PRIVACY STATEMENT-CALIFORNIA

This PRIVACY NOTICE IS FOR CALIFORNIA RESIDENTS and supplements the information contained in the Privacy Statement of red3i LLC (collectively, “we,” “us,” or “our”). It applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We have collected the following categories of personal information about some consumers within the last twelve (12) months:

Category Examples Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

Generally, we collect personal information such as your name, postal address, telephone number, email address, ip address, website(s) where you registered, etc.

We obtain the categories and specific information listed above from the following categories of sources:

- Website Publishers where a consumer registered and/or shared their personal information.

- Data aggregators who obtained a consumer’s personal information from website publishers or other data aggregators as listed above. This could include obtaining consumer information via website registration or website beacons.

- From third-parties that interact with us in connection with the services we perform.

Use of and Sharing of Personal Information

We may use, sell, share, license or disclose the personal information we collect for one or more of the following commercial purposes:

- To deliver email marketing messages to consumers.

- To provide consumers’ personal information to other direct marketing companies engaged in email, postal, display, social and other marketing efforts.

- To add consumers to a DO NOT SELL MY INFORMATION list or other suppression lists maintained by us.

- To improve our website and present its contents to you.

- For testing, research, analysis and product development.

- For law enforcement requests and as required by applicable law, court order, or governmental regulations.

- As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing notice through updates to our Privacy Policy contained here: http://red3i.com/privacy.php

In the preceding twelve (12) months, we have disclosed, sold or licensed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category F: Internet or other similar network activity.

We disclose, sell or license your personal information for a business purpose to the following categories of third parties:

- Our affiliates: email, postal, display, and other marketing companies

- Service providers: email service providers and data hygiene companies

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

The CCPA also requires us to ensure you are making a verifiable consumer request.

Right to Opt Out of Sale of Personal Information

TO EXERCISE YOUR RIGHT TO OPT-OUT OF YOUR PERSONAL INFORMATION BEING SHARED OR SOLD:

1 - Send an email to requests@red3i-ccpa.com with the SUBJECT LINE: Opt-Out Request

2 – Include within the body of the email your full name, postal address, contact telephone number, and all email addresses you would like us to include in our search.

3 – Our compliance team will be in touch shortly to verify and/or honor your request.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected about you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

TO EXERCISE YOUR RIGHT TO HAVE YOUR INFORMATION DELETED:

1 - Send an email to requests@red3i-ccpa.com with the SUBJECT LINE: Delete My Information

2 – Include within the body of the email your full name, postal address, contact telephone number, and all email addresses you would like us to include in our search.

3 – Our compliance team will be in touch shortly to verify and/or honor your request.

Access to Specific Information and Data Portability Rights

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

- The categories of personal information we collected about you.

- The categories of sources for the personal information we collected about you.

- Our business or commercial purpose for collecting or selling that personal information.

- The categories of third parties with whom we share that personal information.

- The specific pieces of personal information we collected about you (also called a data portability request).

- You are entitled to receive this information in a portable and readily usable format.

TO EXERCISE YOUR RIGHT TO ACCESS WHAT INFORMATION RED3I MAY HAVE COLLECTED AND/OR SHARED ABOUT YOU:

1 - Send an email to requests@red3i-ccpa.com with the SUBJECT LINE: Personal Information Request

2 – Include within the body of the email your full name, postal address, contact telephone number, and all email addresses you would like us to include in our search.

3 – Our compliance team will be in touch shortly to verify and/or honor your request.

Exercising All Access, Data Portability, and Deletion Rights

For your convenience, you may exercise your access, data portability, DO NOT SELL and deletion rights listed above with one simple request.

TO EXERCISE ALL OF THESE RIGHTS:

1 - Send an email to requests@red3i-ccpa.com with the SUBJECT LINE: All CCPA Rights Request

2 – Include within the body of the email your full name, postal address, contact telephone number, and all email addresses you would like us to include in our search.

3 – Our compliance team will be in touch shortly to verify and/or honor your request.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our response(s) to you via email to the primary email address provided with your original request. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, our disclosures will usually be provided in a .PDF file format.

We do not charge a fee to process or respond to your verifiable consumer

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

· Deny you goods or services.

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

· Provide you a different level or quality of goods or services.

· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: requests@red3i-ccpa.com
Postal Address: red3i LLC
Attn: Compliance Department
522 Lady Street
Columbia, SC 29201