CityGrid™ Website

Privacy Policy

CityGrid.com
CityGrid™ Website
Privacy Policy Last Updated: July 1, 2023

Summary

Thank you for visiting the CityGrid™ website located at www.CityGrid.com (individually referred to as the "Site"). The Site is an Internet property of eLocal USA LLC ("CityGrid™," "we" or "us"). The following CityGrid™ Website Privacy Policy ("Privacy Policy") sets forth our policy with respect to the collection, storage and use of your personal information and other information that we collect from you. Please note, if you are a resident of a European Union Member State ("EU Resident"), you are not permitted to use the Site and/or CityGrid™ Offerings (as defined below).

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us via privacy@elocal.com; by calling us at: (877) 913-5622; or by sending us mail to: eLocal.com | 1010 Spring Mill Ave | Suite 200 | Conshohocken, PA | 19428.

Background

You agree to this Privacy Policy, in its entirety, when you: access the Site; utilize the CityGrid™ search directory ("Directory Service") in order to obtain Listings regarding a variety of businesses, professionals, venues, products and/or services (collectively, "Third Party Offerings") as offered and provided by the third party business entities and professionals featured on the Site (collectively, "Third Party Service Providers"); access articles, discussions and feedback on the CityGrid™ Home Expert Network ("Home Expert Network") and/or access other content on the Site (collectively, "Content"); utilize the Site's many interactive features designed to facilitate interaction between you, CityGrid™, the Ongoing Contributors and Expert Panelists participating in the Home Expert Network and other Site users including, but not limited to, blogs, comment sections, reviews and question and answer options located in designated areas of the Site (collectively, "Interactive Services"); register to submit a free Listing of your Third Party Offerings; register for Paid Advertiser Services in connection with promoting your Third Party Offerings as an Advertiser; and/or access links to our social media pages on third party social media websites, such as Facebook® and Twitter® ("Social Media Pages," and together with the Site, Directory Services, Listings, Home Expert Network, Content, Interactive Services, Paid Advertiser Services and Social Media Pages, the "CityGrid™ Offerings").

Capitalized terms not defined herein shall have the meaning set forth in the CityGrid™ Website Terms and Conditions ("Terms and Conditions").

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY IN ITS ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE CityGrid™ OFFERINGS.

Any use of the Directory Service by Site Users is not intended to, and will not create, an attorney-client relationship between any such Site Users and CityGrid™. Without limiting the foregoing, any information submitted to CityGrid™ and/or any electronic or other communication sent to CityGrid™ will not create, or be covered by, an attorney-client relationship between Site Users and CityGrid™.

Privacy Policy Quick Links

Below are links to key sections of our Privacy Policy:

• Privacy Policy Quick Links
• Personally Identifiable Information We Collect
• Use and Sharing of Personally Identifiable Information
• Non-Personal Information Collection and Use
• Behavioral Tracking/Do Not Track
• Security of Your Personal Information
• Children's Privacy
• Opt-Out/Unsubscribe
• Deleting, Modifying and Updating Your Information
• Changes to this Privacy Policy
• Contact Us
• Additional U.S. State Privacy Disclosures

Personally Identifiable Information We Collect

We collect your personally identifiable information when you register on the Site in order to utilize the various CityGrid™ Offerings. We may also collect your personally identifiable information when you otherwise agree to the terms of this Privacy Policy, but do not complete the applicable registration process in full.

The personally identifiable information that you must provide on the applicable Site Forms and/or in connection with your request for CityGrid™ Offerings may include, depending on the applicable CityGrid™ Offerings requested, all or some of the following: your first and last name; your e-mail address; your primary telephone number; your credit card information; the category applicable to your inquiry (where searching for a Listing); your company name; your company's address; your business telephone number; categories that apply to your company's business practice, if applicable; at your option, your mobile telephone number; at your option, your business profile and link to your company's website; any other information requested on the applicable Site Form. For purposes of this Privacy Policy, item (d) in the preceding sentence shall be considered "Sensitive Information".

Consent to Call Recording

From time to time, when you call us, when we call you, or when we forward calls between users and thirty party businesses, we may record those calls for quality assurance and customer satisfaction purposes. We will notify you at the beginning of any and all calls that we record.

