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Privacy Policy Continued

Individual States

This section contains additional information relevant to residents of certain US states that have their own data privacy laws and regulations, and associated rights.

California Residents

This notice to California residents is provided under California law. It provides our “Notice at Collection,” provides certain mandated disclosures about our treatment of California residents’ information, both online and offline, explains your privacy rights, and provides our “Notice of Financial Incentives.”

Notice at Collection

We may collect the following categories of personal information (as defined in the California Consumer Privacy Act (CCPA) and the California Customer Records statute), including sensitive personal information (as defined in the CCPA):

  • Identifiers, such as name, email address, username and password, postal address, telephone number, signature, government-issued identifier, IP address, and other similar identifiers.
  • Characteristics of protected classifications and demographic information, such as gender, age, race, disability status, sexual orientation, gender identity, military/veteran status, marital status, national origin, and medical information.
  • Commercial information, including information about your interests and consuming history or tendencies, such as products or services considered; transaction information when you request information, contact customer service, or purchase, return, request or exchange a product or service, including payment card information or other financial information; information provided in response to surveys or other research conducted on our behalf; and information you provide in public forums.
  • Internet or other electronic network activity information, including information regarding your interactions with us online and information we obtain from third parties about use of our applications on third-party platforms or devices.
  • Geolocation data, including precise or approximate location information provided by a mobile device or other device or product interacting with or detected by our sites, applications, or physical properties, where we are permitted by law to process this information.
  • Audio, electronic, visual, or similar information, including telephone call recordings, other voice recordings, and still or video images captured by cameras or readers on or around our physical properties.
  • Inferences based on the above.

We collect this information so that we can best serve you, including to fulfill your requests and to share offers or information that we think you may be interested in. As further described in the How Do We Use Your Information section in our Policy, we generally collect and use the above-listed categories of personal information to provide and manage our sites, applications, products, and services, and for other business or commercial purposes, such as advertising, marketing, and to improve our products and services.

Certain data collection on our sites and applications by third parties for purposes of interest-based advertising and social media tools may be a “sale” or “sharing” under California privacy law. As defined by California law, we “sold” or “shared” certain data elements within the following categories of personal information: identifiers, demographic information, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above.

If you would like to opt out of the sharing of your personal information, you may edit your settings in the banner that appears on the bottom of the page when you first load the Site. Please note that your opt-out choice is specific to the digital property and to the device and browser you are using.

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in our Policy, including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

More information, including a description of your legal rights, can be found in the “California Privacy Rights” section below.

Additional Privacy Mandatory Disclosures

We also make the following disclosures for purposes of compliance with California privacy law:

  • We collected the following categories of personal information in the last 12 months: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
  • The sources of personal information from whom we collected are: directly from our guests, third-party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and third-party services that update or supplement information we hold about you.
  • The business or commercial purposes of collecting personal information are as summarized in our Notice at Collection section, and as described in more detail in our Policy under the How We Use Your Information section.
  • We disclosed certain data elements within the following categories of personal information for a business purpose in the last 12 months: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to business partners, service providers, government entities, and other third parties as described in the Sharing Information With Third Parties section of the Policy.
  • As defined by applicable law, we “sold” or “shared” certain data elements within the following categories of personal information in the last 12 months: identifiers, demographic information, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above. We “sold” or “shared” each category to or with entities who provide advertising, marketing, or audience measurement; other online third-party branded tools or functionality (such as maps or video players); and social networks.
  • The business or commercial purposes of “selling” or “sharing” personal information is to assist us with advertising, marketing, audience measurement, and other functionality on our digital properties.
  • We do not “sell” or “share” the personal information of known minors under 16 years of age.
  • We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations.
Your California Privacy Rights
  • Right to Know - You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.
  • Right to Access - You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.
  • Right to Delete - You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
  • Right to Correct - You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
  • Right to Opt Out of Sale or Sharing of Personal Information - You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law).
  • Removal of Content - If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted.
  • Shine the Light - California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Sim Theory to third parties for the third parties’ direct marketing purposes. Sim Theory does not share guests’ personal information with other member companies or others outside Sim Theory for those parties’ direct marketing use unless a guest elects that we do so.
  • Right Not to Receive Discriminatory Treatment - You have the right not to receive discriminatory treatment for the exercise of your privacy rights. If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those differences are reasonably related to your information. For example, if you exercise your right to opt out of “sale” or “sharing” of your ”personal information,” the ads you view may not be tailored to your interests.
Exercising Your California Privacy Rights
  • Making Requests to Know, Access, Delete, or Correct Your Personal Information -
    To make a request to know or to make an access, deletion, or correction request, please contact privacy@simtheoryinc.com.  To submit a request by phone, you may call (866) 712-1180. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
  • Making Requests to Opt Out of the Sale or Sharing of Personal Information -
    To submit a request to “opt out” of the “sale” or “sharing” of your “personal information,” you may email privacy@simtheoryinc.com.
  • Instructions for Using an Authorized Agent to Make Requests -
    You may use an authorized agent to submit a request to know or an access, deletion, correction, or opt-out request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests at privacy@simtheoryinc.com.
  • Making Requests for Removal of Content -
    California residents under the age of 18 may make requests to remove content by sending an email with a detailed description of the specific content or information to be removed to privacy@simtheoryinc.com.   Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
  • Making Shine the Light Request -
    To make a request for information under the Shine the Light Act, please send an email to privacy@simtheoryinc.com.
Notice of Financial Incentives

