BABY+ Privacy Notice

This privacy notice was last updated on May 9 2022

Pregnancy+ and Baby+ provide insights into your pregnancy, well-being

and baby's development, as well as personalized content, messages, tips

and other services ("Services"). This Privacy Notice is meant to help

you understand our privacy practices when you use our Services,

including what data we collect, why we collect it, and what we do with

it, as well as your individual rights.

This Privacy Notice applies to personal data processed by the apps,

which are controlled by Philips Consumer Lifestyle B.V., or any of its

affiliates or subsidiaries ("Philips", "our", "we" or "us").

Unless specified otherwise, all sections of this notice apply to both

apps.

What Information and Personal Data do we collect and for which Purposes?

We receive or collect information and personal data, as described below,

when we provide our Services, including when you access, download,

install the apps. We may use this personal data to perform the Services

based on your consent or as requested by you as a contractual necessity,

to operate, provide, improve, customize, support and market our Services

based on our legitimate interest, or to comply with a legal obligation

to which we may be subject. If you do not want us to collect and process

your personal data, you may not be able to use the Services.

Sensitive Personal Data

Before we collect sensitive personal data, we will inform you and ask

your explicit consent. You may withdraw your consent at any time,

without affecting the lawfulness of processing based on consent before

withdrawing your consent.

This data includes:

Baby+ and Pregnancy+

Due date

Baby's gender

Your gender

Your age

Your photo

Your location

Your relationship to baby

Date baby is born

Your uploaded pictures

Your weekly notes

Your diary entries and memories

Your doctor's visits (personal notes that you may wish to record, such

as pregnancy weight, blood pressure, foetal heart rate, time and date of

appointment, and name and profession of health care provider)

Mother's weight

Pregnancy+

Your favorite baby names

Baby's kicks

Your shopping list

Details of multivitamin and other products that you use, and which

brands you recognize

Your hospital bag list

Your birth plan

Your to-do list

Mother's contraction

Mother's belly pictures

Baby+

Baby's name

Baby's photo

Baby's milestones

Baby's activities

Baby's growth data

Baby's sleep data

Baby's feed data

Baby's tooth data

Baby's nappy data

Baby's medication (personal notes that you may wish to record, such as

dose, name and label)

Baby's vaccines (personal notes that you may wish to record, such as

name and reaction)

Baby's doctor's visits (personal notes that you may wish to record, such

as weight, time and date of appointment, and name and profession of

health care provider)

Mother's breastfeeding data

You can upload this data to the apps. If you create an account and

provide us your explicit consent we will securely store your data. That

way we can ensure you are securely backed up.

Subject to your choices, we use your data to give you insights into your

pregnancy, your well-being and your baby's development, and to provide

you with personalized content, messages and tips. We may do this by

sending you emails, push notifications and in-app messages.

We ask you not to send or disclose any other sensitive personal data

(e.g., social security numbers, information related to racial or ethnic

origin, political opinions, religion or other beliefs, health,

biometrics or genetic characteristics, criminal background or trade

union membership) on or through the app or otherwise to us.

Account Data

We collect your personal data when you create an account. You may login

to the app using a Philips account or by using your social media

profile, including your Apple account.

The personal data we collect may include your username, name, age

(optional), email address, gender (optional), relation to baby (relative

or friend), language, due date, location (city/country level) and

password. We also process information on your app usage, including your

session, login and authentication details, which we use to manage your

account.

If you choose to log in via social media, the personal data we collect

may include your basic public profile (e.g., profile photo, identifier,

gender, profile URL, birthday, homepage, and location) and email for

authentication purposes. In this case, your social media provider may

collect information on the fact that you are using the app and logging

in using your social media account. Please read your social media

provider’s privacy notice (e.g.,

Facebook,

Google,

Apple) to learn about its

privacy practices.

When you login using Facebook, you enable Facebook to process the

following information via the Facebook SDK:

  • Configuration data. After a user has logged in, Facebook makes
  • periodic background requests to manage the lifetime of the access
  • token automatically.
  • Error information. Facebook captures error information, including
  • during initialization of the login, which may include a user ID of
  • individuals who are logged in to Facebook.
  • Short-term data. Facebook measures some user activity for purposes
  • of managing fraud and abuse. This data is only retained for a very
  • short period for those not logged in to Facebook.

