information about the information we collect and how we use, disclose, and sell personal information, please read the Privacy Policy.

2.) Your Rights.

• Right to Access and Data Portability

You have the right to confirm whether Company is processing personal information and to access this personal information. You may obtain the information in a portable and readily usable format, to the extent technically feasible. 

• Right to Correct

You have the right to correct inaccuracies in your personal information, taking into account the nature of, and purposes for, processing the personal information.

• Right to Delete

You have the right to delete your personal information.

• Right to Appeal Consumer Rights Request Responses

You may appeal Company’s refusal to take action on your consumer rights request within a reasonable time after you received Company’s decision. We will endeavor to notify you within 45 days of receipt of your appeal (and we will notify you if Company requires an additional 60 days) what action Company has taken in our written response. You may contact the state Attorney General if you have concerns about the result of the appeal.

• Right to Opt Out 

You have the right to opt out of your information being processed:

• For targeted advertising
• For the sale of personal information, or
• For profiling to make decisions that produce legal or similarly significant effects.

• Right to Consent to the Processing of Sensitive Personal Information

You have a right to consent to the processing of your sensitive personal information, including:

• Personal information revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship status,
• Genetic or biometric data processed for the purpose of uniquely identifying an individual, or 
• Personal information from a known child.

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Connecticut

Last Updated: April 1, 2024

This supplements the information contained the Privacy Policy and applies solely to individuals who reside in the State of Connecticut. To exercise any of the rights described below consistent with applicable law, please follow the instructions provided in the “Exercising Your Rights” section of this document. 

1.) How We Collect, Use, Disclose, and Sell Information. 

We collect information that is linked or reasonably linkable to an identifiable individual and does not include de-identified data or publicly available information (“personal information“). For more information about the information we collect and how we use, disclose, and sell personal information, please read the Privacy Policy.

2.) Your Rights.

• Right to Access and Data Portability

You have the right to confirm whether Company is processing personal information and to access this personal information. You may obtain the information in a portable and readily usable format, to the extent technically feasible. 

• Right to Correct

You have the right to correct inaccuracies in your personal information, taking into account the nature of and purposes for processing the personal information.

• Right to Delete

You have the right to delete your personal information.

• Right to Appeal Consumer Rights Request Responses

You may appeal Company’s refusal to take action on your consumer rights request within a reasonable time after you received Company’s decision. We will endeavor to notify you within 45 days of receipt of your appeal (and we will notify you if Company requires an additional 60 days) what action Company has taken in our written response. You may contact the state Attorney General if you have concerns about the result of the appeal.

• Right to Opt Out 

You have the right to opt out of your personal information being processed:

• For targeted advertising;
• For the sale of personal information; or
• For profiling to make automated decisions that produce legal or similarly significant effects.

• Right to Consent to the Processing of Sensitive Personal Data

You have a right to consent to the processing of your sensitive personal information, including:

• Personal information revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, citizenship or immigration status,
• Genetic or biometric data processed for the purpose of uniquely identifying an individual, 
• Personal information from a known child, or
• Precise geolocation information.

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Montana

Last Updated: April 1, 2024

This supplements the information contained in the Privacy Policy and applies solely to individuals who reside in the State of Montana. To exercise any of the rights described below consistent with applicable law, please follow the instructions provided in the “Exercising Your Rights” section of this document.

1.) How We Collect, Use, Disclose, and Sell Information. 

We collect information that is linked or reasonably linkable to an identifiable individual and does not include de-identified data or publicly available information (“personal information“). For more information about the information we collect and how we use, disclose, and sell personal information, please read the Privacy Policy.

2.) Your Rights.

• Right to Access and Data Portability

You have the right to confirm whether Company is processing personal information and to access this personal information. You may obtain personal information you previously provided Company in a portable and readily usable format, to the extent technically feasible. 

• Right to Correct

You have the right to correct inaccuracies in your personal information, taking into account the nature of and purposes for processing the personal information.

• Right to Delete

You have the right to delete your personal information.

• Right to Appeal Consumer Rights Request Responses

You may appeal Company’s refusal to take action on your consumer rights request within a reasonable time after you received Company’s decision. Within 45 days of receipt of your appeal, we will notify you via a written response about the action Company has taken or not taken. You may contact the state Attorney General if you have concerns about the result of the appeal.

• Right to Opt Out 

You have the right to opt out of your personal information being processed:

• For targeted advertising;
• For the sale of personal information; or
• For profiling to make decisions that produce legal or similarly significant effects.

• Right to Consent to the Processing of Sensitive Personal Data

You have a right to consent to the processing of your sensitive personal information, including:

• Personal information revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, information about a person’s sex life, sexual orientation, citizenship or immigration status,
• Genetic or biometric data processed for the purpose of uniquely identifying an individual, 
• Personal information from a known child, or
• Precise geolocation information.

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Nevada

Last Updated: April 1, 2024

This supplements the information contained the Privacy Policy and applies solely to individuals who reside in the State of Nevada. To exercise any of the rights described below consistent with applicable law, please follow the instructions provided in the “Exercising Your Rights” section of this document. 

1.) How We Collect, Use, Disclose, and Sell Information. 

We collect information about Nevada residents through a website or online service: first and last name; home or physical address; email address; telephone number; social security number; online or physical identifier; or other information that, combined with an identifier, makes the information personally identifiable (“covered information” or “personal information“). For more information about the information we collect and how we use, disclose, and sell personal information, please read the Privacy Policy.

