Privacy Notice

Last Updated: August 22, 2023

Overview

This Privacy Policy (this “Policy”) applies to personal information that is collected, maintained, used, or otherwise processed by CDE Services, LLC (the “Company”, “we”, “us” or “our”) through our website (the “Site”) and related mobile applications/apps made available by us (each an “App” and collectively the “Apps”; the Site and the Apps are collectively referred to as the “Platform”) when you access the Platform and the services provided through the Platform.

This Policy applies only to information we collect on or through the Platform. This Policy does not apply to information that we collect offline, or that you provide to, or is collected by, any third party, which may have their own privacy policies that we encourage you to read before providing your information on or through them (see “Third-Party Information Collection” below).

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. In using the Platform, you agree to be bound by this Policy and you agree that we can communicate with you electronically regarding security, privacy and other administrative issues relating to your use of the Platform.

If you do not accept the terms of this Policy, you may not access or use the Platform and you should discontinue your use of it.

This Policy may change from time to time (see “Updates to Our Privacy Policy” below). Your continued use of the Platform after we revise this Policy means you accept those changes, so please check this Policy periodically for updates.

The Information We Collect and How We Collect It

Information that you provide to us. When you download, register with, access, or use any aspect of the Platform, we may ask you to provide information by which you may be personally identified, including but not limited to, your name, postal address, email address, and telephone number (“personal information”). When you are asked to provide personal information, you may decline. However, if you choose not to provide information that is necessary, you may not be able to use some of the features or services that are dependent on this information.

This information may be provided by you in the following ways:

Filling in forms on the Platform. This includes information that you may provide when downloading, registering with, accessing, or using any aspect of the Platform, when requesting further services, and when reporting problems with the Platform.
Contacting us. This includes information you may provide when you correspond with us, including, but not limited to, email addresses and phone numbers.
Participating in surveys. This includes information you may provide when you respond to surveys that we might ask you to complete for research purposes.
Searching within the Platform. This includes information you may provide when you perform search queries on the Platform.

If you provide information for publication or display (“Posted”) on public areas of the Platform or websites you access through the Platform (collectively “User Contributions”), then your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information that we collect automatically. Like many websites, the Platform commonly uses information gathering tools, such as cookies and web beacons, to collect information as you navigate. The Platform automatically collects certain information, such as internet protocol (IP address), browser type, operating system, and other usage information, and stores that information in log files.

The technologies we use for automatic information collection may include:

Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App. For information about managing your privacy and security settings for Cookies, see “Your Choices About Our Collection, Use, and Disclosure of Your Information” below.

Flash Cookies. Certain features of the Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Your Choices About Our Collection, Use, and Disclosure of Your Information” below.

Web Beacons. The Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

How We Use the Information We Collect.

We use information that you provide to us, including any personal information, to:

advance cancer-related research conducted by us or in collaboration with other organizations or individuals.
Provide you with the Platform and its contents, and any other information that you request from us.
Fulfill any purpose for which you provide it.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when updates for the Platform are available, and of changes to any products or services we offer or provide though it.
Develop and improve the Platform, products, and services.
Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
Respond to law enforcement requests, or as required by applicable law, court order, or governmental regulations.
Receive communications from us if you agree to receive emails or other communications from us.

The information that we collect automatically helps us to improve the Platform and to deliver a better and more personalized experience by enabling us to:

to analyze trends, administer the Platform, track your navigation around the Platform, and gather anonymous demographic information for the purpose of improving the Platform.
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize the Platform according to your individual interests.
Speed up your searches.
Recognize you when you use the Platform.

Disclosure of Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual without restriction.

In addition, we may disclose information, that may include personal information:

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Platform’s users is among the assets transferred.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information

You have many choices with regards to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system, but if you choose to block or delete cookies, it may limit your use of certain features or functions on the Platform. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.

This section describes mechanisms that we provide for you to control certain uses and disclosures of your information.

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Regarding Flash Cookies, visit the Flash player settings page on Adobe’s website to learn how you can manage your Flash cookie settings. However, if you disable or refuse cookies or block the use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
Promotions by the Company. Users may request to be removed from mailing lists at any time.

To review or request corrections to your personal information collected by us or removal from any promotional communications, please contact us by one of the means noted below under “Contact Us”.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.

Nevada residents who wish to exercise their sales opt-out rights under Nevada Revised Statutes Chapter 603A may submit such request by sending an email to info@goEBT.com or calling us at [PHONE NUMBER].