You can find out more about how Facebook uses information by reading

their privacy policy. Facebook

may process the information in countries outside of your country of

residence, which may not provide adequate protection to personal data in

line with Regulation (EU) 2016/679.

We use your Account Data to create and manage your account and provide

personalized Services. You can use your account to securely login to the

app. If you create a Philips account to login to the app, we will send

you a welcoming email to verify your username and password, to

communicate with you in response to your inquiries, to send you strictly

service-related announcements, or direct marketing communications in

case you have provided consent. You may also use your Philips account to

order or register a Philips product or service, participate in a

promotion or game, participate in a social media activity related to a

Philips promotion (for example clicking "like" or "share"), and

participate in product testing or surveys.

Cookies & Personalization

We process information from your mobile device and use cookies, tags,

pixels or similar technologies (“Cookies”) to provide our Services. Our

Cookies allow us to recognize your mobile device and collect information

and personal data. The information we process may include your mobile

device data (such as unique identifiers, session and usage data,

operating system, model, carrier, network information and IP addresses)

and app information (such as app name, version, usage and events, pages

visited and session information). Our use of Cookies and the collection

of information is essential to provide our Services.

Pregnancy +

When using the app, you can choose between to 2 different experiences.

  • Silver
  • The app uses Cookies to collect information about how you use the
  • app. This typically includes information about you and/or your
  • pregnancy, such as your due date (week), age (optional); your IP
  • address and location; the areas of the app you engage with and
  • information on the device you use. We use this data to perform app
  • analytics and evaluate your interests and preferences, provide you a
  • personalized app experience at each stage of your pregnancy, show
  • you contextual advertising, and invite you to participate in
  • optional surveys by us or the Philips group of companies. We share
  • your app usage information, such as analytics events and unique
  • identifiers, with our Advertising Partner (Google) who helps us show
  • you content and advertising in the app. Our Advertising Partner uses
  • Cookies and may process your data independently. If you downloaded
  • the App by clicking on a Philips Ad from an external platform, we
  • may share unique identifiers and analytics events with such platform
  • to measure the effectiveness of our Ads as explained in this notice.
  • When an Ad within the app directs you to one of our partner’s
  • websites, we may use Cookies to collect anonymous information on how
  • you interact with the Ad and our partner’s website, and use the
  • insights to measure the effectiveness of our campaigns.
  • Gold
  • In addition to the above, the app uses your advertising ID. This
  • allows us to provide you with a customized journey and/or
  • personalized advertising across multiple channels based on the
  • evaluation of your interests and preferences. Based on your
  • advertising ID, we may show you interest-based advertising regarding
  • Philips products and services in our app or through our partner
  • External Media channels, such as Facebook, Google and Pinterest. Our
  • Advertising Partner (Google) may independently use your advertising
  • ID to further personalize the advertisements shown in the app. You
  • can change your preferences in the settings of the app at any time.

Baby +

The app uses Cookies to collect information about how you use the app.

This typically includes information about you and/or your pregnancy,

such as your due date (week), age (optional); your IP address and

location; the areas of the app you engage with and information on the

device you use. We use this data to perform app analytics and evaluate

your interests and preferences, provide you a personalized app

experience at each stage of your pregnancy, show you contextual

advertising, and invite you to participate in optional surveys by us or

the Philips group of companies. We share your app usage information,

such as analytics events and unique identifiers, with our Advertising

Partner (Google) who helps us show you content and advertising in the

app. Our Advertising Partner uses Cookies and may process your data

independently. If you downloaded the App by clicking on a Philips Ad

from an external platform, we may share unique identifiers and analytics

events with such platform to measure the effectiveness of our Ads as

explained in this notice. When an Ad within the app directs you to one

of our partner’s websites, we may use Cookies to collect anonymous

information on how you interact with the Ad and our partner’s website,

and use the insights to measure the effectiveness of our campaigns.

