Privacy Policy

ECS Tuning, LLC (DBA Rennline Automotive) - PRIVACY POLICY

Last Updated: July 14th, 2026

This Privacy Policy (“Policy”) explains how ECS Tuning, LLC (DBA Rennline) (“Company,” “we,” “us,” and “our”), located at 1600 240th St, Harbor City, CA 90710, as data controller collects, uses, maintains, protects, and discloses information about you through your access to or use of the www.ecstuning.com, or other websites, platforms, and online services that link to this Policy (collectively, the “Services”) or otherwise interact or communicate with us.

Please read this Policy carefully. If any term in this Policy is unacceptable to you, please do not use our Services or provide us with any personal information. By using our Services, you acknowledge and understand that your personal information will be processed as described in this Policy.

If you obtain your use of the Services in connection with the services offered by a third party, or click on links to and from our website, the individual terms of that third party and its own privacy policy may differ from what is described in this Policy. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites. These third-party websites and apps may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal information. We are not responsible for the practices of such websites and apps.

Changes to this Policy

We may change this Policy from time to time. If we make any changes to this Policy, we will change the “last updated” date above. We encourage you to check this Policy whenever you use any of the Services or otherwise interact with us to understand how your personal information is used and the choices available to you. By continuing to access the Services after such change, you acknowledge that the updated Policy applies to your use of the Services.

Collection of Information
Use of Information
Disclosure of Information
Links and Social Sharing Features
Use of Cookies
Data Retention
Network and Information Security
Your Choices
Additional Information for Residents of California
Additional Information Residents of Other U.S. States
Additional Information for Individuals in the EEA / UK /Switzerland
Contact Us

COLLECTION OF INFORMATION

We collect information from you in various ways when you use our Services. This may include information defined as personal data, personal information, or personally identifiable information under applicable law (“personal information”). We may also supplement this information with information from other companies and we also collect aggregate data. Aggregate data is information we collect about a group or category of services or users from which individual user identities have been removed.

Aggregate data helps us understand trends in our users’ needs so that we can better consider new features or otherwise tailor our Services.

Information You Provide to Us

We collect personal information you provide directly to us. Depending on your relationship with us, we may collect the following categories of personal information from you:

Personal and Contact Details: Such as your name, email address, shipping and billing address, phone number, demographic information, employer information such as company name, company title, a copy of your military or similar government ID for certain discounts (if applicable), and other personal information you provide.
Account Information: Such as the username and password or other login credentials you use to register with our Services or log into your account.
Payment and Transaction Information: Such as your order details, purchase and return or exchange history, and loyalty points or other reward information. Our third-party payment processors may also collect your payment card and billing information to process your transactions with us.
Communications: Information you provide when you communicate with us, including via email, by phone, or through our chat or other interactive features, such as when you contact us with questions, provide feedback, or otherwise correspond with us through the Services. This information may also include information you upload to our Services such as photos or other media you elect to share.
Contests, Promotions, Sweepstakes, and Surveys: From time to time, you may be able to participate in contests, giveaways, sweepstakes, surveys, or other similar promotions that we, or third parties, may sponsor. When you participate in these initiatives, we may collect personal information such as name, contact information, product or service reviews, and survey or contest responses or submissions.
Other: Any other information you choose to provide.

Information Collected from Other Sources

If someone chooses to place an order on your behalf and/or send you a gift, we may receive your personal information, including your name and email address, from the person placing the order. As noted above, we also may collect personal information about you from our partners and other companies (and their service providers and contractors) including analytics and marketing partners. In addition, we may obtain information you have made publicly available, including from websites and online services you use, consumer research platforms, and/or business contact databases.

