Ntrepid Privacy Information

Ntrepid Privacy Notice
Supplemental California Privacy Notice
Ntrepid California Residents Rights Request Form

LAST UPDATED: June 10, 2022

Ntrepid, LLC (“Ntrepid” “we,” “our,” or “us”) Privacy Statement—Highlights

Here at Ntrepid we know how much you value privacy, and we realize that you care about what happens to the information you provide to us or that we collect through our website, products, mobile applications, email, and other sources (our “Systems”) as well as information collected from third parties. We have provided highlights below regarding how we collect, use, and share your information. For further information, see our full Privacy Statement.

With respect to our products, please note that the policies described in the Privacy Statement and this summary apply to personal data you provide in order for us to set up and administer your account. This personal data includes, but is not limited to, your name, role, username or other account ID, and details regarding any technical support requests. The Privacy Statement and this summary do not apply to content that you upload or import to our Systems while using Ntrepid products. Ntrepid processes such personal data as a data processor only, and such processing is therefore governed by the Terms of Service that you or your employer (or other organization) agree to when purchasing our products.

What Information Does Ntrepid Collect?

We collect the following types of information:

Information you provide to us when you interact with us or purchase our products and services, such as your contact information, information you provide when signing up for promotions, payment information, and product preferences.
Information required by Ntrepid to set up and administer individual user accounts for our products, such as your name, role, username or other account ID, and details regarding any technical support requests.
Information collected from job applicants when they respond to job listings, such as your name, contact information, and details of your education and experience.

Information that is automatically collected when you use our Systems, such as when you visit our website or cookie information.
Information about you that we receive from affiliates and other third party sources (including other users of our Systems).

How does Ntrepid use my information?

We use your information for the following purposes:

Providing products, content, content suggestions, services, and support;
Maintaining the security and integrity of our Systems (including maintaining internal records);
Establishing and verifying the identity and eligibility of users;
Assessing prospective employees and furthering the recruitment process;
Opening, maintaining, administering, managing, and servicing user profiles, accounts or memberships;
Processing, servicing or enforcing transactions (including credit or debit card transactions);
Providing users with product, service, Systems, or company updates;
Responding to your inquiries or comments, or contacting you as necessary;
Analyzing and improving our products, services, or Systems (including developing new products and services; improving safety; managing our communications; analyzing our products; performing market research and tracking our marketing effectiveness; performing data analytics; and performing accounting, auditing and other internal functions);
Conforming to legal requirements or industry standards, complying with legal process, detecting and preventing fraud or misuse, defending our legal rights, or protecting others;
As part of a merger, acquisition, transfer, sale, corporate change, bankruptcy, or any other transaction involving all or a portion of Ntrepid’s assets;
Conducting special events, sweepstakes, surveys, programs, contests, and other offers (and communicating with you about such events); and
Marketing and advertising our products or services as well as products and services of third parties (such as affiliates, subsidiaries, and business partners)

How does Ntrepid share my information?

We may share aggregated data about you that does not identify you directly with third parties for any purpose, including marketing. However, we will only share your personal information that specifically identifies you as follows:

With third party service providers, advisors, or business partners to help us with our business functions;
If necessary to protect the safety, property, or other rights of us, our users, or employees, or when required by law;
With your consent; or
If the ownership or control of Ntrepid or some or all of its assets changes (including through merger, acquisition, transfer, sale, corporate change, bankruptcy or any other transaction involving all or a portion of Ntrepid’s assets), we may transfer your information to the new owner.

Ntrepid Privacy Statement—Full Statement

Ntrepid, LLC (“Ntrepid,” “we,” “our,” or “us”) respects your concerns about privacy and values the relationship we have with you. This Privacy Statement describes the types of information we collect about and from individuals who visit our website, use our products, or otherwise communicate with us (collectively, “you”). This Privacy Statement also describes how we use the information, with whom we share it, the choices available to you regarding our use of the information, and how you can contact us about our privacy practices.