Members of Sim Theory may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see the The Information We Collect section in our Policy. Because we collect personal information, the Programs may be considered to be “financial incentives” or “price or service differences” under California law.

To the extent the Programs are reasonably related to the value of guest personal information, the method for calculating this value would include the expenses related to our offer (such as the costs of providing discounts, free shipping, or other promotions, intellectual property or marketing costs, and other related expenses). The value of the guest personal information that we collect will vary depending on the engagement by each guest.

Contact Information

If you have a question about our privacy policies and information practices, please send an email to privacy@simtheoryinc.com.

Colorado Residents

Colorado law provides Colorado residents with the rights listed below.

  • Right to Access - You have the right to know and see what personal data we have collected about you in a usable format.
  • Right to Delete - You have the right to request that we delete the personal data we have collected about you, subject to applicable legal exceptions.
  • Right to Correct - You have the right to request that we correct inaccurate personal data.
  • Right to Opt Out of Targeted Advertising and Sale of Personal Data - You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data” (as defined under Colorado law).
Exercising Your Colorado Privacy Rights
  • Making Access, Deletion, and Correction Requests - To make an access, deletion, or correction request, please email privacy@simtheoryinc.com. To submit a request by phone, you may call (866) 712-1180. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
  • Making Requests to Opt Out of Targeted Advertising or the Sale of Personal Data - To submit a request to “opt out” of “targeted advertising” or the “sale” of your “personal data,” you may choose your preferences in the banner that appears on the bottom of the Site when the page first loads.
  • Instructions for Using an Authorized Agent to Make Requests - You may use an authorized agent to submit an access, deletion, correction, or opt-out request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests at privacy@simtheoryinc.com.

If you have a question about our privacy policies, please send an email to privacy@simtheoryinc.com.

Notice About Our Loyalty Programs

Members of Sim Theory may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see  the The Information We Collect section in our Policy. Because we collect personal information, the Programs may be considered to be “financial incentives” or “price or service differences” under Colorado law.

To the extent the Programs are reasonably related to the value of guest personal information, the method for calculating this value would include the expenses related to our offer (such as the costs of providing discounts, free shipping, or other promotions, intellectual property or marketing costs, and other related expenses). The value of the guest personal information that we collect will vary depending on the engagement by each guest.

Contact Information

To appeal our decision regarding a request related to these rights, you may email us at privacy@simtheoryinc.com.

Connecticut Residents

Connecticut law provides Connecticut residents with the rights listed below.

  • Right to Access - You have the right to know and see what personal data we have collected about you in a usable format.
  • Right to Delete - You have the right to request that we delete the personal data we have collected about you, subject to applicable legal exceptions.
  • Right to Correct - You have the right to request that we correct inaccurate personal data.
  • Right to Opt Out of Targeted Advertising and Sale of Personal Data - You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data” (as defined under Connecticut law).
Exercising Your Connecticut Privacy Rights
  • Making Access, Deletion, and Correction Requests - To make an access, deletion, or correction request, please email privacy@simtheoryinc.com. To submit a request by phone, you may call (866) 712-1180. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
  • Making Requests to Opt Out of Targeted Advertising or the Sale of Personal Data - To submit a request to “opt out” of “targeted advertising” or the “sale” of your “personal data,” you may do so in the banner that appears at the bottom of the Site when it is first loaded.
  • Instructions for Using an Authorized Agent to Make Requests - You may use an authorized agent to submit a request to opt out of targeted advertising or the sale of personal data. Authorized agents may submit such requests at privacy@simtheoryinc.com. Authorized agents can make a request on your behalf if we are provided with verification of your identity and confirmation that you provided the agent authority to act on your behalf.

To appeal our decision regarding a request related to these rights, you may email us at privacy@simtheoryinc.com.

Nevada Residents

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to privacy@simtheoryinc.com.

Utah Residents

Utah law provides Utah residents with the rights listed below.