Automatic Data Collection

When you access or use our Services, we and our service providers may automatically collect information about you, your device, and your interactions with our Services, including:

Usage Data: This may include the pages or screens you viewed, the website(s) you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and whether you have opened or otherwise engage with our communications, such as our marketing emails, and what kind of content you’re interested in.
We utilize cookies or similar tracking technologies to collect information about your interactions with our website. This enables us to personalize your experience, for instance, by sending shopping cart reminders via SMS message if you have opted into our SMS service.
Device and Network Data: We automatically collect information about the device you use to access our Services, such as your device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet, etc.), IP address, general location (e.g., data derived from your IP address), unique identifiers, and language settings. We also collect information about any rehabilitee protocols you may be using.
Location Information: We may also collect information about your location, including your city, state, zip or postal code or your precise geolocation (if applicable) to personalize content provided to you, or to show you prices and promotions.

We collect this information using cookies, pixels, and similar technologies. For more information, please see Section 4.

Children’s Privacy

Protecting children’s privacy is important to us. We do not direct our Services to, nor do we knowingly collect any personal information from, children under the age of 16. If you are under 16, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Policy by instructing their children to never provide personal information through the Services without their permission. If we learn that a child has provided personal information through our Services, we will use reasonable efforts to remove such information from our files. If you think we might have any information from or about a child, please contact us via our contact details in Section 14.

USE OF INFORMATION

Our collection and use of your personal information depends on the manner and purpose for which we have collected it. In general, we may use your personal information for the following purposes:

Provide and maintain the Services, including to provide you with any products or services you purchase from us or otherwise request and enable you to use our Services;
Facilitate account creation and authentication and otherwise manage your accounts with us;
Process your requests or transactions, including to fulfill and manage your orders, payments, returns, and exchanges made through the Services;
Communicate with you, including to respond to emails, submissions, comments, requests, complaints, or other inquiries, and provide customer support, and inform you about other information, events, promotions, products, or services we think will be of interest to you (including through marketing communications and our use of targeted advertising);
Assist with the registration and provision of any contests, sweepstakes, or promotions, including to enable you to participate in any loyalty programs or similar offerings;
Request feedback and to enable us to develop, customize, and improve our Services;
Notify you of changes to our products or services;
Perform our duties in the context of our commercial or business relationship with you;
Improve and manage our Services and your customer or user experience, including by researching and evaluating our Services, products, and marketing, and understanding your use of our Services, including through session replay;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to protect the rights and property of the Company and others;
Comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights;
For compliance management;
For other purposes about which we notify you in advance or with your consent.

Please note that we do not collect, use, or sell personal information for the purpose of training large language models.

Disclosure OF INFORMATION

We may disclose your personal information as follows or as otherwise described in this Policy:

Service Providers. We may disclose your personal information with third-party companies and individuals that perform services on our behalf or help us operate our Services (including third-party hosting providers, payment processors, and fraud detection and prevention providers) such as for customer service, email and chat services, data analytics, newsletters and other communications, loyalty or rewards programs, advertising, or other services.
Professional Advisors. To accountants, auditors, lawyers, and other outside professional advisors to the Company, subject to appropriate contractual obligations of confidentiality.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Advertising and Other Third Parties. Third parties, such as advertising companies, social media providers, search engines and data providers, for interest-based advertising and other marketing purposes. These third parties may use the information we share to develop and improve their services, including to improve their ability to target ads on our and their other clients’ behalf. We do not endorse and are not responsible for the content of any such external website or for social sharing features provided by third parties. Please refer to the terms of use and privacy notices of the external website or feature for more information. To learn about your choices, please see the “Your Privacy Rights and Choices” section below.
Legal Purposes. We may disclose your information to third parties, including authorized government agencies and local or foreign financial, tax, administrative, criminal or judicial, or public authorities or institutions, where required by law, court order, or subpoena if we believe disclosure is in accordance with, or required by, applicable law or legal process or where necessary to prevent, detect, or prosecute criminal offenses, or to protect the rights, property, and safety of the Company or others.
Business Transfers or Reorganization. We may share or transfer your personal information in connection with any direct or indirect reorganization process including, but not limited to, an acquisition, merger, divestiture, or sale of all or part of our business to another company (including, in connection with a bankruptcy or similar proceedings).
Affiliates and Subsidiaries. Between and among the Company and our current and future parents, affiliates, subsidiaries, and other group companies under common control and ownership.
Your Consent or Direction. With your consent or at your direction, including through your use of the Services in a public forum, such as a discussion forum or product reviews. Where you choose to utilize such features of the Services, other users of the Services may be able to see personal information you disclose, such as your location, interests, occupation, and birthday, and they can post comments in response to certain of your public submissions.