2.) Reviewing and Requesting Changes to Your Information.

You may review and request changes to your personal information collected through Company’s website or online services.

3.) Opting Out of the Sale of Personal Information.

You may submit a verified request that Company not sell your personal information.

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Oregon

Last Updated: April 1, 2024

This supplements the information contained in the Privacy Policy and applies solely to individuals who reside in the State of Oregon. To exercise any of the rights described below consistent with applicable law, please follow the instructions provided in the “Exercising Your Rights” section of this document.

1.) How We Collect, Use, Disclose, and Sell Information. 

We collect information that is linked or reasonably linkable to an identifiable individual and does not include de-identified data or publicly available information (“personal information“). For more information about the information we collect and how we use, disclose, and sell personal information, please read the Privacy Policy.

2.) Your Rights.

• Right to Access and Data Portability

You have the right to confirm whether Company is processing personal information and to access this personal information. You may obtain personal information you previously provided Company in a portable and readily usable format, to the extent technically feasible. 

• Right to Correct

You have the right to correct inaccuracies in your personal information, taking into account the nature of and purposes for processing the personal information.

• Right to Delete

You have the right to delete your personal information.

• Right to Appeal Consumer Rights Request Responses

You may appeal Company’s refusal to take action on your consumer rights request within a reasonable time after you received Company’s decision. Within 45 days of receipt of your appeal, we will notify you via a written response about the action Company has taken or not taken. You may contact the state Attorney General if you have concerns about the result of the appeal.

• Right to Opt Out 

You have the right to opt out of your personal information being processed:

• For targeted advertising;
• For the sale of personal information; or
• For profiling to make decisions that produce legal or similarly significant effects.

• Right to Consent to the Processing of Sensitive Personal Data

You have a right to consent to the processing of your sensitive personal information, including:

• Personal information revealing racial or ethnic background, national origin, religious beliefs, a mental or physical health condition or diagnosis, sexual orientation, status as transgender or nonbinary, status as a victim of a crime, citizenship or immigration status,
• Genetic or biometric data, 
• Personal information from a child, or
• Precise geolocation information.

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Virginia

Last Updated: April 1, 2024

This supplements the information contained in the Privacy Policy and applies solely to individuals who reside in the Commonwealth of Virginia. To exercise any of the rights described below consistent with applicable law, please follow the instructions provided in the “Exercising Your Rights” section of this document.

1.) How We Collect, Use, Disclose, and Sell Information. 

We collect information that is linked or reasonably linkable to an identifiable individual and does not include de-identified data or publicly available information (“personal information“). For more information about the information we collect and how we use, disclose, and sell personal information, please read the Privacy Policy.

2.) Your Rights.

• Right to Access and Data Portability

  You have the right to confirm whether Company is processing personal information and to access this personal information. You may obtain personal information you previously provided Company in a portable and readily usable format, to the extent technically feasible. 

• Right to Correct

  You have the right to correct inaccuracies in your personal information, taking into account the nature of and purposes for processing the personal information.

• Right to Delete 
  

  You have the right to delete your personal information.

• Right to Appeal Consumer Rights Request Responses

  You may appeal Company’s refusal to take action on your consumer rights request within a reasonable time after you received Company’s decision. Within 60 days of receipt of your appeal, we will notify you via a written response about the action Company has taken or not taken. You may contact the state Attorney General if you have concerns about the result of the appeal.

• Right to Opt Out 
  

  You have the right to opt out of your personal information being processed:

  • For targeted advertising;
  • For the sale of personal information; or
  • For profiling to make decisions that produce legal or similarly significant effects.

• Right to Consent to the Processing of Sensitive Personal Data

  You have a right to consent to the processing of your sensitive personal information, including:

  • Personal information revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, citizenship or immigration status,
  • Genetic or biometric data processed for the purpose of uniquely identifying an individual, 
  • Personal information from a known child, or
  • Precise geolocation information.

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Exercising Your Rights

Depending on where you live, the rights described in this supplement may apply to you. To exercise your rights compatible with applicable law, please submit a verifiable consumer request via 212-328-1440 or privacy@shoptelligence.com. 

• Verifiable Consumer Requests

Your verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected information, and describe your request in sufficient detail that allows us to properly respond to it. We cannot respond to your request if we cannot verify your identity and confirm that the information relates to you. 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us via the methods noted above. If you are a California resident, you can designate an authorized agent to make a request on your behalf only if: (1) the authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (2) you sign a written declaration that you authorize the authorized agent to act on your behalf.  If you use an authorized agent under California law to submit a request to exercise your rights, please have the authorized agent take the following steps in addition to the steps described above:

• Mail a copy of your signed written declaration authorizing the authorized agent to act on your behalf; and
• Provide any information we request in our response to your email to verify your identity. The information requested 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 California Probate Code sections 4121 to 4130, 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.

California and Virginia residents may make a verifiable consumer request twice within a 12-month period, free of charge, unless the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Colorado, Connecticut, Montana, and Oregon residents may make a verifiable consumer request, free of charge, once within a 12-month period; subsequent requests from residents in these states may warrant a fee. 

• Response Time

We will respond to verifiable consumer requests within the time allotted under applicable law, generally forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing in compliance with applicable law. 

• Response Content

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 personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance in compliance with applicable law.

• Method of Response

You do not need to create an account with us to make a verifiable consumer request. However, if you have an account with us, we will 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.