Marketing Data

If you opt-in to receive promotional communications about Philips

products, services, events and promotions that may be relevant to you

based on your preferences and online behavior, we may send you marketing

and promotional communications via email, phone and other digital

channels, such as mobile apps and social media. To be able to tailor the

communications to your preferences and behavior and provide you with a

more relevant and personalized experience, we may analyze and combine

your personal data. You may opt-out and unsubscribe from such

communications at any time.

Survey Data

When you participate in a survey, we collect your personal data. The

personal data we collect includes your responses, which may relate to

your opinion and experience when interacting with our Services or third

party services, as well as information about your pregnancy or about any

other mother and child care topics.

We process your survey data in combination with the analytics

information we collect when you use the apps. We use this data to gain

an understanding of our users, and use these insights to improve our

apps and services in the Philips mother & childcare domain. To do so, we

analyze and aggregate your information and answers.

Sometimes we run surveys in collaboration with selected partners. We

only share aggregated results and insights with our partners. For

instance, "50% of our users have a baby monitor". For clarity, no

personal data is shared with our partners.

We use Survey Monkey to run our surveys. Survey Monkey processes your

personal data on behalf of Philips in accordance with this notice.

Customer Support Data

You may provide us with information related to your use of our Services,

including your interaction with Philips, and how to contact you so we

can provide you customer support. We operate and provide our Services,

including providing customer support, and improving, fixing and

customizing our Services. We also use your information to respond to you

when you contact us.

Combined Data

We may combine your personal data, including account data, other data

provided by you, Device data, cookies, location data, data collected

during your interactions and usage of the Philips digital channels, such

as social media, websites, emails, apps and connected products, IP

address, cookies, device information, communications you click on or

tap, location details and websites you visit.

Subject to your choices, we may analyze your combined data to provide

you with the Services, such as to give you insights into your pregnancy,

your well-being and your baby's development, and deliver personalized

content, messages and tips in accordance with this notice. We may also

use this data to improve the content, functionality and usability of the

apps and Services, as well as to develop new products and services in

the mother & childcare domain.

Ratings and Reviews Data

If you write a review or rate the apps on the app stores, we may process

such information to respond to your comments and questions, understand

how you feel when using the apps, get familiar with your general

perception of the apps and our brand, and use these insights to improve

the apps. We can only see your app store username, ratings, comments and

any other detail you decide to share with us or make publicly available.

Unless you require us to do so, we do not link this information to your

account credentials or any other information we hold from you. When you

require customer support, we may use your data to follow-up on your case

and guide you through our customer support process in accordance with

this notice.

Permissions

The apps may request your permission to access your phone or sensors

(e.g. camera, Wi-Fi) or other data (e.g. photos, agenda or contacts) on

your mobile device. We use such data only when needed to provide you the

Services and only after you have provided consent.

  • Wifi. The apps require WIFI connection to connect to the internet.
  • You can at any time block WIFI connection through the settings of
  • your mobile device.
  • Camera or Photo Gallery (optional). If you add a picture to your
  • profile, the apps require permission to access your mobile device's
  • camera or photo gallery.
  • Calendar (optional). The apps allow you to copy your appointments to
  • your mobile device calendar.
  • Apple Health (optional). If you are using iOS, you can authorize the
  • app to read data from Apple’s Health App as well as to write data to
  • Apple’s Health App. Subject to your choices, you may share
  • information such as your weight. Philips’ cloud solutions do not
  • sync with Apple. This means that the exchange of data only happens
  • locally in your mobile device.

Sharing your personal data with others

Philips may disclose your personal data to third party service

providers, business partners, or other third parties in accordance with

this Privacy Notice and/or applicable law.

Affiliates and Service providers

We may share your data with other Philips entities that are part of the

Philips Group. For instance, some Philips entities may help us manage

the app infrastructure or manage your inquiries. Only people that

strictly require access to fulfil their jobs will process your data. We

also work with third-party service providers that help us operate,

provide, improve, understand, customize, support and market our apps.