To What Information Does This Privacy Statement Apply?

This Privacy Statement applies to the collection, use, and disclosure of information from and about you by Ntrepid on Ntrepid’s website (www.ntrepidcorp.com), through our products, mobile applications, and through telephone, email communications, and other sources (collectively, our “Systems”), as well as information collected by third parties. For the purposes of applicable data protection legislation, Ntrepid is the data controller of such information. Ntrepid’s mobile applications will collect the same information identified in this Privacy Statement and that information will be used and shared as stated in this Privacy Statement.

This Privacy Statement does not apply to third party websites that may be accessible through hyperlinks on our Systems, which have their own privacy statement. Linking to a third party site does not mean that we endorse the site, any products or services described on the site, or any other material contained in a that site. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites. Please review the privacy statement on those other sites to see how they handle your information.

If you choose to use our Systems in any way, such as browsing or interacting, you acknowledge the terms of our current Privacy Statement as posted here. If you do not agree with this Privacy Statement, you should not use our Systems. We may update or modify this Privacy Statement from time to time at our sole discretion, and will note the date of last update on the top of this webpage with a corresponding effective date on the last webpage. We encourage you to visit this area frequently to stay informed, as your continued use of our Systems following the posting of changes to these terms constitutes your acknowledgement to such changes.

What Information Does Ntrepid Collect?

We may obtain information about you from various sources. We may collect this information when you provide it directly through our website, products, mobile applications, telephone or email communication, or at one of our events. We may also collect information about you from third parties. When you use our Systems, we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs, and web beacons.

You are not obliged to provide us with information about yourself. However, if you do not provide us with information that we need, we may be unable to provide you with our products and services, consider you for potential employment, or respond to any other correspondence that you send to us.

Information that You or Others Provide

You may choose to provide information to us in a number of ways, such as when you participate in an offer or promotion, when you register on our System, when you contact us, or when you otherwise use our products or interact on our Systems. You may also provide information to us if we interact with a company that you represent (e.g., if your employer is an Ntrepid customer or supplier). The types of information you may provide to us include:

Information required to register your use of our products and services or when you contact us, such as your name, address, city, state, ZIP or postal code, email address telephone number, and any other information that you provide;
Information needed to set up and administer your user account (such as your name, role, username or other account ID, and details regarding support requests);
Personal details and information about your previous and current roles, and relevant education and experience when you apply for a job with us;
Information provided voluntarily by you when signing up for promotions (such as birth date, household information, income, marital status, and education);
Financial and payment information if you use our Systems to make or receive payments (such as payment card number, expiration date, account number, and billing address); and
Product preferences, advertisement preferences, and other information about how you use our Systems.

If you provide us with information regarding another individual, we will assume that you have that person’s permission to give us his or her information and that you have provided them with a copy of this Privacy Statement. In addition, we may collect information about you that is provided to us by other users of our Systems and other third parties.

Information Collected Automatically

When you visit or use our Systems or our online advertisements, utilize our services, open an email that we send you, or interact with the communication features on our Systems, we may collect information about your usage or device by automated means or by using technologies such as cookies, web server logs, and web beacons. Some of the technologies we use to collect information automatically collected include:

Cookies: Cookies are small text files that websites and Ntrepid products may send to your computer or other Internet-connected device to uniquely identify your device or to store information or settings. With your consent, we may use cookies that are managed by Ntrepid or by third parties for the purposes provided in this Privacy Statement, including for session management, authentication, user preference storage, Systems performance and personalization, Systems analytics, advertising (including affiliate marketing), content management, eCommerce, search, and social media integration.
Web server logs: In conjunction with obtaining information through cookies, our web servers may log details regarding your device, operating system, or information about your usage of our Systems.
Web beacons & pixels: With your consent, we may place tags on our Systems or in emails called “web beacons” or “pixels.” These are computer instructions that link web pages to particular web servers and their cookies. Web beacons and pixels can be used to track the pages you view, links that you click, or other online behavior. These tools have a number of uses, such as measuring the effectiveness of our email campaigns and online advertisements (both on our Systems and on third party websites).
Other: In addition to cookies, web server logs, and web beacons, we may use other technologies to collect information for the purposes described in this Privacy Statement.