Use and Sharing of Personally Identifiable Information

Please see our Additional State Privacy Disclosures below for additional details regarding how we use the personal information collected.

By submitting your personal information on the Site, you agree that we may share such personal information (other than your Sensitive Information) with Third Party Service Providers that you request to be contacted by in order to complete your request for Third Party Offerings, and that the Third Party Service Providers may use such personal information for any lawful purposes, subject to any restrictions contained herein. Any information that you supply to any Third Party Service Provider shall be governed by the applicable Third Party Service Provider's privacy policy. Please be advised that CityGrid™ does not itself provide Third Party Offerings, or any other related products and/or services. The ultimate terms and conditions of any Third Party Offerings provided by any Third Party Service Providers will be determined by those Third Party Service Providers.

Where you register to access any of the CityGrid™ Offerings, we use the personal information that you make available to personalize your experience with the Site, facilitate the provision of the applicable CityGrid™ Offerings to you and for verification purposes. You also agree that we may contact you at any time, via e-mail or other means: with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the CityGrid™ Offerings; with information regarding third party products, services, offers and/or promotions that we think might be of interest to you. If you wish to stop receiving future communications from us, please see the Opt-Out/Unsubscribe section below.

If you wish to stop receiving future communications from us, please see the Opt-Out/Unsubscribe section below.

By submitting your personal information in connection with the CityGrid™ Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the "Rule") and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

In addition, where you provide "express written consent" within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time ("TCPA"), you consent to receive telephone calls from CityGrid™ and any designated Third Party Service Provider(s), including artificial voice and pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the CityGrid™ Offerings, and your consent simply allows CityGrid™, as well as the designated Third-Party Service Provider(s), to contact you via these means.Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: have your telephone number reassigned to another person or entity; give up your telephone number so that it is no longer used by you; port your telephone number to a landline or vice versa; or otherwise stop using that telephone number for any reason (collectively "Phone Number Change"), you agree that you shall promptly notify CityGrid™ of the Phone Number Change via e-mail at: privacy@eLocal.com. We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our users' personal information as needed to perform their functions for us, but we do not permit them to use your personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience on the Site and/or to contact you when necessary in connection with transactions entered into by you on the Site. We may also use your personal information for internal business purposes, such as analyzing and managing our business. We may also combine the information we have gathered about you with information from other sources.

We also reserve the right to release current or past user information: in the event that we believe that the user is using, or has used, the CityGrid™ Offerings to commit unlawful acts and/or in violation of the Terms and Conditions, this Privacy Policy or any other of our operating rules, policies, price schedules and other supplemental terms and conditions or documents that may be published by us from time to time; if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or if we are sold, merge with a third party or are acquired; provided, however, that if CityGrid™ is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information. Moreover, you hereby consent to disclosure of any record or communication to any third-party when CityGrid™, in its sole discretion, determines the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time.

Non-Personal Information Collection and Use

Please see our Additional State Privacy Disclosures below for additional details regarding how we collect and share your non-personal information.

IP Addresses/Browser Type We may collect certain non-personally identifiable information about you when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Internet Explorer, Chrome, Safari), your IP address, the type of operating system that you use (e.g., Windows or Mac OS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the CityGrid™ Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze CityGrid™ Offerings usage, as well as to offer you products and services.

Cookies When an end-user visits the Site, we send one (1) or more cookies and/or gif files (collectively, "Cookies") to assign an anonymous, unique identifier to the applicable end-user's computer or other device. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Site, including for storing user preferences, and tracking Site-user trends (such as pages opened and length of stay at the Site).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a user rejects a Cookie, he or she may still use the CityGrid™ Offerings. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking/Do Not Track

ther than as set forth below, neither CityGrid™, nor any third parties, track the activity of Site Users in connection with the Site. However, when an Advertiser is logged into its account, we track changes in such Advertiser's status and updates to its profile. We may use this activity data to target those Advertisers with more specific marketing messages. In addition, when an Advertiser opens or clicks on links in email marketing messages from us, we record that information and may use it to refine subsequent marketing messages. This tracking will usually occur even where the applicable Advertiser has selected the "do-not-track" option on its Internet browser.