We may share your personal data with the following service providers:

  • IT, survey and cloud providers. These service providers deliver
  • the necessary hardware, software, networking, storage, transactional
  • services and/or related technology required to run the apps and/or
  • provide the Services.
  • Analytics providers. These service providers deliver the necessary
  • hardware, software, networking, storage, transactional services
  • and/or related technology required to perform analytics and provide
  • the Services.
  • Google Firebase and/or Google Analytics. We use Google
  • services to obtain analytics reports and usage analyses on how
  • you interact with our services, understand how you use our app
  • and how the app runs on your mobile device, how the app performs
  • and when it crashes so that we can fix any issues, and try out
  • app changes or features so that we can understand how you
  • interact with them. We will also use the information generated
  • by the app to compile reports on app activity.
  • Branch Metrics. We use Branch Metrics to deep-link users into
  • the app, analyze how users access and use the app and use these
  • insights to improve the app. If you downloaded the app by
  • clicking on a Philips Ad on one of our marketing partners’
  • platforms, such as Facebook, Apple or Google, and decide to
  • provide consent, Branch will collect Ad measurement data from
  • your mobile device, including unique identifiers and analytics
  • data on the Ad that you click on and other app events (such as
  • first install, open and app sharing via the app’s sharing
  • feature). To understand the effectiveness of our advertising
  • campaigns and measure engagement, we share your Ad measurement
  • data with the platform we used to run the Ad, which will then
  • use the data to report on the effectiveness of our Ads. By
  • consenting to the use of Branch, you agree to the sharing of
  • your Ad measurement data with the platform you used when
  • clicking on our Ad, such as
  • Facebook,
  • Apple or
  • Google, as it may be the
  • case, which will process your data pursuant to its privacy
  • notice, and in countries outside of your country of residence
  • which may not provide adequate protection to personal data in
  • line with Regulation (EU) 2016/679.

Philips requires its service providers to provide an adequate level of

protection to your personal data similar to the level that we provide.

We require our service providers to process your personal data only in

accordance with our instructions and only for the specific purposes

mentioned above, to have access to the minimum amount of data they need

to deliver a specific service, and to protect the security of your

personal data.

Other third parties

Philips may also work with third parties who process your information or

personal data for their own purposes. Please read their privacy notices

carefully as they inform about their privacy practices, including what

type of personal data they collect, how they use, process and protect

them.

If Philips shares information or personal data with a third party that

uses your personal data for its own purposes, Philips will ensure to

inform you and/or obtain your consent in accordance with applicable laws

before we share your personal data.

Subject to your choices, we may share your information and/or personal

data with the following third parties:

  • External Media Channels, including Facebook, Instagram and Pinterest, for advertising purposes. We share your mobile device’s
  • advertising ID with our partner External Media Channels to show you
  • advertising in their respective environments in accordance with this
  • notice.
  • External Platforms, including Facebook, Apple and Google, for Ad measurement and Ad attribution purposes. We share unique
  • identifiers and analytics events with these third parties via Branch
  • Metrics to understand the effectiveness or our Ads in accordance
  • with this notice.
  • Advertising partners, for serving content and advertising in the apps.
  • Pregnancy+. We use Google’s ad serving solutions to serve Ads
  • through the apps. Google may combine information collected via
  • the apps, with other information it has independently collected
  • from other services or products. Analytics events and unique
  • identifiers, such as the device advertising ID (only for Gold
  • experience), are sent to Google in order to make advertisement
  • and content more personalized and as relevant as possible. You
  • may receive advertising about products and services not related
  • to Philips or the mother & childcare domain. Google uses Cookies
  • on your mobile device when providing its services. Google’s
  • Terms and Privacy Policy for these services are available
  • here:
  • https://policies.google.com/technologies/partner-sites?hl=en
  • https://policies.google.com/privacy?hl=en
  • Pregnancy + and Baby +. We use Google’s services to serve
  • programmatic advertisement and content to users in the apps.
  • Information about how the apps are set up, such as trimester and
  • relation, along with analytics events and unique identifiers,
  • such as the device advertising ID (only for Gold experience in
  • the case of Pregnancy+), is sent to Google in order to make
  • advertisement and content more personalized and as relevant as
  • possible. You will receive content and advertising about mother
  • & childcare products and services. Google uses Cookies on your
  • mobile device when providing its services. Additionally, Google
  • also uses IP targeting to ensure that all advertisement is
  • localized appropriately. Google’s Terms and Privacy Policy for
  • these services are available here:
  • https://www.google.com/doubleclick/publishers/small-business/terms.html
  • https://policies.google.com/technologies/partner-sites?hl=en
  • https://policies.google.com/privacy?hl=en
  • Business partners, for allowing you to subscribe to our partners’ marketing offers. We’ve teamed up with some wonderful partners and
  • we may offer you the opportunity to opt into their marketing
  • campaigns. By selecting one or multiple partners and tapping
  • 'Sign-up!' you are authorizing and instructing Philips to share your
  • contact details (email, first name, last name), due date, mobile
  • device information (country, locale and operating system) and
  • authorization (consent text and date) with the selected partners to
  • receive personalized offers from them in accordance with your
  • choices.