Please note we may disclose certain categories of personal information including identifiers, commercial information, and internet or other similar network activity to show you targeted advertisements on third-party properties and to expand the reach and effectiveness of our own marketing campaigns. These activities may be considered “sales,” “sharing,” or “targeted advertising” under certain state privacy laws.

This Policy in no way restricts or limits our collection and use of fully anonymized data, and we may disclose anonymized data with third parties for various purposes, including to help us better understand our customer needs and improve our Services, to provide new Services, and for advertising and marketing purposes.

USE OF COOKIES AND OTHER AUTOMATED TECHNOLOGY

Our Services use first- and third-party single-session and multi-session cookies, log files, plugins, pixels, software development tools, and web beacons (collectively, “Cookies”). A Cookie is a small amount of data which is sent to your browser and stored locally on your device. We may store Cookies on your device when you use our Services. These technologies help us speed up your future activities and improve your experience by remembering the information that you have already provided to us.

Third parties operating on our behalf, including social media and other internet-based advertising companies, may also use these technologies to provide us with information regarding your use of our Services, as well as to help us manage and display advertisements, tailor advertisements to your interests, or send abandoned shopping cart reminders.

Our use of your personal information for the purposes described in this section is based on our legitimate business interests to promote our Services, except where your consent is required by applicable laws. For more information on how you can manage these technologies from your device, please review our Cookie Policy and see the “Your Privacy Rights and Choices” section below.

DATA RETENTION

We may retain your personal information for as long as needed to carry out the purposes described herein or as otherwise required by applicable law. Unless we are required or permitted by law to keep your personal information for a longer period of time, when your personal information is no longer necessary to carry out the purposes for which we process it, we will delete your personal information or keep it fully anonymized. When determining the retention period, we take into account various criteria, such as the nature of the use of our Services, your general relationship with us, the impact on our ability to provide you Services if we delete your personal information, mandatory retention periods provided by law and the statute of limitations, and our use of your personal information for aggregated market research.

NETWORK AND INFORMATION SECURITY

We take reasonable steps to protect information we collect from you to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction.

It is important that you protect against unauthorized access of your password and computer, and be sure to sign off when finished using a shared computer. While we take reasonable efforts to protect personal information, no security system is impenetrable. In addition, we cannot guarantee that any collected personal information you choose to include in the Services is maintained at adequate levels of protection to meet specific needs or obligations you may have relating to that information.

International Data transfers

To provide the Services, we may transfer your information to our servers in the United States and possibly to other countries.
For international data transfers subject to EEA, UK, and Swiss law: When we transfer information from the EEA, the UK, or Switzerland to countries that have not been deemed to provide an adequate level of protection, we will either rely on a derogation applicable to the specific situation, or we employ data processing agreements based on the EU Standard Contractual Clauses (with appropriate modifications for Switzerland where applicable) to help ensure that your data is protected wherever it is transferred. You may request a copy of these clauses by contacting us at [email protected].
For international transfers between other jurisdictions: We may rely on other legal mechanisms for international transfers as appropriate under applicable law.

