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Best Coast Pairings LLC Privacy Policy ("Privacy Policy")

Date Privacy Policy Last Modified: February 2025

INTRODUCTION

Best Coast Pairings LLC ("Company" or "We") respects your privacy and are committed to protecting your personal data through our compliance with this Privacy Policy.

This Policy will inform you as to how we look after your personal data, your privacy rights, how the law protects you, and our practices for collecting, using, maintaining, protecting and disclosing your personal data when you visit our website BestCoastPairings.com (our "Website") or use any of the Company's services (including, without limitation, any desktop or mobile applications, products or other services) (collectively, the Website and services are referred to as the "Services"). As you are using our Services, we want to be clear about how we use information and the ways in which you can protect your privacy.

Please read this Policy carefully to understand our policies and practices regarding your personal data and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services because we will not be able to perform the contract we have or are trying to enter with you (for example, to provide you with services).

By accessing or using our Services, you agree to this Privacy Policy, and if you are under age 16, you have your parent or legal guardian's permission to use our Services and your parent/legal guardian has agreed to this Privacy Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE. This Privacy Policy aims to give you information on how Best Coast Pairings LLC collects and processes your personal data (in various formats, including digitally, physically, and abstract physical formats) through your use of the Services, including any data you may provide through the Services when you purchase a subscription or participate in an Event.

CONTROLLER. For purposes of the European Union's ("EU") General Data Protection Regulation 2016/679 ("GDPR"), Best Coast Pairings LLC (the "Company") is the controller and responsible for this Website. In some instances, the Company may act as a processor on behalf of another controller, for example, when the Company's Services are used to power the ranking system of another company (e.g. Games Workshop, Catan Studio, etc.).

DATA PRIVACY MANAGER. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy and the GDPR. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the Company's data privacy manager using the details set out below.

Best Coast Pairings LLC

Casey Dunn

support@bestcoastpairings.com

Individuals located in the EU have the right to make a complaint at any time to the appropriate EU supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES.It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page, banner within the mobile application, or by sending an email to the email address you provided to us. Your continued use of this Website following the effective date of such update constitutes your acceptance of the revised privacy policy.

You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Services and this privacy policy to check for any changes. The date the privacy policy was last revised is identified at the top of this page. Historic versions are available by emailing support@bestcoastpairings.com and requesting copies.

It is important that the personal information, and importantly, the contact information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD PARTY LINKS. The Services may include links (and advertisements) to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements/notices. When you leave our Services (including the Website), we encourage you to read the privacy notice of every website you visit and application you use.

2. THE DATA WE COLLECT ABOUT YOU

"Personal Data" (or personal information) means any information about an individual from which that person can be identified. It does not include data where the person's identity has been removed.

This Policy applies to Personal Data we collect from or about you in any format.

We collect several types of Personal Data from and about users of our Services, including the following:

  1. Identity Data includes: first name and last name
  2. Contact Data includes: email address.
  3. Technical Data includes: internet protocol (IP) addresses, your login data, your internet connection, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and information about the equipment (computer or mobile device) you use to access our Services.
  4. Transaction Data includes details about transactions with you and other details of Services you have purchased from us.
  5. Profile Data includes: event scores (including by round) and rankings, army lists, and table assignments.
  6. Usage Data includes: information about how you use our Services.
  7. Marketing and Communications Data includes: your preferences in receiving marketing from us and any third parties, and your communication preferences.

We also collect, use, and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data because this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service. However, if we combine or connect Aggregated Data with your information so that it can directly or indirectly identify you, we will treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We also use a third-party payment processor to handle all payment processing transaction data, and we, therefore, do not have access to any Financial Data, such as details about payments, billing addresses, or debit/credit card information.

We collect Technical Data which includes: internet protocol ("IP") address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, traffic data, logs and other communication data and the resources that you access and use on the Services, operating system and platform, and other technology on the devices you use to access our Services. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain Technical Data about your equipment, browsing actions and patterns. We do not use automated technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

We do not maintain or associate the Technical Data we collect with your Personal Data. The Technical Data helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

  1. Estimate our audience size and usage patterns.
  2. Store information about your preferences, allowing us to customize our Services according to your individual interests.
  3. Speed up your searches.
  4. Recognize you when you return to our Services.

We do not collect any Special Categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data). Nor do we collect any information about criminal convictions or offenses.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect this information from you and about you including:

DIRECT INTERACTIONS. You may give us your Personal Data by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes Personal Data you provide when you:

  • Register and use our Services (such as entering event scores, army lists, etc.)
  • Create an account on our Website or Services;
  • Subscribe to our Services;
  • Request marketing be sent to you;
  • or Give us some feedback or report a problem with our Services.