We will obtain your express consent before placing non-essential cookies or similar technologies on your device. For more information, please visit our Cookie Notice.

These technologies may permit collection of information such as demographic data, browser type, MAC address and other device information, operating system type and settings, domain, the address of the web page that linked you to our website, IP address, pages visited, whether you have visited us before or are new to the website, activities conducted on the page (such as search queries), and the day and time of your visit.

We also collect information about you and your interactions with social media and other third party websites, which we may merge or enhance with other information we collect about you for the purposes described in this Privacy Statement.

At this time, we do not honor “do not track” signals from website browsers. However, you may refuse or delete cookies. If you do so, some of the functionality of our Systems may be impaired. Additionally, you may still be identifiable and your usage may still be trackable by other means. Please refer to your browser “Help” instructions to learn more about how to manage cookies and the use of similar technologies on your web browser.

How Does Ntrepid Use My Information?

We use your information for the following purposes:

Providing products, content, content suggestions, services, and support;
Considering applications for roles with us and liaising with prospective employees;
Maintaining the security and integrity of our Systems, including maintaining internal records;
Establishing and verifying the identity and eligibility of users;
Opening, maintaining, administering, managing, and servicing user profiles, accounts or memberships;
Processing, servicing or enforcing transactions (including credit or debit card transactions);
Providing users with product, service, Systems, or company updates;
Responding to your inquiries, comments, or support updates and contacting you as necessary;
Analyzing and improving our products, services, or Systems (including developing new products and services; improving safety; managing our communications; analyzing our products; performing market research and tracking our marketing effectiveness; performing data analytics; and performing accounting, auditing and other internal functions);
Conforming to legal requirements or industry standards, complying with legal process, detecting and preventing fraud or misuse, defending our legal rights, or protecting others;
As part of a merger, acquisition, transfer, sale, corporate change, bankruptcy, or any other transaction involving all or a portion of Ntrepid’s assets;
Conducting special events, sweepstakes, surveys, programs, contests, and other offers (and communicating with you about such events); and
Marketing and advertising our products or services as well as products and services of third parties (such as affiliates, subsidiaries, and business partners).

What Legal Bases Does Ntrepid Rely On For Using My Information?

If you are located in the EEA or UK we will only process your personal data in accordance with applicable European data protection legislation, such as the GDPR. We will only process your personal data where:

The processing is necessary for the performance of a contract to which you are a party, or to take steps at your request to enter into a contract. For example, if you wish to utilize our products or services, we will need to process your personal data in order to negotiate and enter into the relevant agreement with you. We may also process your personal data on this basis to open, maintain, administer, manage, and service individual customer’s user profiles. This is also the legal basis we will rely upon when processing personal data to take steps to enter into an employment agreement with you where you have applied for a role.
The processing is necessary for compliance with a legal obligation to which we are subject. For example, establishing and verifying the identity of our users and ensuring compliance with anti-money laundering and anti-fraud legislation, and financial sanctions. We may also process your personal data in accordance with this basis where we are subject to a legally binding request for information from a regulator or law enforcement agency.
The processing is necessary for our legitimate business interests, or those of a third party. For example: (i) analyzing and improving our products, services, or Systems; (ii) responding to inquiries or comments, or contacting potential customers; (iii) opening, maintaining, administering, managing, and servicing enterprise user accounts in connection with our products; and (vi) as part of a merger, acquisition, transfer, sale, corporate change, bankruptcy, or any other transaction involving all or a portion of Ntrepid’s assets. We will always consider your fundamental rights and freedoms before initiating any processing based on this legal basis.
You have provided your consent for processing. For example, where you have signed up to our marketing list and consented to our use of your contact details for this purpose. Note that consent can be withdrawn at any time.