Data Privacy Framework

ECS Tuning, LLC (DBA Rennline) as part of Enthusiast Auto Holdings, LLC (the parent company of ECS Tuning, LLC, Turner Motorsport, LLC, Pelican Parts, LLC, Rennline Automotive, Texas Speed & Performance, LLC, Z1 Motorsports, LLC, Z1 Off-Road, Teqsport, Teslaaccessories, LLC, and RCI Metalworks, LLC) complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. ECS Tuning, LLC (DBA Rennline) has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal information received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. ECS Tuning, LLC (DBA Rennline) has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
As disclosed herein, we sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the EU-US DPF, UK Extension to the EU-US DPF, and the Swiss-US DPF to a third party, we may be liable if such third party fails to meet its obligations under the EU-US DPF, UK Extension to the EU-US DPF, and the Swiss-US DPF unless we prove we are not responsible for the event giving rise to the damage. ECS Tuning, LLC (DBA Rennline) is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”). We may be required to disclose personal information that we handle under the EU-US DPF, UK Extension to the EU-US DPF, and the Swiss-US DPF in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have any questions or complaints regarding our participation in the EU-U.S. DPF, the UK Extension of the EU-U.S. DPF and the Swiss-U.S. DPF or the processing of your personal information you may contact us as indicated below in the section of this Policy “Contact Us.”

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, ECS Tuning, LLC (DBA Rennline) commits to refer unresolved complaints concerning our handling of personal information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (“ICDR-AAA”) as an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services provided through this link are offered at no cost to you.

In certain cases, when all other dispute resolution mechanisms have been exhausted, you may also have the possibility to engage in binding arbitration through the applicable DPF panel. To learn more, please visit https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

YOUR PRIVACY RIGHTS AND CHOICES

Account Information

If your personal information changes in any way, we encourage you to update and correct your account information by logging into your account, emailing us at [email protected], or calling us at 213-224-7393. If you wish to delete your account, please email us at [email protected] but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a limited period of time.

Cookies/Automatic Tracking Technologies

As noted above, our Services may use cookies and other automatic data collection technologies. You may block or delete these technologies from your device. However, by disabling such technologies, you may not have access to the entire set of features of our Services. For more information about cookies, including links to web browser instructions for disabling and managing such technologies, visit https://thenai.org/how-to-opt-out/. For more information about interest-based ads in particular, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit https://optout.aboutads.info/ in the United States and http://www.youronlinechoices.eu in the European Union.

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Promotional Communications

The Company may send you electronic communications or data regarding our Services taking into account applicable consent requirements, including but not limited to (i) notices about your use of our Services, including any notices concerning violations of use, (ii) updates, and (iii) promotional information and materials regarding our Services. You may opt out of receiving promotional emails from the Company by following the opt-out instructions provided in those emails. You may also opt out of receiving promotional emails and other promotional communications from us at any time by emailing [email protected] with your specific request. Opt-out requests will not apply to transactional service messages, such as security alerts and notices about your current account and Services.

Text Messages

With your consent, we may send marketing and/or non-marketing communications by text message (e.g., SMS and MMS). You are not required to consent to such communications as a condition of purchasing products or services, and you may revoke your consent at any time by replying “STOP” (or similar revocation language as permitted under applicable law) to the text message you receive from us or by contacting us via the methods described in the “Contact Us” section below. Please note that you may be subscribed across different short codes used by the Company, and therefore you must separately submit an opt-out request to each short code from which you wish to unsubscribe. After revoking consent, you may receive a confirmation text that you have been opted out.

Please note, we will not share your text messaging opt-in data and consent with any third parties for their marketing purposes. However, as indicated in the “Disclosure of Information” section above, we may disclose this information to third parties that support our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

Additional Information for Residents of CALIFORNIA

Residents of California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act (California Civil Code Section 1798.100 et seq.), as amended by the California Privacy Rights Act (Civil Code Section 1798.100, et seq.) (collectively, “California Law”). This section supplements this Policy and applies solely to eligible residents of California. Any terms used but not defined in this section have the same meaning as defined in California Law.

