This Statement applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to Andrew J R Squires personnel or job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, telephone number, account name, classifications under California or federal law (e.g. race, color, national origin, religion, age, sex, gender, gender identity) and other similar identifiers.
• Additional Data Subject to Cal. Civ. Code § 1798.80: credit card number, debit card number, bank account information and other financial information.
• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
• Employment Information: professional or employment-related information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Policies and for the following business purposes specified in the CCPA (“Business Purposes”):

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;

2. SOURCES OF PERSONAL INFORMATION

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you register for our services or subscribe to our newsletters
• Your devices, such as when you visit our website
• Our affiliates
• Vendors who provide services on our behalf
• Our joint marketing partners
• Our publishing partners
• Data analytics providers
• Government entities
• Operating systems and platforms
• Social networks
• Data brokers
• Institutional customers
• Cooperative Databases

3. SALE OF PERSONAL INFORMATION

We do not sell your personal information in exchange for monetary consideration.  We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our website in exchange for non-monetary consideration. We share the categories of personal information listed below for online advertising purposes, e-commerce and to provide third-party social network features and functionality on our website. You have the right to opt-out of this disclosure of your information, which may be considered a “sale” under California law, via cookie management in the privacy preference centers of each platform listed above.

That said, due to technical limitations and in the interest of the users, we do not necessarily know the identities of all visitors to our platforms at all times based on the settings they adopt. Your opt-out of cookies setting would only apply to the browser and device you are currently using as we do not make any attempts to link devices you use. If you clear cookies or if you use a new browser or device, your opt-out cookie may no longer be available. As a result, in those situations we may still ask that you authorize the “sale” of your personal information when you visit our platforms, by asking you to accept cookies, within 12 months after you opt out the “sale” of your information.

During the 12-month period prior to the effective date of this Statement, we may have “sold”, to the extent “sale” under the CCPA is interpreted to include advertising technology activities, the following categories of personal information about you to online advertising services and social networks:

• Identifiers
• Online Activity
• Inferences

Our websites are not directed at minors, and we do not knowingly collect, much less sell, any personal information from minors under the age of 16 through our websites. However, if the parent or the guardian of a minor under 16 years old believes that the minor has provided us with personal information, the parent or guardian of that minor should contact us at [email protected] to request the deletion of this information from our files.

4. CALIFORNIA CONSUMER PRIVACY RIGHTS

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access or deletion request, please email us at [email protected] or call us at 1-419-469-1386 and indicate what you wish to access and what you wish to have deleted.

Please understand that we cannot delete personal information in those situations where our retention is required for Business Purposes as detailed above. In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.

We do not offer financial incentives for the collection or sale of personal information, although we may offer individuals the opportunity to receive coupons or discounts via email. If you ask us to delete your information, we will not be able to send you additional coupons or discounts via email, however coupons or discounts sent to you previously will continue to be honored according to their original terms.  We will not discriminate against you if you exercise your rights under CCPA.

To the extent advertising technology activities (e.g online advertising, e-commerce and related tools) are interpreted  as a “sale”  under the CCPA , please visit the cookie preference center when you first visit a Andrew J R Squires site to opt out of such sales. You have the ability to update your preferences at any time via the Manage Cookies link in the page footer of the same site. We collect pseudonymised or aggregated data, e.g. shortened IP addresses to analyse the use of our websites and, thereby, improve and optimize the websites and to display advertising tailored to your needs. We collect this data (to improve your website experience and to promote our products and services) via OneTrust, a cookie management tool.

To submit a request as an authorized agent on behalf of a consumer, please send an email from your own email address to [email protected] indicating the name and email address of your agent. We will respond to requests using both your email address and the agent’s email address. The request must provide enough information for us to reasonably verify you are, or are the authorized representative of, the person about whom we collected personal information. For questions or concerns about our privacy policies and practices, please contact us as described in the Contacting Us section of the Privacy Policy  of the website you are visiting.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you have an account with us, we may verify your identity by requiring you to sign in to your account.  If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide additional information reasonable enough to verify your identity.  In addition, if you do not have an account and 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.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.