Colorado, Connecticut, Virginia, and Utah each provide their residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their residents with rights to:

Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

For residents of Colorado, Connecticut, Nevada, Virginia, and Utah to exercise the above rights, please contact us (“Consumer Rights Request”) (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at info@goEBT.com, or (ii) by regular mail at 1200 Williams Drive, Suite 1200, Marietta, GA 30066.

For residents of Colorado, Connecticut, and Virginia, if we decline to take action on your Consumer Rights Request, you may appeal such refusal (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at info@goEBT.com, or (ii) by regular mail at 1200 Williams Drive, Suite 1200, Marietta, GA 30066 within a reasonable time period after we sent you our decision.

Third-Party Information Collection

When you use the Platform or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
- Advertisers, ad networks, and ad servers.
- Analytics companies. Please see additional information below under “Our Use of Google Analytics”.
- Your mobile device manufacturer.
- Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Other Sites. We are not responsible for the practices employed by websites linked to/from the Platform nor the information contained therein. Often links to other websites are provided solely as a way for the user to obtain information that may be useful to them. The third party’s privacy policy and/or that of its service provider will govern the use of this information, and we are not responsible for the privacy practices of such companies. To better protect your privacy, we encourage you to read these businesses’ privacy policies to learn about how they treat your information.
Social Media Sites. You may share information from the Platform with people associated with your social media account and your social media account provider. By sharing this information, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider’s privacy policy. Please note that any information you post within these public forums or social media pages may become public and may be read, collected, and used by anyone. If you don’t want people to know your email address, for example, don’t include it in any message you post publicly. Please exercise caution when deciding whether to disclose your personal information in public posting areas. We are not responsible for the use by others of the information that you disclose in public posting areas.

Our Use of Google Analytics

We use Google Analytics to collect limited information about your use of the Platform to help us improve how the Platform works. Google Analytics collects certain information, such as how often you use the Platform. We use the information received from Google Analytics to improve the Platform. For more information about Google Analytics and how it collects and processes data, please visit: https://policies.google.com/technologies/partner-sites?hl=en-US. Instructions on opting out of Google Analytics using a specific plug-in are available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt-out is specific to Google activities and does not affect the activities of other ad networks or analytics providers that we may use.

Security Measures

We have taken certain precautions designed to protect the users of the Platform’s information. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password and/or user name for access to certain parts of our Platform, you are responsible for keeping such password and user name confidential. We ask you not to share your password or user name with anyone. Because the information you share in public areas may be viewed by other users of the Platform, we urge you to be careful about giving out information in public areas of the Platform, such as message boards.

Notwithstanding our efforts, no data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information transmitted to us, and you transmit such information at your own risk. You are responsible for keeping the information you provide confidential. We are not responsible if someone else accesses your account through information they have obtained from you or through a violation by you of this Policy or our Terms of Service.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Platform and visiting your account profile page. You may also send us an email at info@goEBT.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Platform.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.

Do Not Track

The Platform does not respond to web browser “do not track” signals or other similar mechanisms.

Retention of Your Information

Our policy is to retain personal information only for as long as is necessary to fulfill the reason for which the personal information was collected and as necessary to process such personal information. In addition to the above, we will retain your personal information for the purposes of satisfying any professional, legal, accounting or reporting requirements to which we are subject. To determine the appropriate retention period for personal information, we consider the scope, 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 collected and processed your personal information and whether we can reasonably achieve those purposes through other means, as well as any applicable legal and professional requirements.

Children or Adolescents

The Platform is intended strictly for adult users. By agreeing to this policy through use of the site, the user is verifying that they are an adult aged 18 or older. We do not knowingly collect personal information from children under the age of 18. If we discover or are made aware that we have received personal information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will delete such information from our systems. If you are a parent or legal guardian of a child under the age of 18 and believe that your child has disclosed personal information to us we welcome you contacting us as provided below so that we can address such matter.

From time to time there may be instances when we collect information through the Platform about children under the age of 18 but we will only do this when such information is provided to us by that child’s parent or legal guardian. In all cases where we’ve collected information about a child under the age of 18, the parent or legal guardian may contact us via email or regular mail using the contact information noted below under “Contact Us”, to review and request deletion of such child’s personal information as well as to prohibit the further use of such information by us.

California Minors. California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your California Privacy Rights” below for more information.