Subject to certain exceptions, these rights include:

Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your personal information, including 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, disclosing, selling, or sharing that personal information; the categories of third parties with whom we disclosed, shared, or sold that personal information; and the specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained.

Right to Correct Inaccurate Personal Information: You have the right to request that we correct any inaccuracies in the personal information that we maintain about you.

Right to Opt Out of the Sales or Sharing of Personal Information: We do not, and will not, sell the personal information of our customers for direct, monetary profit. However, we may engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. If we sell or share such information with third parties, you have the right to opt out of the selling or sharing of your personal information. [To exercise the right to opt out, you (or your authorized representative) may submit a request to us by visiting the Your Privacy Choices link in the footer of the website.]

Right to Non-Discrimination or Retaliation: Unless permitted by applicable law, we will not retaliate or discriminate against you for exercising any of your privacy rights under California Law.

Exercising Your Rights as a Resident of California

If you are a California resident and would like to exercise any of your privacy rights as described in this section, please submit a request to us by using any of the following methods:

Emailing us at [email protected]
Calling us at 213-224-7393
Submitting a request via our webform, available at https://www.surveymonkey.com/r/KVMZ3JG

In addition, to the extent you have provided consent for our collection and/or processing of your personal information and wish to revoke that consent, please contact us via the methods described in the section “Contact Us.”

To exercise your right to know, delete, or correct, as described above, we need to verify your identity or authority to make the request and confirm the personal information relates to you. To verify your identity, we may ask you to provide your full name, telephone number, and address. We will only use personal information provided in your consumer request to verify your identity or authority to make the request.

Only you, your parent or guardian, a natural person or person registered by the Secretary of State authorized to act on your behalf, a conservator, a person to whom you have given power of attorney, or an authorized agent may make a verifiable consumer request related to your personal information. You also may make a verifiable consumer request on behalf of your minor child, if necessary. When an authorized agent is submitting a request on your behalf, we may require your authorized agent to provide evidence of their entitlement, which may include information sufficient to identify you and the purpose of the request and a written and signed permission designating the authorized agent to act on your behalf. You may also be required to verify your identity with us or directly confirm with us that you have provided the authorized agent permission to submit the request. Absent proper documentation or proof of authority, we reserve the right to refuse to comply with third-party requests, in accordance with applicable law. Please note that you may only make a verifiable consumer request for your right to access twice within a 12-month period.

Notice at Collection/Additional Disclosures Related to the Collection, Use, and Disclosure of Personal Information

In the preceding twelve (12) months, we have collected the following categories of personal information directly from consumers, automatically when consumers use the Services, or from other third-party sources, such as publicly-available sources and databases, in accordance with applicable law, or from those who place an order on a consumer’s behalf or purchase a gift for a consumer, as discussed in further detail in the section titled “Collection of Information.”

