Privacy Policy

Last updated: May 23, 2024

Your privacy is very important to us and we take your privacy very seriously. This Privacy Policy describes how Cool Cats Group LLC (“Company”, “we”, “us”, or “our”) collects and uses the personal information you provide to us on our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, and through the use of our services, (collectively the “Site”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States, the United Kingdom General Data Protection Regulation, and the General Data Protection Regulation which applies across the European Union, and we are responsible as “controller” of that personal information for the purposes of those laws.

By creating an account, providing information to us (by any means, whether in correspondence, via our Site, or otherwise), or continuing to use our services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR PRACTICES, YOU MAY NOT USE OUR SITE. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME AND YOUR CONTINUED USE OF OUR SITE CONSTITUTES YOUR ACCEPTANCE OF THOSE CHANGES. WE ENCOURAGE YOU TO REVIEW THIS PRIVACY POLICY PERIODICALLY.

Children and our Site.

Our Site is not directed to children, and you may not use our Site if you are under the age of 13. If you are under 13, do not use our services, access the Site, or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under 13, please see our “How to Contact Us” Section below. Please visit the FTC’s website at www.ftc.gov for tips on protecting children’s privacy online.

Personal Information We Collect About You.

We may collect and use the following information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):

Categories of Personal Information	Specific Types of Personal Information Collected
A. Identifiers	Email address, user name, IP address
B. Customer records information	Credit or debit card number or other financial information you may provide in connection with merchandise purchased through the Site
C. Characteristics of protected classifications under state or federal law	None
D. Commercial information	Purchase history of merchandise offered through the Site
E. Biometric information	None
F. Internet or other electronic network activity information	IP address, Ethereum address, social media user name (if provided)
G. Geolocation data	None
H. Sensory data	None
I. Professional or employment-related information	None
J. Education information, as defined in the Family Educational Rights and Privacy Act (FERPA)	None
K. Inferences drawn from collected personal information	None
M. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	None

This personal information is required to provide the Site to you. If you do not provide personal information we ask for, it may delay or prevent us from providing the Site to you.

Cookies and Other Tracking Technologies.

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.

There are a number of different types of cookies, however, our Site may use:

Essential – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.
Performance and Functionality – These cookies are used to enhance the performance and functionality of our Site. For example, we may use these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and your geographic location. These cookies are nonessential to the use of our Site, however, without these cookies, certain functionality may become unavailable.
- Analytics and Customization –Our Company uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Site. For example, we use Google Analytics on the Site to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here.
- Social Media – If you opt in to these cookies, these are cookies will be used to connect our Site to a third-party social media platform. For example, these cookies enable you to share our Site’s content through third-party social networks and other websites. They remember your details after you sign in to a social media account from a website. These cookies may also be used for advertising purposes.
- Unclassified – These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

Web Beacons

Our Site contains electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. We use a third party to gather information about how you and others use our Site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Site is used.

How to Manage Cookies.

You have the right to decide whether to accept or reject certain cookies. You can set your browser not to accept cookies, and the above websites tells you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.

Do Not Track.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Promotional Communications.

We may use your personal information to send you updates (by email, text message, telephone or post) about our Site, products or services, including exclusive offers, promotions or new products or services.

We have a legitimate interest in processing your personal information for promotional purposes (see below “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us by using one of the methods listed in the “How to Contact Us” Section below; or
Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

How Your Personal Information is Collected.

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our Site. However, we may also collect information:

Directly from a third party (e.g., Stiftung Ethereum, a Swiss Stiftung, in connection with an Ethereum wallet when you mint or purchase a Company NFT);
From cookies on our Site; and
Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

How and Why We Use Your Personal Information.

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide our Site, products and services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud or other criminal activities against you or Company	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Processing necessary to comply with professional, legal and regulatory obligations that apply to our business, including to respond to requests from public and government authorities, including public and government authorities outside your country of residence	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. our Site Terms and Conditions	For our legitimate interests or those of a third party, i.e. to make sure you are following our Terms and Conditions to access and use our Site
Operational reasons, such as diagnosing or fixing technical issues, improving efficiency, training and quality control, and ensuring the security of our IT systems, architecture and networks	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price and to prevent and detect criminal activity that could be damaging for us and for you
Statistical analysis to help us manage our business and to improve your experience and our service offerings, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Marketing our services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

We may also anonymize, aggregate or de-identify personal information in compliance with applicable law including taking reasonable measures to ensure the end-product does not identify you or any other individual. We will commit to use this information in its deidentified form and not attempt to reidentify the information, unless permitted by applicable law, and we will contractually obligate any recipients of the information to comply with these obligations and applicable law. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.