Linking Policy

We permit text links to the Platform. However, linking should not: suggest or falsely claim endorsement or affiliation with us; be used for commercial or fundraising purposes; or conceal the fact that the reader has left the linking site. We reserve the right to withdraw permission for any link at any time. Please contact us with any related questions by using one of the means noted below under “Contact Us”.

Updates to Our Privacy Policy

We may update this Policy from time to time. We will notify you by posting the new Privacy Policy on this page, and we will update the “Last Updated” date at the top of this Policy. We will let you know via email and/or a prominent notice on our Services, in the event of a material change. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

Your California Privacy Rights

The following additional privacy notices for California residents (the “California Notice”) supplement the information contained in the other portions of this Policy and apply solely to individuals who reside in the State of California (“California consumer” or “you”). The Company adopts this California Notice to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and their related regulations (collectively the “California Privacy Law” or the “CPL”) and other applicable California laws.

Overview of Consumer Rights Under the CPL—California Consumers

Under the CPL, California consumers have certain rights regarding their personal information, including:

The right to know the categories of personal information that the Company has collected and the categories of sources from which we obtained such information.
The right to know the Company’s business purposes for sharing personal information.
The right to know the categories of third parties with whom the Company shared personal information.
The right to know if we sold or disclosed your personal information for a business purpose, comprising two separate lists disclosing:
any sales, which list identifies the personal information categories that each category of recipient purchased (note that at present we do not sell personal information that we collect); and
any disclosures for a business purpose, which list identifies the personal information categories that each category of recipient obtained.
The right to access the specific pieces of personal information that the Company has collected
The right to correct personal information that the Company has collected.
The right to delete your personal information.
The right to not be discriminated against if you exercise your rights under the CPL.

The provisions below of this California Notice provide further details about these and other rights and certain details about the exercise of such rights.

Information We Collect—California Consumers

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device (collectively, “personal information”). Personal information does not include:

Publicly available information from government records.
De-identified or aggregated California consumer information.
Information excluded from the CPL’s scope, including:
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 other laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples
A. Identifiers	An individual’s 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.
B. Personal information categories described in 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 (Note: Certain of the above information may be considered to be sensitive personal information under the CPL and, to the extent such data is considered to be sensitive personal information you have the right to limit the use and disclosure of such data.)
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).
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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.
F. Internet or other similar network activity	Browsing history, search history, information on a California consumer’s interaction with our website, application, or advertisement and any social media sites from which user information is linked, connected or obtained.
G. Geolocation data	Physical location or movements (Note: Certain precise geolocation data may be considered to be sensitive personal information under the CPL and, to the extent such data is considered to be sensitive personal information you have the right to limit the use and disclosure of such data.)
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.	Current or past job history or performance evaluations.
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.
K. Inferences drawn from other personal information	Examples include a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Sources of Personal Information—California Consumers

In addition to sources of personal information addressed elsewhere in this Policy, we obtain the categories of personal information listed above from the following categories of sources:

Directly from You. For example, from forms you complete or products and services you purchase or from communications with you such as when you contact the Company (whether in person, by mail, by phone, online, via electronic communication or by other means) including our customer support service.
Indirectly from You. For example, from observing your actions on the Platform or from products or services that you have purchased from the Company, if you have enabled such functionality, such as telemetry services.
From Others.
From third party service providers. For example, if you choose to make an electronic payment directly to the Company, or through a linked website or mobile application, or through an affiliate of ours, the Company may receive personal information about you from third parties such as payment services providers, for the purposes of that payment.
From affiliates. We may collect personal information about you from our affiliates or others acting on their behalf.
From Public Sources. For example, we may collect information from public records.
Uses of Personal Information

In addition to uses of personal information addressed elsewhere in this Policy, we may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill the reason that you provided the information. For example, if you share your name and contact information to request a price quote, request to be contacted by an affiliate, or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we may use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders or to process returns.
To perform services such as customer service, order fulfillment, payment processing, financing and advertising, marketing or analytic services.
To advance our commercial or economic interests, such as by helping you to buy, rent, lease, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
To verify or maintain quality or safety standards or improve or upgrade a product or service provided or controlled by or for us.
To provide, support, personalize and develop the Platform, products and services such as to perform warranty related services or other post-sale activities such as product or service monitoring or repairs.
To create, maintain, customize and secure your account with us.
To process your requests, purchases, transactions and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Platform, third-party sites and via mail, email or text message (with your consent, where required by law).
To help maintain the safety, security and integrity of the Platform, products and services, databases and other assets and business.
For testing, research and analysis purposes, including to develop and improve the Platform, products and services.
To respond to 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 CPL or applicable law.
To send you information relevant to your past purchases and interests, subject to compliance with applicable laws regarding direct marketing.
To otherwise use as reasonably necessary and proportionate to achieve our operational or notified purpose for collecting personal information and as compatible with the context in which we collected the information.
To perform services on behalf of a CPL-covered business or its service provider, such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services.
To review and audit our business interactions with you.
To detect or prevent security incidents or other illegal activity.
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 a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Platform users, including California consumers, is among the assets transferred.