We do not anticipate routinely processing special categories of personal data as identified under the GDPR. We may, however, process such special category data in certain circumstances. This will ordinarily be done on the following basis:

You have provided your express consent for this processing (for example, by including special category personal data in any communications that you send to us).
The processing is necessary for the establishment, exercise, or defense of legal claims (for example where special category data is pertinent to an ongoing claim).
We are complying with specific obligations or exercising certain rights in relation to employment law (for example where we are considering health information needed to make reasonable adjustments, or when processing information regarding your religious beliefs or ethnicity for diversity monitoring).

We may share aggregated data about you that cannot be used to identify you directly with third parties for any purpose, including marketing. However, we will only share your personal information that can be used to specifically identify you as follows:

We may disclose your information to third parties who help us with our business functions, such as service providers or suppliers, and with business partners. Such third parties are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Examples of service providers include entities that process credit card and other types of payments, entities that provide web hosting or analytics services, or third party software providers, such as job applicant tracking systems.
We may contract with third-party advertising networks that collect information about you through the use of cookies, web server logs, and web beacons on our Systems and emails; on third-party websites and emails; and on our advertising placed on third-party websites. We and these third parties use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on other websites.
We may share your information if necessary to protect the safety, property, or other rights of us, our customers, or employees, or when otherwise required by law.
We may also share your information with your consent in certain circumstances.
We reserve the right to transfer your information in the event we sell, transfer, or engage in another transaction involving all or a portion of our business or assets, or undertake another form of corporate change, including bankruptcy. Following such a sale, transfer, transaction, or corporate change, you may contact the entity to which we transferred your information with any inquiries concerning the processing of that information.

Your information may be stored in databases maintained by Ntrepid (including local storage) or third parties, and may be disclosed to third parties for the purposes stated in this Privacy Statement, that are located within and outside the United States, including countries where privacy rules differ and may be less stringent than those of the country in which you reside. If you are located in the UK or EEA we will implement appropriate safeguards to protect your personal data following such a transfer. In most cases, this will be the standard contractual clauses approved by the European Commission or the UK Secretary of State as appropriate. For more detail about the particular appropriate safeguards used in relation to a specific transfer, please contact us using the details below.

Is My Information Secure?

Ntrepid will take reasonable precautions to protect your information from loss, misuse, or alteration. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorized interception.

How Long Does Ntrepid Store My Information For?

We store data for as long as it is necessary to provide the products and servicesfor the purposes described in this Privacy We store data for as long as it is necessary for the We store data for as long as it is necessary for the purposes described in this Privacy Statement, as required by law, and for our internal business purposes. If you would like us to delete your data, you may contact us using the information below, and we will make reasonable efforts to accommodate your request.

Does Ntrepid Collect Information From Children?

Ntrepid does not intentionally collect information from children under 13 years of age, and children under age 13 should not submit any information to us. If we become aware that a child has provided us with information without parental consent, or a parent or guardian of a child contacts us through the contact information provided below, we will use reasonable efforts to delete the child’s information from our databases.

9. What Choices Do I Have Regarding Marketing?

We want to communicate with you about our products and services and make content available to you, but only in the ways that you agree to hear from us. You are given the choice to “opt-out” of marketing communications when we collect your personal data. If you do not opt-out at this time, you may subsequently opt-out or unsubscribe from our newsletters, special offers or discounts, or other marketing communications by following the unsubscribe instructions in any email or other communication you receive from us.

After opting-out, you will not receive future promotional emails unless you open a new account, enter a contest, or sign up to receive newsletters or emails. You may also continue to receive non-marketing communications about your account or purchases that you have made. Please allow up to 2 weeks to process your request.