Who We Share Your Personal Information With.

We routinely share personal information with:

Our affiliates;
Service providers we use to help deliver our Site, products, and services to you, such as payment service providers, warehouses, delivery companies, and website hosts;
Other third parties we use to help us run our business, such as marketing agencies, data analytic service providers, IT and cybersecurity tools and developers;
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may disclose personal information where required to do so any law or subpoena or if we reasonably believe that such action is necessary to enforce our terms of use or to protect the security, quality or integrity of our Services; or to exercise or protect the rights, property, or personal safety of Company, our users, or others.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing products or services to you.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy or to comply with applicable laws. Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

Keeping Your Personal Information Secure.

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction.

However, while we strive to protect your privacy, due to many reasons, including the inherent security flaws in the internet, we cannot guarantee the security of any information you disclose to us and, as such, you agree that your disclosure of such information is at your own risk.

Where Your Personal Information is Held.

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the country where we originally collected your personal information. For more information, including on how we safeguard your personal information when this occurs, see below: “International Transfers of Personal Information”.

International Transfers of Personal Information.

To bring you our Site, we operate globally. Therefore, it is sometimes necessary for us to share your personal information outside the country where we originally collected your personal information, e.g.:

With our offices in the United States; or
With our service providers located in the United States;

These transfers may be subject to special rules under local data protection law.

The United States may not have the same data protection laws as the country where we originally collected the personal information. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you are located outside the United States, we will only transfer your personal information if:

you provide your explicit consent;
the country to which the personal information will be transferred has been granted an appropriate adequacy decision by your local supervisory authority; or
we have put in place appropriate safeguards in respect of the transfer, for example we have entered into the appropriate standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.

Our Company is headquartered in the United States and utilizes service providers both in the United States and throughout the world. As such, our Company and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

Where the laws of your country allow you to do so, by using the Site or our services, you consent and authorize our Company to transfer, store, and use all such information in the United States of America and any other country where we operate which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that information by us on its servers located in the United States of America as described in this Privacy Policy. If you do not want your personal information transferred to the United States of America and any other country where we operate, please do not submit any information to us or use our services.

If you would like further information, please contact us (see “How To Contact Us” below).

Your Rights and Choices.

If you are located in the European Economic Area or if you are a resident of California, Colorado, Connecticut, Iowa, Utah, and Virgina please go to our Privacy Notice Addendum to learn about additional rights you may have under applicable data protection laws.

Third Party Websites.

If, in your interactions with the Site, you are linked or directed to, or click on, a third party website, we cannot control what information you may provide to that party or on that website, and we are not responsible for how that party may use or disclose any information you may provide to them. This is not as an endorsement by us of any third party website, content that may be offered on such third party website, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third party website, product or service offerings. As such, we urge that you exercise caution before providing them with your personal information and to review the third party’s privacy policy for information on its data processing practice.

You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.

Changes to This Privacy Notice.

This Privacy Policy was published on the date “Last Updated” above.

We may change this Privacy Policy from time to time. Changes to this Privacy Policy will be made by updating this page. Please visit this Privacy Policy regularly to read the current version.

How to Contact Us.

Please contact us or our European Representative by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.

Our contact details are shown below:

Our contact details	Our European Representative’s contact details
legal@coolcatsnft.com
	legal@coolcatsnft.com

Privacy Notice Addendum

This Privacy Notice Addendum (“Notice”) supplements the information contained in Cool Cats Group LLC’s Privacy Policy and applies solely to all visitors, users, and others who are located in the European Economic Union or who reside in the State of California, Colorado, Connecticut, Iowa, Utah, and Virgina (“consumers” or “you”). We adopt this Notice to comply with the General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act of 2021, the Connecticut Data Privacy Act of 2022, the Iowa Consumer Data Protection Act of 2023, the Utah Consumer Privacy Act of 2022, the Virginia Consumer Data Protection Act of 2023, and certain other privacy and data protection laws, as applicable (collectively, the “Statutes”). Any terms defined in the Statutes will have the same meaning when used in this Notice.