The app may contain links to other sites or services of interest. Once

you have used these links to leave the app, we do not have any control

over those third-party sites or services. The information that you

provide whilst visiting such sites is governed by their respective

Privacy Notices.

When required by law, or as necessary to protect our rights, we may

share your data with public and governmental authorities. 

Cross-border transfer

Your personal data may be stored and processed in any country where we

have facilities or in which we engage service providers. By using the

Services you acknowledge the transfer (if any) of information to

countries outside of your country of residence, which may have data

protection rules that are different from those of your country. In

certain circumstances, courts, law enforcement agencies, regulatory

agencies or security authorities in those other countries may be

entitled to access your personal data.

If you are located in the EEA, your personal data may be transferred to

our affiliates or service providers in non-EEA countries that are

recognized by the European Commission as providing an adequate level of

data protection according to EEA standards (the full list of these

countries is

available here).

For transfers from the EEA to countries not considered adequate by the

European Commission, such as the United States, we have put in place

adequate measures, such as our Binding Corporate Rules for Customer, Supplier and Business Partner Data and/or

standard contractual clauses adopted by the European Commission to

protect your personal data. You may obtain a copy of these measures by

following the link above or by contacting

us here.

How long do we keep your data?

We will retain your personal data for as long as needed or permitted in

light of the purpose(s) for which the data is collected. The criteria we

use to determine our retention periods include: (i) the length of time

you use the app and Services; (ii) whether there is a legal obligation

to which we are subject; or (iii) whether retention is advisable in

light of our legal position (such as in regard to applicable statutes of

limitations, litigation or regulatory investigations). In any case, we

will retain your Account Data for as long as you have and use your

account. We keep the Data you provide to us until you revoke your in-app

consents. After 3 years of inactivity and not using the app, we will ask

you if you still want us to retain your personal data. We will provide

you with a 3-month window for you to re-consent for us to continue

retaining your personal data. Ultimately, without receiving your consent

after our contact attempts, we will delete your personal data after 3

years and 3 months.

Your Choices and Rights

If you would like to submit a request to access, rectify, erase,

restrict or object to the processing of personal data that you have

previously provided to us, or if you would like to submit a request to

receive an electronic copy of your personal data for purposes of

transmitting it to another company (to the extent this right to data

portability is provided to you by applicable law), you may contact

us here.

We will respond to your request consistent with applicable law.

In your request, please make clear what personal data you would like to

access, rectify, erase, restrict or object to its processing. For your

protection, we may only implement requests with respect to the personal

data associated with your account, your email address or other account

information, that you use to send us your request, and we may need to

verify your identity before implementing your request. We will try to

comply with your request as soon as reasonably practicable.

Where we process your data to provide our services based on our terms,

we may not be able to provide the services if we do not receive your

data. Where we rely on our legitimate interests, we ensure that the

processing does not outweigh your privacy rights and interests. Where we

rely on consent, you may withdraw it at any time, without affecting the

lawfulness of processing before your withdrawal.

We Protect Your Personal Data

We take seriously our duty to protect the data you entrust to Philips

against accidental or unauthorized alteration, loss, misuse, disclosure

or access. Philips uses a variety of security technologies, technical

and organizational measures to help protect your data. For this purpose,

we implement, among others, access controls, use firewalls and secure

protocols.

Special Information for Parents

While the Services are not directed to children, as defined under

applicable law, it is Philips policy to comply with the law when it

requires parent or guardian permission before collecting, using or

disclosing personal data of children. We are committed to protecting the

privacy needs of children and we strongly encourage parents and

guardians to take an active role in their children’s online activities

and interests.