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 – California Consumers

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Protected classification characteristics under California or federal law.
Commercial information.
Biometric information.
Internet or other similar network activity.
Geolocation data.
Sensory data.
Professional or employment-related information.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Inferences drawn from other personal information.

The categories of third parties to which we may disclose personal information collected by us include the following:

Service providers
Affiliates
Recipients of data from cookies

Sales of Personal Information – California Consumers

The Company does not sell personal information to third parties.

Exercising Your CPL Rights and Choices – California Consumers

The sections below describe how you may exercise your rights under the CPL.

Exercising Your CPL Rights and Choices – Access to Specific Information and Data Portability Rights—California Consumers.

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights – California Consumers” below), 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 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).
If we disclosed your personal information for a business purpose, a list disclosing the personal information categories that each category of recipient obtained.

Exercising Your CPL Rights and Choices – Deletion and Correction Request Rights – California Consumers.

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 consumer request (see “Exercising Access, Data Portability, Deletion and Correction Rights – California Consumers” below), we will delete (and direct our service providers to delete) your personal information from our (and service provider) records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products or services to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another California consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
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.
Enable solely internal uses that are reasonably aligned with California consumer expectations based on your relationship with us, such as future field campaigns or product safety issues.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

In addition, if you provide us with a verifiable consumer request to correct inaccurate personal information that we maintain about you, we will use commercially reasonable efforts to correct such information in accordance with your instructions.

Exercising Your CPL Rights and Choices – Exercising Access, Data Portability, Deletion and Correction Rights – California Consumers.

To exercise the access, data portability, deletion and correction rights described above, you should submit a verifiable consumer request to us by one of the following methods:

Emailing us at info@goEBT.com.
By postal mail at 1200 Williams Drive, Suite 1200, Marietta, GA 30066.
Accessing your online account that you maintain with us.
By calling us at [TELEPHONE NUMBER].

Only you, or someone legally authorized 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 a minor child for whom you are a parent or legal guardian.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include:

Your name
Your address
Additional information depending upon the type of request and the sensitivity of the information involved with such request
Describe your request with sufficient detail to enable us to properly understand, evaluate and respond to such request.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm that the personal information involved with the request relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we will consider requests made through a password-protected online account that you maintain with us to be sufficiently verified when the request relates to personal information associated with that online account, provided such online account functionality is then made available by us on the Platform.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Exercising Your CPL Rights and Choices – Response Timing and Format – California Consumers

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an online account with us, we may deliver our written response to that online account, provided that such online account functionality is then made available by us on the Platform. If you do not have an online account with us, or such functionality is not available for your online account we will deliver our written response by mail or electronically, at your option.

If we’re unable to comply with your request, the response we provide will also explain the reasons we cannot comply with the request. For data portability requests, we will select a format to provide your personal information that is readily usable 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 consumer 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 – Notice to California Consumers.

We will not discriminate against you for exercising any of your CPL rights. Unless permitted by the CPL or other applicable law, we will not as a result of you exercising any of your rights under the CPL:

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; 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.

However, we may offer you certain financial incentives permitted by the CPL that can result in different prices, rates, or quality levels. Any CPL-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Retention of Personal Information – Notice to California Consumers.

Other California Privacy-Related Disclosures

Sharing Personal Information for Direct Marketing Purposes. Before sharing personal information of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out.

California Do-Not-Track Disclosure. At this time, the Platform is not set up to honor web browser do-not-track settings. Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.

Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at: (i) by email (writing “Privacy Policy/Removal Request” in the subject line), or (ii) by regular mail, as applicable, by using the contact information under “Contact Us” below.

Content Removal Requests for Platform Users Under 18 Years Old. If you are a user of the Platform under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on the Platform. You may send us any such requests by one of the following methods: (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at info@goEBT.com, or (ii) by regular mail at 1200 Williams Drive, Suite 1200, Marietta, GA 30066. We will review the request and respond promptly. You should be aware that a request to remove content or information posted by you on the Platform does not ensure or require complete or comprehensive removal of such content or information from our databases.