As further set forth in our Privacy Policy, may collect certain information that is (i) linked or reasonably linkable to an identified or identifiable individual or natural person, or (ii) that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household, or (iii) as further defined in the Statutes as “Personal Data” or “Personal Information.”

Your Rights Under the GDPR.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws.

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

How to File a GDPR Complaint.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority in your country is the entity who may be contacted at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Personal Information We Sold or Disclosed for a Business Purpose.

In the preceding 12 months, we not sold for a business purpose to one or more third parties any categories of personal information

In the preceding 12 months, we have disclosed to one or more third parties the following categories of personal information:

Category A – Identifiers
Category B – Customer records information
Category D – Commercial information
Category F – Internet or other electronic network activity information

Shine the Light Law.

California Civil Code Section 1798.83, also known as the “Shine The Light” law permits individuals who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Your Rights Under the CCPA.

You may have the right under the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold, Shared, Disclosed, or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: [URL].
Right to Limit Use and Disclosure of Sensitive Personal Information.	You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services. We do not collect sensitive personal information.
Right to Correction	You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Right to Deletion	Subject to certain exceptions, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Your Rights Under Other State Privacy Laws.

Colorado, Connecticut, Iowa, Utah, and Virgina also provide consumers who are residents of these states with certain rights regarding their Personal Data. This section describes the rights you may have under these state privacy laws, under certain circumstances and subject to certain exceptions. Please contacts us if you have any questions about your rights under these state privacy laws.

	Colorado	Connecticut	Iowa	Utah	Virginia
Right to Opt-Out	X	X	X	X	X
						Right of Access	X	X	X	X	X
						Right to Correction	X	X			X
						Right to Deletion	X	X	X	X	X
Right to Data Portability	X	X	X	X	X
Right to Data Portability	X	X	X	X	X	Right to Appeal	X	X	X		X

The Right to Opt-Out	You may have the right to opt out of the processing of Personal Data concerning you for the purposes of: Targeted Advertising; The Sale of Personal Data; or Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not sell Personal Data.
The Right of Access	You may have the right to confirm whether we are processing Personal Data concerning you and to access your Personal Data. Please note, there may be restrictions on how often you may exercise this right.
The Right to Correction	You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
The Right to Deletion	You may have the right to delete Personal Data concerning you or to request that we delete Personal Data provided by, or obtained about, you.
The Right to Data Portability	You may have the right to obtain a copy of your Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Please note, there may be restrictions on how often you may exercise this right.
The Right to Appeal	We hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. The Colorado Privacy Act also gives you right to contact the Colorado Attorney General if you have concerns about the results of your appeal. The Iowa Consumer Data Protection Act of 2023 also gives you right to contact the Iowa Attorney General if you have concerns about the results of your appeal. The Virginia Consumer Data Protection Act of 2023 also gives you right to contact the Virginia Attorney General if you have concerns about the results of your appeal.

How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Please note that under certain Statutes you may only make a related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us, we will take steps to verify your identity before granting you access to your personal information or complying with your request. In order to help protect your privacy and maintain security, you will need to provide us with:

Enough information to identify you (e.g., your full name, address, email address, telephone number, birth date, or customer or matter reference number));
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

In some circumstances, you may use a representative, called an “authorized agent,” to submit a request to us. The definition of authorized agent varies by Statute but we will review each request to exercise your right on a case by case basis and respond in compliance with the applicable Statute.

In order to protect your privacy, Company requires you to confirm that you have provided the authorized agent permission to submit the request and you must provide the authorized agent with signed permission. “Signed” means that the written attestation, declaration, or permission has either been physically signed or provided electronically pursuant to the Uniform Electronic Transactions Act. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but in such cases, consumer verification will not be required. Company may deny a request from an authorized agent that does not submit proof that they have been authorized to act on your behalf. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.