10. What Other Rights Do I Have?

Depending on where you are located, you may have certain rights in relation to your personal data. For example, if you are located in the EEA or UK you may have the right to:

Request access to your personal data.
Request that personal data that is incorrect is rectified.
Request that your personal data is deleted (erasure).
Request that the processing of your personal data is restricted in certain circumstances.
Object to the processing of your personal data in certain circumstances.
Request that your personal data is transferred to another organisation in a way that is accessible and machine-readable.

We would ask that you direct any complaints to Ntrepid in the first instance. However, you also have the right to complaint to a supervisory authority (such as the ICO in the UK) about our processing of your personal data.

11. How Can I Contact Ntrepid?

Ntrepid is committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have submitted information to Ntrepid and you would like to have it deleted from our databases or corrected, if you would like to ask about any of the other rights listed above, or if you have any other questions or comments regarding our privacy practices, please email us at legal@ntrepidcorp.com for more information.

Effective Date: June 10, 2022

California Privacy Notice

Effective Date: As of January 1, 2023

This California Privacy Notice (“Notice”) supplements, for California residents (referred to throughout this Notice as “you” or “your”), the general privacy policies of Ntrepid, LLC (together with its relevant subsidiaries, associates, and affiliated companies, “Ntrepid,” “us,” “we,” or “our”), including, without limitation, the Ntrepid Website Privacy Statement , and any other privacy policies, notices or statements provided on a website, mobile app, or any other digital asset that we own and operate (each, a “Service”). You have certain privacy rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, including the regulations promulgated thereunder (together, the “CCPA”). This Notice provides information regarding our data practices, including our collection, use, disclosure, and sale of your personal information (“PI”).

PI is defined under the CCPA as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident. Sensitive Personal Information (“SPI”) is a subset of PI under the CCPA.

In the event of a conflict between any other Ntrepid policy, statement or notice applicable to our Services and this Notice, this Notice will prevail as to California residents, unless stated otherwise.

Non-Applicability, Human Resources: The rights described in this Notice apply to California residents whose PI is subject to the CCPA. If you are not a California resident, the rights described in this Notice do not apply to you. ThisNotice does not apply toour current and former employees and independent contractors (“Personnel”). Our California-based Personnel may obtain a separate privacy notice that is applicable to them. This Notice also does not apply to our applicants for employment (“Applicants”). Our California-based Applicants may obtain a separate privacy notice here.

Non-Applicability, Customer Uploaded Information: This Notice does not apply to information uploaded or imported into our systems by customers in connection with their use of Ntrepid products and services (“Ntrepid Customers”). In these circumstances, any processing by Ntrepid of such information is governed by the Ntrepid Customer’s privacy policy. Ntrepid is unable to respond to any privacy rights requests regarding Customer uploaded or imported information because Ntrepid is a Service Provider under the CCPA with respect to such information and collects and processes PI at the direction of Ntrepid Customers.

1. NOTICE OF PERSONAL INFORMATION PRACTICES

The description of our PI practices in this Notice covers the twelve (12) month period immediately prior to the Effective Date of this Notice.

(a) PI Collection and Retention

In the past 12 months, we collected and retained PI about you as follows:

Category of PI	Examples of PI Collected by Ntrepid
Contact Information and Identifiers	Real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, and e-mail address.
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))	Name, signature, address, and telephone number.
Internet Usage Information	Browsing history, search history, and other information regarding your interaction with our Services.
Geolocation Data	The approximate location of the device or equipment you are using to access our Services.
Sensory Data
Inferences from PI Collected	We may draw inferences from PI we collect about you.

Category of SPI	Examples of SPI Collected and Retained by Ntrepid
Precise Geolocation	The location of the device or equipment you are using to access the Services within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.

(b) Retention of PI

Because there are numerous types of PI in each category of PI, and various uses for each PI type, our retention periods vary for each of the categories of PI described above. The length of time for which we retain each category of PI depends on the purposes for our collection and use in addition to applicable laws. In no event do we retain your PI for any longer than reasonably necessary to achieve the purposes for which it was collected or processed. The criteria used to determine the retention period of PI includes the nature and sensitivity of the PI, the potential risk of harm from unauthorized use or disclosure of the PI, as well as applicable laws (such as applicable statutes of limitation).