Data Category Collected	Primary Purpose for Such Collection/Use	Sold or Shared?
Identifiers: Name, shipping and billing address, online and device identifiers, IP address, email address, phone number, account credentials, and military or similar government ID.	Provide and maintain the Services (including account creation, authentication, and administration); process requests and transactions made through the Services; communicate with you including requests for feedback and to notify you of changes to our products and services; marketing and advertising; improve, monitor, manage, and personalize our Services and your customer or user experiences; perform our duties in the context of our commercial or business relationship with you; protect our Services; comply with our legal obligations	Yes
Personal information described in California Civil Code Section 1798.80(e): Name, shipping and billing address, telephone number, military or similar government ID number, employment, and credit card number or any other financial information.	Provide and maintain the Services (including account creation, authentication, and administration); process requests and transactions made through the Services; communicate with you including requests for feedback; marketing and advertising; improve, monitor, manage, and personalize our Services and your customer or user experiences; perform our duties in the context of our commercial or business relationship with you	No
Commercial information: Records of products or services purchased, obtained, or considered, purchase price, date and location of transaction, and other purchasing or consuming histories or tendencies.	Provide and maintain the Services (including account creation, authentication, and administration); process requests and transactions made through the Services; marketing and advertising; improve, monitor, manage, and personalize our Services and your customer or user experiences	Yes
Internet or other electronic network activity information: Browser type and language, operating system and version, hardware model, account activity, files/pages accessed, access times, referring website address, information about any rehabilitee protocols, browsing history, search history, and information regarding interactions with a website, application, or advertisement.	Improve, monitor, manage, and personalize our Services and your customer or user experiences; marketing and advertising; protect our Services	Yes
Geolocation data	Provide and maintain the Services; improve, monitor, manage, and personalize our Services and your customer or user experiences; marketing and advertising	Yes
Audio and visual information: Photos/videos uploaded and recorded phone calls.	Provide and maintain the Services (including account creation, authentication, and administration); communicate with you including requests for feedback and to notify you of changes to our products and services; improve, monitor, manage, and personalize our Services and your customer or user experiences	No
Professional and employment-related information: Company name and title.	Provide and maintain the Services	No
Inferences drawn from the above personal information to reflect your preferences.	Improve, monitor, manage, and personalize our Services and your customer or user experiences; marketing and advertising; protect our Services	No
Sensitive personal information: Personal information revealing state ID or similar ID card number and account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.	Provide and maintain the Services (including account creation, authentication, and administration); improve, monitor, manage, and personalize our Services and your customer or user experiences	No

Please note that we only use and disclose sensitive personal information as permitted under California Law and/or without the purpose of inferring characteristics about a consumer.

Disclosures, Sales, and Sharing of Personal Information:

Disclosures. In the preceding twelve (12) months, we have disclosed the personal information categories identified in the table above and “Collection and Use of Information” section to the following categories of service providers, contractors, and third parties for a business or commercial purpose:
Service Providers or Contractors: We may disclose your personal information to our service providers or contractors (including third-party hosting providers, payment processors, and fraud detection and prevention providers) that provide services on our behalf, such as for customer service, email and chat services, data analytics, newsletters and other communications, loyalty or rewards programs, and advertising, or other services.
Internally: We may disclose your personal information to our current and future parents, affiliates, subsidiaries, and other group companies and employees under common control and ownership who require such information to assist us with establishing, maintaining, and managing our business relationship with you.
Professional Advisors: We may disclose your personal information to accountants, auditors, lawyers, and other outside professional advisors to Company.
In the Event of a Business Transaction or Reorganization: We may share or transfer your personal information in connection with any direct or indirect reorganization process including, but not limited to, an acquisition, merger, divestiture, or sale of all or part of our business to another company (including, in connection with a bankruptcy or similar proceedings).
For Legal Purposes: We disclose your personal information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury, or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant, or similar legal process; or if necessary to assert or protect our rights, assets, or safety, or the rights, assets, or safety of others.
With Your Consent or at Your Direction: We disclose your personal information if you provide consent or authorization to do so.
Other: We may disclose your personal information to any other third party for such purposes as disclosed by us in this Policy or when you provide your information.
Sales and Sharing. The Company does not, and will not, sell personal information of our customers for direct, monetary profit. However, we may engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. In the preceding twelve (12) months, we have sold or shared the following categories of personal information to the categories listed below and for the following purpose:

Category	Business or Commercial Purpose	Categories of Third Parties to Whom Personal Information was Disclosed That May be Considered “Sales” or “Sharing” Under California Law
Identifiers.	To provide you with personal advertising and content	Advertisers and advertising networks Business partners or affiliates
Commercial information.	To provide you with personal advertising and content	Advertisers and advertising networks Business partners or affiliates
Internet or other similar network activity.	To provide you with personal advertising and content	Advertisers and advertising networks Business partners or affiliates

We do not knowingly sell or share the personal information of consumers under 16 years of age.