Complaints

If you have any complaint about use of the Platform, you may contact the Company in writing via email or regular mail by using the contact information under “Contact Us” below. In accordance with California Civil Code Section 1789.3, California residents may also file complaints with the Complaint Assistance Unit, Division of Consumer Services, California Department of Consumer Affairs by postal mail at 1625 North Market Road, Suite N112, Sacramento, CA 95834 or by telephone at 800-952-5210.

Changes to Our California Notice

We reserve the right to amend this California Notice at our discretion and at any time. When we make changes to this California Notice, we will post the updated California Notice on the Platform and update the California Notice’s effective date. Your continued use of the Platform following the posting of changes constitutes your acceptance of such changes.

Your EU Privacy Rights

Persons who are residents of the member countries of the European Union (“EU”) or other data subjects covered by the EU’s General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), have certain additional privacy rights under applicable law. The following provisions of this Policy provide an overview of these additional rights.

Legal Bases for Processing Personal Information of European Union Data Subjects

When processing your personal information, the Company may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:

Legitimate Interests. We may process your personal information where the Company has a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.
We may process your personal information where the Company has obtained your consent to the processing.
Contractual Necessity. We may process your personal information where such processing is necessary in connection with any contract that the Company has with you.
Legal Requirements. We may process your personal information where such processing is required by applicable law.

Disclosures to Third Parties of European Data Subject Personal Information.

Your personal information will not be disclosed to third parties except for where it is necessary for fulfillment of the Company’s obligations to you or where the Company is obliged or permitted to do so by law (including, without limitation, through the terms of any agreement the Company may have with you), or where the Company makes disclosures that are otherwise consistent with the uses described in this Policy.

The Company may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.

The Company reserves the right to transfer any personal information the Company has about you in the event the Company sells or transfers all or a portion of our business or assets, or merges with another organization. Should such a sale, transfer or merger occur, the Company will use reasonable efforts seeking to require that the transferee uses personal information you have provided to the Company in a manner that

is consistent with this Policy.

We will not sell, resell or lease your personal information to any third parties but the Company may, if required for the purpose(s) for which your personal information was collected and processed, share it with the Company partners and/or service providers to enable them to provide their services to the Company or to you, as applicable. The foregoing are in addition to the other uses described elsewhere in this Policy.

Security of Personal Information of European Citizens

The Company has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although the Company will use reasonable efforts to protect your personal information, the Company does not warrant the security of personal information transmitted to the Company or stored by the Company, and personal information that is transmitted to the Company by you electronically is done at your own risk.

Retention of Personal Information of European Data Subjects.

Our policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which the Company collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which the Company is subject. To determine the appropriate retention period for personal information, the Company considers the scope, 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 the Company collected and processed your personal information and whether the Company can achieve those purposes through other means, and any applicable legal and professional requirements.

Your Rights as a European Data Subject.

You have a number of rights concerning your personal information that the Company holds and uses, including the following:

Right of Access. You have the right to be informed about what personal information the Company holds about you and to a copy of this personal information.
Right to Rectification. You have the right to have any inaccurate personal information which the Company holds about you updated or corrected.
Right to Erasure. In certain circumstances you may request that the Company delete the personal information that the Company holds about you.
Right to Complain. You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in your country.
Right to Withdraw Consent. Where processing of personal information is based on your consent, you have the right to withdraw such consent at any time.
Right to Object. Where the Company relies on our legitimate interests to process your personal information, you have the right to object to such use and the Company is required to discontinue such processing unless the Company can demonstrate an overriding legitimate interest in such processing.
Right to Restriction. You have the right to request that the Company stop using your personal information in certain circumstances including if you believe that the personal information the Company holds about you is inaccurate or that the Company’s use of your personal information is unlawful. If you validly exercise this right, the Company will store your personal information and will not carry out any other processing until the issue is resolved.

You may exercise any of the above requests in writing to the Company via email or regular mail by using the contact information under “Contact Us” below.

Contact Us

If you have any questions about matters addressed in this Policy, please contact us by one of the following methods:

By Mail: CDE Services, LLC

Attn: Privacy Policy
1200 Williams Drive, Suite 1210
Marietta, GA 30066

By E-mail: info@goEBT.com