(c) Sources of PI

We collect PI about you in the following ways and from the following sources:

Directly from you. We collect PI directly from you when you contact us, for example, by submitting an inquiry on our website, by telephone or by e-mail, or if you express interest in being contacted by us at a trade show in which we participate.
Indirectly from you through cookies and other tracking technologies. We may collect PI that includes your Internet Protocol address, information about your device, internet usage, browsing preferences, browser type, and website activity (including access times and dates) when you use our Services or otherwise interact with us online through cookies and other tracking technologies. We do not enable third parties to collect PI from cookies on our website in a way that would constitute a “sale” or “sharing” of PI to them under the CCPA.
From third parties. We may collect your PI from third parties that interact with us in connection with our business activities, such as business partners or vendors that provide or sell lists of potential customers (e.g., marketing lists).
From social media: We may collect, receive, and retain PI if you interact with us through our social media presence.

(d) Use, Processing, and Disclosure of PI

Generally, we process your PI only to the extent necessary for business operations, including for one or more of the following business purposes:

Fulfilling or meeting the reason you provided the PI (for example, if you share your name, e-mail, and phone number with us at a trade show);
Managing interactions between you and us to provide our Services (for example, responding to inquiries through our website and using your PI to send information concerning our products);
For legal, safety, and security purposes (for example, to respond to law enforcement requests or secure your account with us);
Debugging to identify and repair errors that impact existing intended functionality of our Services;
Marketing our products; and
For our own internal purposes, such as research and development to improve the quality of your interactions with us and to deliver content, products, and service offerings relevant to your interests.

We may also disclose your PI to:

Our vendors, to you, or to other parties at your direction for the additional purposes explained at the time of collection (such as in the applicable privacy policy or notice);
The government or private parties in order to comply with applicable law or legal process or to protect our rights or the rights of others; and
Assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business.

During the past 12 months, Ntrepid did not “sell” or “share,” as those terms are defined by the CCPA, any of the categories of PI described in section 1(a) of this Notice.

(e) Use, Processing, and Disclosure of SPI:

We do not use or disclose the types of SPI described below in section 1(f) of this Notice for purposes other than the following:

Detecting security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted SPI;
Resisting malicious, deceptive, fraudulent, or illegal actions directed at us and prosecuting those responsible for those actions;
Performing services on behalf of our business, such as providing customer service, verifying customer information, providing analytic services, providing storage, or providing similar services on behalf of our business; and
Verifying or maintaining the quality or safety of products we own, manufacture or control; and
Improving, upgrading, or enhancing a product we own, manufacture, or control.

(f) PI and SPI Disclosure Practices

During the past 12 months, for the purposes explained above in section 1(d) and section 1(e) above, we disclosed PI and SPI to the categories of third parties described below (collectively, “Recipients”):

Category of PI	Categories of Recipients
1. Identifiers	Vendors (e.g., web hosting and data analytics providers, processing and storage providers, fraud prevention and security providers, and marketing services providers); Governmental entities (pursuant to legal or regulatory process).
2. Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))	Vendors (e.g., web hosting and data analytics providers, processing and storage providers, fraud prevention and security providers, and marketing services providers); Governmental entities (pursuant to legal or regulatory process);
3. Internet Usage Information	Vendors (e.g., web hosting and data analytics providers, processing and storage providers, fraud prevention and security providers, and marketing services providers); Governmental entities (pursuant to legal or regulatory process)
4. Geolocation Data	Vendors (e.g., web hosting and data analytics providers, processing and storage providers, fraud prevention and security providers, and marketing services providers);
5. Inferences from PI Collected	Vendors (e.g., data analytics providers, processing and storage providers, fraud prevention and security providers, and marketing services providers);

Category of SPI	Categories of Recipients
1. Precise Geolocation	Vendors (e.g., processing and storage providers, fraud prevention and security providers);

2. Your Privacy Rights and How to Exercise Them:

Subject to our identity verification standards (as provided in subsection 2(d)(1) below), commencing on June 12, 2023, you may exercise any of the privacy rights under in this section.