We use Google Analytics on the Site, as well as a conversion rate optimization platform called Visual Website Optimizer. These platforms do not record personal information of Site Users, but aggregate information and activity only.

Cross Device Tracking

CityGrid™ does not track Site Users' use of the CityGrid™ Offerings across multiple devices, including personal computers and mobile devices.

Other Websites

The Site may contain links to third-party owned and/or operated websites including, without limitation, websites owned and/or operated by our Third Party Service Providers. CityGrid™ is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of their third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and CityGrid™ has no responsibility or liability relating to them.

Security of Your Personal Information

We endeavor to safeguard and protect our users' personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). The privacy of your personal information is very important to us. When our registration process asks users to submit Sensitive Information (such as credit card information), and when we transmit such Sensitive Information, that Sensitive Information is encrypted and is protected with Transport Layer Security ("TLS') encryption software.

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. The servers that we store personal information on are kept in a secure physical environment. We also have security measures in place to protect against the loss, misuse and alteration of personal information under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure.

Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site is at your own risk.

All of our users' personal information is restricted in our offices. Only employees or third party agents who need personal information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Children's Privacy

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. CityGrid™ does not knowingly solicit or collect information from visitors under eighteen (18) years of age. CityGrid™ encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

Please see our Additional State Privacy Disclosures below for additional details regarding how certain State residents can opt-out from the sale of their personal information.

To opt-out of receiving e-mail advertising, SMS text-based marketing (where and to the extent permitted by applicable law), telemarketing and direct mail marketing from us, you can follow the instructions at the end of the applicable marketing message or email us at privacy@elocal.com.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your use of the CityGrid™ Offerings and to respond to any inquiry or request made by you. To opt-out of receiving CityGrid™ Offerings-related and inquiry response-related messages from CityGrid™, you must cease utilizing the CityGrid™ Offerings and submitting inquiries to CityGrid™, as applicable.

Deleting and Updating Your Information

Please see our Additional State Privacy Disclosures below for additional details regarding how certain State residents can opt-out from the sale of their personal information.

At your request, we will inform you of what personal information we have on file for you. In addition, at your request, we will remove and/or modify the personal information that you have provided to us, or that we have collected. You may do so by submitting the form here by email to privacy@elocal.com; provided, however, that we ask individuals to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information will terminate your access to some or all of the CityGrid™ Offerings. If you wish to continue using the CityGrid™ Offerings, you may not delete the personal information that we have on file for you. Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of personal information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

CityGrid™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing this Privacy Policy. If the manner in which we use personally identifiable information changes, CityGrid™ will notify users by: (a) sending the modified policy to our users via email; and/or (b) any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner, and we will only use your information in this different manner where you opt-in to such use.

Contacting the Site

If you have any questions about this Privacy Policy or the privacy practices of CityGrid™, please feel free to e-mail us at: privacy@elocal.com.

Filing a Complaint with the Federal Trade Commission

To file a complaint regarding our privacy practices, please click here.

Changes to these Provisions

We reserve the right to amend these Provisions in our discretion and at any time. When we make changes to these Provisions, we will notify you by email or through a notice on the Site's homepage.

Contact Information

If you have any questions or comments about these Provisions, our Privacy Policy, 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 state law, please do not hesitate to contact us by either:

• Clicking here
• Calling us at: (877) 913-5622;
• Emailing us at: privacy@elocal.com; or
• Sending us U.S. mail to: eLocal.com, 1010 Spring Mill Ave, Suite 200, Conshohocken, PA, 19428.

Additional State Privacy Disclosures

These Additional State Privacy Disclosures supplement the above information by providing additional information about our personal data processing practices relating to individual residents of the States of California, Colorado, Connecticut, Utah, and Virginia. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these Disclosures.

Additional Personal Data Disclosures

Sensitive Information

The following personal data elements we collect may be classified as "sensitive' under certain privacy laws ("sensitive information'):

• Credit/debit card number plus expiration date and security code (CVV), and financial account number and routing number;
• Username and password; and
• Precise geolocation data.

We use this sensitive information for the purposes set forth in the "Personally Identifiable Information We Collect' and "Use and Sharing of Personally Identifiable Information' sections of our Privacy Notice, to comply with legal and regulatory requirements, to protect the life or physical safety of you or others, or as otherwise permissible for our internal business purposes consistent with applicable laws.