Data Retention

Shine the Light

In addition to your rights under California Law, California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure, if any, of their personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information disclosed and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2026 will receive information about 2025 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide a current California address for our response. If you are a California resident and would like to make such a request, please contact us as described in Section 14.

Additional Information for RESIDENTS OF Other U.S. States

Eligible residents of states in which there is a comprehensive privacy law in effect, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, also have rights with respect to the personal information that we collect about you. This section supplements this Policy and applies solely to eligible residents of U.S. states with applicable comprehensive privacy laws in effect. Any terms not defined in this section have the same meaning as defined under applicable law. Subject to certain exceptions, if you are an eligible resident of one of these states, you have certain privacy rights which may include, depending on your state of residency:

Right to Know/Access: You have the right to confirm whether Company processes your personal information and the right to access such personal information. You also have the right to obtain your personal information in a portable, and to the extent reasonable feasible, readily usable format that you can transmit without hindrance. In addition, Delaware and Maryland residents have the right to obtain a list of the categories of third parties to which we have disclosed their personal information, and Connecticut, Minnesota, and Oregon residents have the right to receive a list of specific third parties to which we have disclosed any personal information.
Right to Delete: You have the right to request that Company delete the personal information you have provided to us or that Company has otherwise obtained about you.
Right to Correct: You have the right to request that Company correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
Right to Opt Out: You have the right to opt out of the processing of your personal information for the purposes of (i) targeted advertising, (ii) the sale of your personal information, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.

Please note that we do not engage in such profiling as defined under applicable law, but we may sell or use your personal information as described in Section 3 “Disclosure of Information” for targeted advertising purposes.

Right to Appeal: You have the right to appeal Company’s decision with regard to your request to exercise any rights described herein.

The exact scope of these rights may vary by state. You do not need to create an account with us to exercise your state privacy law rights. If you would like to exercise the rights described in this Section 11, including the right to opt out, please submit a request to us using any of the following methods:

Emailing us at [email protected]
Calling us at 213-224-7393
Submitting a request via our webform, available at https://www.surveymonkey.com/r/KVMZ3JG

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA / UK / Switzerland

If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, this section applies to you, and describes certain rights and protections you may have under applicable law regarding the processing of your personal information.

Legal Bases and Purposes for Processing

The following table summarizes our processing of your personal information as further described in this Policy.

Processing Purpose(s)	Data Categories	Legal Basis
Provide and maintain the Services	Basic identifiers and personal details, account credentials, financial information, commercial information, internet or other similar network activity, communication data, views and opinions, geolocation data, inferences drawn from other personal information, sensitive personal information	Performance of a contract or consent (if required under applicable law)
Facilitate account creation, authentication, and administration	Basic identifiers and personal details, financial information, commercial information, internet or other similar network activity	Performance of a contract
Process requests and transactions	Basic identifiers and personal details, financial information, commercial information	Performance of a contract
Communicate with you	Basic identifiers and personal details, internet or other similar network activity	Performance of a contract
Assist with the registration and provision of any contests, sweepstakes, or promotions	Basic identifiers and personal details, communication data, views and opinions	Performance of a contract
Request feedback and enable us to develop, customize, and improve our Services	Basic identifiers and personal details, communication data, views and opinions	Consent or legitimate interest in improving our Services
Notify you of changes to our products or services	Basic identifiers and personal details	Performance of a contract
Send you marketing and promotional communications	Basic identifiers and personal details	Consent
Perform our duties in the context of our commercial or business relationship with you	Basic identifiers and personal details, commercial information	Performance of a contract
Improve and manage our Services and your user experience	Basic identifiers and personal details, commercial information, internet or other similar network activity, communication data, views and opinions, geolocation data, inferences drawn from other personal information	Consent or legitimate interest in improving our Services
Comply with our legal obligations, respond to legal requests, and exercise, establish or defend our legal rights	Basic identifiers and personal details, financial information, commercial information, internet or other similar network activity, communication data, views and opinions, geolocation data, inferences drawn from other personal information, sensitive personal information	Comply with our legal obligations
Protect our Services	Basic identifiers and personal details, internet or other similar network activity	Consent or legitimate interest in maintaining our Services
Strictly necessary cookies	Internet or other similar network activity	Legitimate interest in providing our Services as requested by you
Non-strictly necessary cookies	Basic identifiers and personal details, internet or other similar network activity	Consent
For any other purpose with your consent	Basic identifiers and personal details, financial information, commercial information, internet or other similar network activity, communication data, views and opinions, geolocation data, inferences drawn from other personal information, sensitive personal information	Consent