AUTOMATED TECHNOLOGIES OR INTERACTIONS. As you interact with our Website or other Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns as you navigate through the Services. Information collected automatically may include usage details, IP addresses and information collected through cookies.

THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES. We may receive Personal Data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    • Analytics providers (such as, Google, based outside the EU);
    • Advertising networks, based inside or outside the EU;
    • Search information providers, based inside or outside the EU;
    • Contact, Financial or Transaction Data from our third-party payment processor based inside or outside the EU submitted by you detailing the transactions you carry out through our Services and of the fulfillment of your orders;
    • and Identity, Contact and registration Data from our business partners, such as Frontline Gaming, based outside the EU for event registration purposes.

The Website does not have the functionality for a forum when users submit contributions directly, but you may provide information to be published or displayed (hereinafter, "posted") on public areas of the Services, or transmitted to other users of the Services or third parties, such as event scores, army lists (collectively, "User Contributions"). User Contributions will be posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that User Contributions, if any, will not be viewed by unauthorized persons.

COOKIES. The technologies we use for this automatic data collection of Technical Data may include Cookies (or browser cookies). Our Cookie Notice provides details on how we use cookies and your choices about cookies. A cookie is a small file placed on the hard drive of your computer. Cookies enable the site's or service provider's systems to recognize your browser and capture and remember certain information regarding your visit to the Website such as: your IP address; the domain from which you accessed the Website; the date, time and duration of your visit; and the pages you visited.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES.Some content or applications, including advertisements, on our Services are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. When you leave our Website, we encourage you to read the privacy notice of every website you visit and every application you use.

4. HOW WE USE YOUR PERSONAL DATA

As permitted by law, we use information that we collect about you or that you provide to us, including your Personal Data:

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including without limitation to:
    • provide our Services and content, and any information you request from us, to you;
    • allow you to participate in interactive features of our Services;
    • for billing and collection purposes, provide notices to you about your account and/or subscription, including expiration and renewal notices;
    • create, maintain, customize and secure your account with us;
    • personalize your Website experience and to deliver content and products and service offerings relevant to your interests;
    • provide notices to you about changes to our Services or any products or services we offer;
    • to provide notices to you of updates to the Privacy Policy or other terms of service;
    • and evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to respond to law enforcement requests (such as a search warrant or subpoena) and court orders, and to comply with legal or regulatory obligations.

We generally do not rely on consent as the legal basis for processing your Personal Data other than in relation to sending third party or direct marketing communications to you via email about our own and third-parties' goods and services that may be of interest to you. You have the right to withdraw consent to such marketing by emailing the address provided in the Contact Information section below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA.We set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below:

Purpose/ActivityType of DataLawful basis for processing including the basis of legitimate interest if applicableData Retention Period
To register you as a new customer
  1. Identity
  2. Contact
Performance of a contract with you.For as long as the Company has a business need or is legally required to maintain/use such information.
To process and deliver your order including: (1) manage payments, fees, and charges; and (2) collect and recover money owed to us
  1. Identity
  2. Contact
  3. Transaction
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us).
For as long as the Company has a business need or is legally required to maintain/use such information.
To manage our relationship with you which will include: (1) notifying you about changes to our Privacy Policy or terms of use; (2) asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communication
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services).
For as long as the Company has a business need or is legally required to maintain/use such information.
To administer and protect our business, Website, and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
  1. Identity
  2. Contact
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business.)
For as long as the Company has a business need or is legally required to maintain/use such information.
To deliver relevant content via the Services and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communication
Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy).For as long as the Company has a business need or is legally required to maintain/use such information.
To make suggestions and recommendations to you about goods and services that may be of interest to you.
  1. Identity
  2. Contact
  3. Usage
  4. Profile
Necessary for our legitimate interests (to develop our Services and grow our business).For as long as the Company has a business need or is legally required to maintain/use such information.
To use data analytics to improve the Services, products, marketing and user experiences.
  1. Technical
  2. Usage
Necessary for our legitimate interests (to define types of users of our services, to keep the Services updated and relevant, to develop our business and inform out marketing strategy).For as long as the Company has a business need or is legally required to maintain/use such information.

"Legitimate Interest" means the interest of the Company's business in conducting and managing our business to give you the best service/products and the best and most secure experience. We make sure we consider and balance any potential impact on you, both positive and negative, and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted to by law. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at the address listed in the Contact Information section below.