(a) Right to Know/Access:

You are entitled to submit a request for access to PI that we maintain about you twice within a 12-month period.

(1) Categories of PI:

You have a right to submit a request for access to any of the following:

Categories of PI we have collected about you;
Categories of sources from which we collected your PI;
Purposes for our collecting your PI; and
Categories of PI disclosed to third parties and, for each, the categories of recipients.

(2) Specific PI:

You may request to confirm if we are processing your PI and, if we are, to obtain a transportable copy, subject to applicable request limits, of the specific PI that we collect and maintain. Before providing the specific PI that we maintain about you, we will apply the identify verification standards (as provided in subsection 2(d)(1) below.

(b) Right to Delete:

Subject to certain exceptions, you may request that we delete your PI. Ntrepid is not required to delete PI that we did not collect directly from you.

(c) Right to Correct:

You may request that we correct any inaccurate PI that we maintain about you.

(d) How to Exercise Your Privacy Rights

To exercise your privacy rights, either you or your authorized agent may use our California Resident Privacy Rights Request Webform or call us toll-free at: 1-800-921-2414. In order to process your request, we will require your response to any follow-up inquiries we make.

Please be aware that we do not accept or process requests through any other means (e.g., e-mail, social media, etc.).

(1) Identity Verification Standards

When you submit a request, we will initially ask you to provide the following verifying information: your full name, e-mail, phone number and/or mailing address. We will review the information provided and may request additional verifying PI via e-mail or other means to ensure we are interacting with a California resident and the correct individual. We will not honor your request unless you provide sufficient information for us to verify, with a reasonable or reasonably high degree of certainty, that you are the California resident about whom we collected PI.

We will use PI provided in your request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose.

We verify each request as follows:

Right to Know/Access (Categories of PI): We will verify your request by matching at least two (2) data points you provide with data points we maintain, which we have determined to be reliable for the purpose of verifying you.
Right to Know/Access (Specific PI): We will verify your request by matching at least three (3) data points you provide with data points we maintain, which we have determined to be reliable for the purpose of verifying you. You will also be required to provide a signed declaration under penalty of perjury that you are the individual whose PI is the subject of the request.

If you fail to provide at least three (3) data points and the signed declaration, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a request for access to the categories of PI we maintain about you. Because of the need for a signed declaration, we will be unable to complete a request for specific PI exclusively via the toll-free number.

Right to Delete: We will verify your request by matching at least two (2) or three (3) data points you provide with data points we maintain with the number of data points contingent upon the sensitivity of the PI and the risk of harm posed by an unauthorized deletion.
Right to Correct: We will verify your request by matching at least two (2) or three (3) data points you provide with data points we maintain with the number of data points contingent upon the sensitivity of the PI and the risk of harm posed by an unauthorized correction.

If you fail to provide the number of data points specified above, we will be unable to verify you sufficiently to honor your request.

(2) Agent Requests

You may use an authorized agent to exercise your privacy rights on your behalf. Authorized agents must demonstrate authority to exercise rights on the requesting consumer’s behalf by submitting supporting documentation to legal@ntrepidcorp.com. At a minimum, we will require evidence of the agent’s identity (via submission of a driver’s license or other government-issued identification), and at least one of the following forms of proof of the agent’s legal authority to act on your behalf:

Written authorization signed by you under the penalty of perjury; or
Certified copy of a Power of Attorney granted under the California Probate Code

Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing PI about another individual, you represent that your interactions and exchanges comply with applicable data privacy laws. You shall have sole responsibility for any violation of applicable laws as a result of a failure to obtain any necessary consent from such individual.