  • Right to Access - You have the right to know and see what personal data we have collected about you in a usable format.
  • Right to Delete - You have the right to request that we delete the personal data we have collected about you, subject to applicable legal exceptions.
  • Right to Opt Out of Targeted Advertising - You have the right to “opt out” of “targeted advertising” (as defined under Utah law). We do not “sell” personal data as defined under Utah law.
Exercising Your Utah Privacy Rights
  • Making Access and Deletion Requests - To make an access or deletion request, please email privacy@simtheoryinc.com.  To submit a request by phone, you may call (866) 712-1180. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
  • Making Requests to Opt Out of Targeted Advertising - To submit a request to “opt out” of “targeted advertising” you may do so in the banner that appears at the bottom of the Site when it is first loaded.

Virginia Residents

Virginia law provides Virginia residents with the rights listed below.

  • Right to Access - You have the right to know and see what personal data we have collected about you in a usable format.
  • Right to Delete - You have the right to request that we delete the personal data we have collected about you, subject to applicable legal exceptions.
  • Right to Correct - You have the right to request that we correct inaccurate personal data.
  • Right to Opt Out of Targeted Advertising - You have the right to “opt out” of “targeted advertising” (as defined under Virginia law). We do not “sell” personal data as defined under Virginia law.
Exercising Your Virginia Privacy Rights
  • Making Access, Deletion, and Correction Requests - To make an access, deletion, or correction request, please visit privacy@simtheoryinc.com. To submit a request by phone, you may call (866) 712-1180. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
  • Making Requests to Opt Out of Targeted Advertising - To submit a request to “opt out” of “targeted advertising” you may do so in the banner that appears at the bottom of the Site when it is first loaded.

To appeal our decision regarding a request related to these rights, you may email us at privacy@simtheoryinc.com.

Your Choices

To opt out of our email marketing or to unsubscribe from our email newsletters, you can contact privacy@simtheoryinc.com, or you can use the link provided at the bottom of each marketing message or newsletter. If you choose to opt out, you will continue to receive all email communications related to our transactions with you.

If you would like to update your mailing information or want your name and address removed from our direct mailing list, you can contact privacy@simtheoryinc.com.

You can control the tools on your mobile devices. For example, you can turn on and off the GPS locator or push notifications on your phone. Please consult your mobile device’s user guide for instructions on clearing cookies, enabling and disabling location services, and disabling push notifications.

When you make a purchase, you can choose to save your information to obtain a faster checkout for purchases and/or you can choose to receive emails or texts, which provide you with information regarding our other products and services. We obtain your consent before contacting you with certain non-emergency, automated, autodialed, prerecorded, or other telemarketing phone calls or text messages. You are not required to grant consent to telemarketing calls or texts as a condition of buying any goods or services. Also, you may revoke your consent at any time at the contact information listed at the end of this policy. Message and data rates may apply. We will retain your personal information for the period necessarily to fulfill the purposes of your personal information collection, unless a longer retention period is required or permitted by law. 

Children's Privacy

We understand the importance of protecting children’s privacy, especially in an online environment. Our Sites are not intentionally designed for or directed at children less than 13 years of age. We do not knowingly collect personal information from children under the age of 13 without the consent of the child’s parent or guardian. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any personal information relating to children that we have collected, we will take steps to securely remove it from our systems.

Updating Your Information

You may request to view, update, or correct your personal information by contacting our privacy office at privacy@simtheoryinc.com. In order to protect your privacy, we will take steps to verify your identity before granting you access to the information or enabling you to make corrections.

Security

We endeavor to safeguard and protect your personal information. When you make personal information available to us, your personal information is protected both online and offline (to the extent that we maintain any personal information offline). Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of your personal information is restricted in our offices, as well as the offices of our third party service providers. Only employees or third party agents who need personal information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse, and alteration of personal information under our control.

In order to protect the payment information you provide to us, including your credit card number, expiration date, security code, and billing address, we use 2048-bit Secure Sockets Layer (SSL) technology. SSL technology encrypts your information so that it cannot be recognized or decoded in cyberspace. Your computer will begin operating in secure mode once you enter our checkout page. You can confirm that SSL is active by looking in the address bar of your browser, where you will see either a closed lock or an unbroken key (depending on your browser type). Additionally, the URL line of your browser will change from "http" to "https" when the SSL technology is operating.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols, or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors, and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases, or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through our Sites or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit https://www.allaboutdnt.com, but we are not responsible for the completeness or accuracy of this third-party information. 

Tracking Across Time and Technologies Disclosure

Some information about your use of the service and certain third-party services may be collected by us or by third parties using tracking technologies across time and services and used by us and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the service and certain third-party services.

Consumers with Disabilities

We are committed to ensuring this Policy is accessible to individuals with disabilities. To request this Policy in an alternative format, please reach out to us at privacy@simtheoryinc.com.

Contact

If you have questions or wish to contact us about this Policy, please direct inquiries to:

Privacy Officer
Simulation Theory, Inc.

Phone: 1-866-712-1180
Email: privacy@simtheoryinc.com

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