If a parent or guardian becomes aware that his or her child has provided

us with his or her personal data without their consent, please contact

us

here.

If we become aware that a child has provided us with personal data, we

will delete his/her data from our files.

Changes to this Privacy Notice

Our Services may change from time to time without prior notice to you.

For this reason, we reserve the right to amend or update this Privacy

Notice from time to time. When we update this Privacy Notice, we will

also update the date at the top of this Privacy Notice. We encourage you

to review regularly the latest version of this Privacy Notice.

The new Privacy Notice will become effective immediately upon

publication. If you do not agree to the revised notice, you should alter

your preferences, or consider stop using our Services. By continuing to

access or make use of our Services after those changes become effective,

you acknowledge that you have been informed about the updates to the

Privacy Notice.

Contact Us

If you have any question about this Privacy Notice or about the way in

which Philips uses your personal data, you may contact us (including our

Data Protection Officer and/or

Representative) here.

Alternatively, you have the right to lodge a complaint with a

supervisory authority competent for your country or region

Philips Consumer Lifestyle B.V.

High Tech Campus 5, 5656 AE,

Eindhoven, The Netherlands

Additional information for California Residents

California Civil Code Section 1798.83 permits our customers who are

California residents to request and obtain from us once a year, free of

charge, information about the personal information (if any) we disclosed

to third parties for direct marketing purposes in the preceding calendar

year. If applicable, this information would include a list of the

categories of personal information that was shared and the names and

addresses of all third parties with which we shared information in the

immediately preceding calendar year. If you are a California resident

and like to make such a request, please visit our privacy

website: https://www.philips.com/a-w/privacy/questions-and-feedback.html.

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information that we collect and process about California residents via the app.  For details on how we handle Personal Information pursuant to the CCPA in other contexts, please go here. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

Sources of Personal Information

We collect Personal Information from:

  • Our interactions with you through the apps; and
  • Our affiliates.

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.

Categories of Personal Information Disclosed to Which Categories of Third Parties for Operational Business Purposes Identifiers, such as name, contact information, IP address and other online identifiers. Our affiliates and subsidiaries; trusted third-party service providers; business partners; third-party sponsors of sweepstakes, contests and similar promotions; your social media account providers, in connection with the social sharing you choose to use in accordance with this Privacy Notice. Personal information as defined in the California customer records law, such as name and contact information. Our affiliates and subsidiaries; trusted third-party service providers, and business partners in accordance with this Privacy Notice. Characteristics of protected classifications under California or federal law, such as age and primary language Our affiliates and subsidiaries; trusted third-party service providers, and business partners in accordance with this Privacy Notice. Internet or network activity information, such as browsing history and interactions with our online services Our affiliates and subsidiaries; trusted third-party service providers, and business partners in accordance with this Privacy Notice. Geolocation data, such as device location. Our affiliates and subsidiaries; trusted third-party service providers, and business partners, in accordance with this Privacy Notice. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, behaviour and characteristics Our affiliates and subsidiaries; trusted third-party service providers, in accordance with this Privacy Notice. Use of Personal Information

We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, as described above under “What Personal Data are collected and for which purposes?”

We do not sell and have not sold Personal Information in the preceding 12 months, as “sale” is defined in the CCPA. We do not sell the Personal Information of minors under 16 years of age.

Individual Rights and Requests

If you are a California resident, you may request that we:

  • Disclose to you the following information covering the 12 months preceding your request:
  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
  • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
  • Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us at: https://www.philips.com/a-w/privacy/questions-and-feedback.html or (866) 309-3263.  We will verify and respond to your request as described above in “Your Choices and Rights” and consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address, mailing address, or telephone number in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable:

  • Proof of your registration with the California Secretary of State to conduct business in California;
  • A power of attorney from the California resident pursuant to Probate Code sections 4000-4465;
  • Written permission that the California resident has authorized you to make a request on the resident’s behalf.  This permission must be signed (via physical or e-signature) by the California resident.

If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4000-4465, we may also require the resident to:

  • Provide you with a written permission signed by the resident to make the request on the resident’s behalf;
  • Verify the resident’s own identity directly with us;
  • Directly confirm with us that the resident provided you permission to submit the request.