We do not sell your sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising. eLocal does not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.

De-identified Information

We may at times receive or process personal data to create de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in de-identified form and not attempt to re-identify the data except as required or permitted by law.

Your Privacy Choices

Depending on your state of residence, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.

Depending on your state of residence, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.

Submitting Privacy Rights Requests

To submit a request to exercise one of the privacy rights identified above, please:

• Submit the form here or email privacy@elocal.com.

We may need to verify your identity before processing your request. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. We will use personal data provided in connection with a Rights Request only to review and comply with the request

To Exercise Your Right to Opt-Out of Personal Data Sales or Sharing for Targeted Advertising

Unless you have exercised your Right to Opt-Out, we may disclose your personal data to third parties who may use such information for their own purposes in accordance with their own privacy policies. Under some state laws, disclosing personal data for online advertising like this may be considered a "sale of personal data' or "sharing for targeted advertising.'

eLocal allows certain companies to place tracking technologies like cookies and pixels on our sites, which allow those companies to receive information about your activity on eLocal that is associated with your browser or device. The companies may use that data to serve you more relevant ads on our sites or others. Except for this kind of selling or sharing, eLocal doesn’t otherwise sell any of your personal data. You always have control over whether these technologies work on your devices. You can disable cookies altogether by adjusting the settings on your browser. However, if you choose to disable some or all cookies, parts of our services may no longer work.

You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal data so that we can properly identify you to track compliance with your opt-out request. We will only use personal data provided in an opt-out request to review and comply with the request. If you choose not to provide this data, we may be able to process your request only to the extent we are able to identify you in our data systems.

To exercise the Right to Opt Out of Personal Information Sales or Sharing: email privacy@eLocal.com with sufficient information to identify you and your request.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted by law to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residence, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

Depending on your state of residence, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to privacy@elocal.com.

Minors

We do not collect the personal data of consumers we know to be less than 16 years of age. If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative). Please make any privacy requests regarding a minor via email to privacy@elocal.com.

California-Specific Disclosures

The following disclosures only apply to residents of the State of California.

California Categories of Personal Data

California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data, sources and purposes described in the "Personally Identifiable Information We Collect' section of our Privacy Notice below:

1. Identifiers, including Account Registration and Profile Information, information related to your feedback, inquiries, and communications, credit and identity information relating to data used to identify you, full name, and IP address.
2. Customer Records, including Account Registration and Profile Information, Security/Authentication Information, and Payment Information.
3. Protected Classification Characteristics, including age, date of birth, gender, and sex.
4. Commercial Information, including Account Registration and Profile Information relating to your purchases and purchase history.
5. Internet/Network Information, including information about how you access and use the services, Log Data, and Analytics Data.
6. Geolocation Data, including general geographic location or more precise location with your consent or when permitted by law.
7. Sensory Information, including, where permitted by law, recordings of phone calls between us and individuals, and image and video recordings of visitors to our offices or events.
8. Profession/Employment Information, including the business or organization you represent, your title with that business or organization, information relating to your role with the business or organization, and current or past job history or performance evaluations.
9. Sensitive Information, including credit/debit card number plus expiration date and security code (CVV), financial account number and routing number, username and password, and precise geolocation.
10. ther Personal Data, including any information you provide us in connection with signing up the eLocal Services, email communications, and surveys, personal data you permit us to see when interacting with us through social media, and personal data you provide us in relation to a question, request, inquiry, survey, contest, or promotion.

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated CA User information.
• Information excluded from the CCPA's scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

• Directly from our CA Users. For example, from online registration forms that our CA Users submit to us related to the products and/or services that we (and our third party service providers) offer by and through the Site. (Category A, B, D, H and I)
• Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, D, F, G and I)
• Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners. (Category E, F)
• From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Category A, B, D, F and I)
• From third-party data brokers or aggregators. (Category A, B, C, D and I)

Retention of Personal Data

We strive to retain your personal data only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain your personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and/or accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Therefore, we retain personal data for as long as you use our services for the purposes explained in our Privacy Notice, including maintaining a user account. When you discontinue the use of our services, we will retain your personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as for any additional purpose based on the choices you have made, such as to receive marketing communications.