(e) Ntrepid Response:

We will not charge a fee to respond to your privacy rights requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining the basis for such a decision including a cost estimate before completing any such request.

In protecting and maintaining the confidentiality of your PI, we will never provide your account log-in password, or security questions or answers in response to a privacy rights request.

3. NON-DISCRIMINATION/NON-RETALIATION:

We will not discriminate or otherwise retaliate against you in any manner prohibited by the CCPA for exercising your privacy rights hereunder.

4. OUR RIGHTS AND THE RIGHTS OF OTHERS:

Notwithstanding anything to the contrary in this Notice, we may collect, use, and disclose your PI as required or permitted by applicable law and which may override your rights under the CCPA. In addition, we are not required to honor your privacy rights hereunder to the extent that doing so would infringe upon our or another person’s or party’s rights or otherwise conflict with applicable law.

5. CHANGES TO NOTICE:

We reserve the right to update this Notice from time to time. When we make updates, we will notify you by revising the Effective Date at the top of the Notice. Your continued use of our Service following the posting of updates constitutes your acceptance of such updates.

6. ADDITIONAL INFORMATION:

If you have any questions, comments, or concerns about our privacy practices, please e-mail legal@ntrepidcorp.com or visit the Contact section of our website.

Cookie	Duration	Description
cookielawinfo-checkbox-advertisement	1 year	Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the "Advertisement" category .
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
esctx	session	The esctx cookie is set by Microsoft for secure authentication of the users' login details.
JSESSIONID	session	The JSESSIONID cookie is used by New Relic to store a session identifier so that New Relic can monitor session counts for an application.
stsservicecookie	session	This cookie is set by Microsoft for secure authentication of the users' login details.
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
x-ms-gateway-slice	session	This cookie is set by Microsoft for secure authentication of the users' login details.

Cookie	Duration	Description
_ga	2 years	The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
_gat_UA-37785135-1	1 minute	A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to.
_gcl_au	3 months	Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services.
_gid	1 day	Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
CONSENT	2 years	YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data.
vuid	2 years	Vimeo installs this cookie to collect tracking information by setting a unique ID to embed videos to the website.

Cookie	Duration	Description
_fbp	3 months	This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.
fr	3 months	Facebook sets this cookie to show relevant advertisements to users by tracking user behaviour across the web, on sites that have Facebook pixel or Facebook social plugin.
personalization_id	2 years	Twitter sets this cookie to integrate and share features for social media and also store information about how the user uses the website, for tracking and targeting.
test_cookie	15 minutes	The test_cookie is set by doubleclick.net and is used to determine if the user's browser supports cookies.
VISITOR_INFO1_LIVE	5 months 27 days	A cookie set by YouTube to measure bandwidth that determines whether the user gets the new or old player interface.
YSC	session	YSC cookie is set by Youtube and is used to track the views of embedded videos on Youtube pages.
yt-remote-connected-devices	never	YouTube sets this cookie to store the video preferences of the user using embedded YouTube video.
yt-remote-device-id	never	YouTube sets this cookie to store the video preferences of the user using embedded YouTube video.
yt.innertube::nextId	never	This cookie, set by YouTube, registers a unique ID to store data on what videos from YouTube the user has seen.
yt.innertube::requests	never	This cookie, set by YouTube, registers a unique ID to store data on what videos from YouTube the user has seen.

Cookie	Duration	Description
buid	1 month	No description available.
fpc	1 month	No description available.
muc_ads	2 years	No description available.
RpsContextCookie	10 minutes	No description available.
visitor_id456132	10 years	This is a cookie pattern that appends a unique identifier for a website visitor, used for tracking purposes. The cookies in this domain have a lifespan of 10 years.
visitor_id456132-hash	10 years	This is a cookie pattern that appends a unique identifier for a website visitor, used for tracking purposes. The cookies in this domain have a lifespan of 10 years.