Data Subject Rights

If you are a resident of the EEA/UK or Switzerland (or if the GDPR, UK GDPR, or Swiss law are otherwise applicable to you), subject to certain exceptions, you have certain rights regarding the personal information we hold about you:

Right to Object: You have the right to object to certain types of processing of your personal information, including processing for direct marketing purposes. You may also have the right to object where you data is being processed for purposes of our legitimate interests.
Right to Access: You have the right to access your personal information and to request a copy of the personal information undergoing processing.
Right to Data Portability: You have the right to obtain from us, under certain circumstances, your personal information in a structured, commonly used and machine-readable format and to transfer this personal information to another controller or, if technically feasible, to have it transferred by us.
Right to Restrict: You have the right, under certain circumstances, to block or restrict our processing of your personal information.
Right to Rectification: If your personal information is inaccurate or incomplete, you have the right to request rectification or completion of your personal information. Where exercising this right, please let us know if, and to what extent, your data stored by us has changed, so that we can rectify or update it accordingly.
Right to Erasure/Deletion: You have the right, under certain circumstances, to request the erasure of your personal information from our systems.

Right to Withdraw Consent: If our processing of your personal information is based on your consent, you have the right to withdraw that consent at any time with effect for the future. Your withdrawal of consent will not, however, affect the lawfulness of the previous processing of your data based on such consent.

Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way

If you would like to exercise any of these rights, please contact us at [email protected] or via phone at 213-224-7393.

Complaints

If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or work or where the alleged infringement took place. For contact details of your data protection authority, please see: for EU residents, https://www.edpb.europa.eu/about-edpb/about-edpb/members_en; for UK residents, see https://ico.org.uk/make-a-complaint/; and for Swiss residents, see https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

Additional information for residents of other jurisdictions

To the extent you are located in a non-U.S. jurisdiction with laws that are applicable to the Company, including Mexico and Canada, this section shall apply to you.

As provided in this Policy, the Company may share your personal information with third parties to provide the Services or as otherwise described herein. Please note that some of these third parties may be located outside of your country of residence or location and therefore, your personal information may be transferred abroad. For further information regarding our data processing and disclosure practices, please see the “Use of Information” and “Disclosure of Information” sections above.

Depending on your location or country of residence, and subject to certain exceptions and limitations, you have may certain rights regarding the processing of your personal information under applicable law, including the right to:

(i) access your personal information in our possession and know the details of its processing;
(ii) rectify your personal information if it is inaccurate, incomplete, or has not been updated in accordance with applicable law;
(iii) cancel or delete the personal information maintained about you;
(iv) withdraw your consent when our processing of your data is based on such consent; or
(v) oppose or restrict the processing of your personal information for specific purposes.

While we encourage you to get in contact with us first to try and resolve your concerns, you may also have the right to file a complaint regarding our data protection practices with a supervisory authority/privacy regulator in your country/province of residence.

To exercise any of the above-mentioned rights, please contact us using the contact information provided below. Please note, in order to comply with applicable law, prior to fulfilling your request, we may require you to provide additional information and documentation including information necessary to verify your identity.

CONTACT US

If you have any questions about this Policy, please contact us at [email protected] or via phone at 213-224-7393 or contact our EEA/UK/Swiss representative at [email protected] or 213-224-7393.