Once retention of your personal data is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store your personal data and isolate it from further processing until deletion or deidentification is possible.

Use of Personal Information

We may use or disclose the personal information that we collect for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your request for products and/or services featured on the Site, we will use that personal information to better provide you with the requested information. (Category A, B, D and I)
• To enable the third-party service providers featured on the Site to contact you regarding the featured products and/or services. (Category A, B, D, F, G and I)
• To provide you with information, products or services that you request from us. (Category A, B, D, G and I)
• To create, maintain, customize and secure your account with us. (Category A, B, D, F and I)
• To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Category A, B, D, F and I)
• To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, D, F and I)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site's Terms and Conditions. (Category A, B, D, E, F, G and I)
• To improve the Site and better present its contents to you. (Category A, B, D, F and I)
• For customer service purposes and to respond to inquiries from you. (Category A B, and D)
• For testing, research, analysis and product development. (Category A, B, D, F and I)
• As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, D, F, G and I)
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, D, F, G and I)
• As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Category A, B, D, F and I)
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Category A, B, D, F, G and I)

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 you with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information (Category A, F and I): (a) with/to the third party service providers that offer the products and services featured on the Site; and (b) for the other business purposes set forth above.

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

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

• Category A. Identifiers.
• Category E. Internet or other similar network activity.
• Category H. Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

• Our affiliates. (Category A, E and H)
• Service providers. (Category A, E and H)
• The third party service providers that offer the products and services featured on the Site. (Category A, E and
• Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Category A, E and H)

In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:

• Category A. Identifiers.
• Category E. Internet or other similar network activity.
• Category H. Professional or employment-related information.

In the preceding twelve (12) months, we have sold the above referenced categories of personal information to the third party service providers that offer the products and services featured on the Site.

Your Rights and Choices

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

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:

• Clicking here and submitting the form via email to privacy@elocal.com
• Calling us at: (877) 913-5622; or,
• Sending us U.S. mail to: eLocal.com, 1010 Spring Mill Ave, Suite 200, Conshohocken, PA, 19428.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of 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 twelve (12) months. Once we receive and confirm your verifiable CA User 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 have shared that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) 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 obligations in connection with 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 rights, ensure the right of another CA User 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 CA User 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.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

• Clicking here and submitting the form via email to privacy@elocal.com
• Calling us at: (877) 913-5622; or,
• Sending us U.S. mail to: eLocal.com, 1010 Spring Mill Ave, Suite 200, Conshohocken, PA, 19428.

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

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

• Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative of the applicable CA User.
• 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 that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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; and/or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

"Shine the Light' Disclosures

The California "Shine the Light' law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, email us at privacy@eLocal.com.

Nevada-Specific Disclosures

Under Nevada law, Nevada residents may opt out of the sale of certain "covered information' collected by operators of websites or online services. This right applies even if your personal information is not currently being sold.  If you are a resident of the State of Nevada and would like to opt-out from the disclosure of your personal information to any third party data broker, please submit the contact form here to privacy@elocal.com or by phone: 877-913-5622. We may share your data as explained in this privacy policy, such as to enhance your experiences and our services, and those activities will be unaffected by a Nevada do not sell request. You may also have other choices regarding our data practices as set forth elsewhere in this privacy policy.

Virginia-Specific Disclosures

If you are a Virginia resident, you have certain rights related to your personal information. If you wish to exercise these rights, you can submit a request using the methods listed below:

• Access Requests: submit the contact form here to privacy@elocal.com, by mail to 1010 Spring Mill Ave, Suite 200, Conshohocken, PA, 19428, or by phone: 877-913-5622.
• Correction Requests: contact us at privacy@elocal.com by mail to 1010 Spring Mill Ave, Suite 200, Conshohocken, PA, 19428, or by phone: 877-913-5622.
• Deletion Requests: submit the contact form here to privacy@elocal.com, by mail to 1010 Spring Mill Ave, Suite 200, Conshohocken, PA, 19428, or by phone: 877-913-5622.
• Do Not Sell My Personal Information Requests: submit the contact form here to privacy@elocal.com

You may appeal our decision with respect to a request you have submitted by emailing us at privacy@elocal.com.