MARKETING. We strive to provide you with choices regarding certain uses of your Personal Data, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM THE COMPANY. We may use your Identity, Contact, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you. We call this marketing.

You will receive marketing communications from us if you have requested information from us or purchased Services from us, and in each case, if you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING. We will get your express opt-in consent before we share your Personal Data with any company outside of Best Coast Pairings LLC for marketing purposes.

OPTING OUT. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at the email address provided in the Contact Information section below.

CHANGE OF PURPOSE. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably determine that we need to use it for another reason compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the email address provided in the Contact Information section below.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where such processing is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

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

We may disclose Personal Data that we collect or you provide as described in this Policy to enforce our Website policies, or protect our or other's rights, property, or safety; to comply with any law, court order or legal process, including responding to any government or regulatory request; and with the parties described below for the purposes set forth in the table in Section 4 above:

  • Internal Third Parties, such as our subsidiaries and affiliates.
  • External Third Parties, such as:
    • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
    • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Best Coast Pairings LLC's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Best Coast Pairings LLC about our Services' users is among the assets transferred.
    • To third parties to market their products or services to you if you have consented to or not opted out of these disclosures.
    • To third parties (e.g., shops) for estimating attendance, ticket verification purpose.

6. USE OF WEBSITE BY CHILDREN (UNDER THE AGE OF 16 IN THE EUROPEAN UNION OR AGE 13 IN THE UNITED STATES) / CHILDREN'S PRIVACY POLICY

Our Website and Services are not intended for children under the age of 16 in the EU or children located in the US who are under age 13, and we do not knowingly collect, use, disclose or sell Personal Data from such children. No one under age 16 located in the EU, or age 13 in the US, may provide any Personal Data to or through our Services. If you are under age 16 located in the EU, or under age 13 in the US, do not use or provide any information on or through any of the Services' features, register for the Services, use any of the interactive features of the Services, or provide any information about yourself to us. If you know or suspect that your child has submitted Personal Information to us and you would like to request that such information, be removed, you may do so by contacting us at the address listed below in the Contact Information section.

7. INTERNATIONAL TRANSFER

If you are located in a province, country, or other government jurisdiction outside of the United States, and if you choose to provide your personal information to Best Coast Pairings LLC through our Services, please be aware that your personal information will be transferred to and maintained on computers located in the United States and the applicable US privacy laws may not be as protective as those in your jurisdiction.

Whenever we transfer your personal data to countries outside of the European Economic Area ("EEA"), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Data Privacy Framework (DPF) Program which requires them to provide similar protection to personal data shared between the EU and the US.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. We also limit access to Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. These individuals will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

All Financial Data is securely processed by Stripe, Inc. and Stripe's privacy policy is available here (https://stripe.com/privacy).

We have put in place procedures to deal with any suspected incident involving Personal Data and will notify you and any applicable regulator of an incident involving Personal Data where we are legally required to do so.

9. DATA RETENTION

We maintain one or more databases to store your Personal Data and may keep such information indefinitely in order to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some circumstances you may ask us to delete your Personal Data. See the section below regarding Requesting Erasure for more information. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Financial Data is collected and maintained by our third-party payment processor, Stripe, Inc., and is subject to Stripe, Inc.'s data retention policy. More information can be found here (https://support.stripe.com/questions/data-retention-policy).

10. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending an email to the email address provided in the Contact Information section below.
  • Promotional Offers from the Company. If you do not wish to have your e-mail address used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an e-mail stating your request to the e-mail address provided below in the Contact Information section. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to communications with the Company as a result of a product or subscription purchase, product service experience or other transactions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an e-mail stating your request to the e-mail address provided below in the Contact Information section.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

11. YOUR LEGAL RIGHTS FOR CONSUMERS OUTSIDE OF THE UNITED STATES.

Under certain circumstances, consumers in the EEA and other jurisdictions that have adopted privacy laws or regulations similar to GDPR have rights regarding their Personal Data. Each of the rights is summarized below:

  • Request access to your Personal Data. You have the right to be informed of the Personal Data we hold about you, and why and how we have it. You may also request certain information regarding Company's disclosure of Personal Data to third parties for their direct marketing purposes.
  • Request correction of your Personal Data. You have the right to request correction of inaccurate or incomplete Personal Data although we will need to verify the accuracy of the new data you provide to us. We may require you to take certain steps or provide additional information to verify your identity before we provide any information or make any corrections. We may not be able to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
  • Request erasure of your Personal Data. You have the right to have your Personal Data erased if there is no good reason for us to continue to process it. You also have the right to ask us to delete/erase your Personal Data where you have successfully exercised your right to object to its processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request to erase for specific legal reasons which will be provided to you, if applicable, when evaluating your request. By requesting that we delete your Personal Data, we may keep the anonymized or de-identified statistical data (including, without limitation, your tournament score information), that is not connected to your name or other Personal Data or identity.
  • Object to processing of your Personal Data. You have the right to object to the processing of your Personal Data where we have justified the data processing on the basis of our legitimate interests and there is something about your particular situation which makes you feel the processing impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request restriction of processing your Personal Data. You have the right to restrict the processing of your Personal Data if: the accuracy of the data is being contested for as long as it takes to verify that accuracy; the processing is unlawful and you request restriction of processing (rather than erasure of the data); we no longer need the data for its original purpose but you would like us to hold the data because you need it to establish, exercise, or defend legal rights; or you have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate interests to use it.
  • Request transfer of your Personal Data. You have the right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you designate, your Personal Data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to withdraw consent. You have the right to withdraw your consent to the processing of your Personal Data where we were are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case when reviewing your request to withdraw your consent.

You may exercise any of these rights by e-mailing us at the address listed in the Contact Information section below. You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in such circumstances. Also, the exercise of some rights will prevent our ability to provide Services to you, and if this is the case, we will explain this to when you submit your request to us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data or to exercise any of your other rights. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month after the request is received. Occasionally it may take us longer than a month if your request is particularly complex or you have submitted several requests. In this case, we will notify you and keep you updated.

12. YOUR LEGAL RIGHTS FOR CONSUMERS IN THE UNITED STATES

In addition to the provisions of our Privacy Policy set forth above, the Company recognizes that other jurisdictions have passed their own comprehensive privacy laws, including several states in the US. Unless the provisions below states that it specifically applies to residents of a particular state, the following provisions apply to all US-based consumers.

Under California law, California residents have specific rights regarding their Personal Information and must be provided a particular notice when Personal Information is collected (the "Notice at Collection"). Our Notice of Collection is comprised of the following links:

  • The section of this Privacy Policy, below, entitled "Personal Information Defined."
  • The section of this Privacy Policy entitled "How We Use Your Personal Data" and "Disclosures Regarding Collection, Disclosure, Sale and Sharing of Personal Information."

Personal Information Defined. "Personal Data" as used above includes the "Personal Information" described below with respect to US-based consumers. The Company has collected the following categories of Personal Information from consumers within the last 12 months:

Examples of Information Under This Category (*Not all of this information is collected by the Company)Whether this Information is CollectedRetention Period

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, government issued identification number, or other similar identifiers.
We may collect and use Personal Information within this category.For as long as the Company has a business need or is legally required to maintain/use such information.

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

A name, signature, Social Security number, physical characteristics or description, address, telephone number, government issued identification number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
We may collect and use Personal Information within this category.For as long as the Company has a business need or is legally required to maintain/use such information.

C. Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
We may collect and use Personal Information within this category.For as long as the Company has a business need or is legally required to maintain/use such information.

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
We may collect and use Personal Information within this category. ORFor as long as the Company has a business need or is legally required to maintain/use such information.

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information such as, fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
We do not collect any Personal Information within this category.We do not collect any Personal Information within this category.

F. Internet or other similar network activity

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
We may collect and use Personal Information within this category.For as long as the Company has a business need or is legally required to maintain/use such information.

G. Geolocation data

Physical location or movements, including physical location and time related to use of an internet website, application, or device.
We may collect and use Personal Information within this category.For as long as the Company has a business need or is legally required to maintain/use such information.

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information and call monitoring.
We do not collect any Personal Information within this category.We do not collect any Personal Information within this category.

I. Professional or employment-related information

Current or past job history or performance evaluations.
We do not collect any Personal Information within this category.We do not collect any Personal Information within this category.

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

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
We do not collect any Personal Information within this category.We do not collect any Personal Information within this category.

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We do not collect any Personal Information within this category.We do not collect any Personal Information within this category.

L. Sensitive Personal Information means certain types of Personal Information, such as:

Social security, driver's license, state identification card, or passport number, 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, precise geolocation, including any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by regulations, racial or ethnic origin, citizenship or immigration information, religious or philosophical beliefs, or union membership, the contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication, genetic data, unique biometric information used for identification, consumer's neural data, and health information.
We do not collect any Personal Information within this category.We do not collect any Personal Information within this category.

DISCLOSURES REGARDING COLLECTION, DISCLOSURE, SALE AND SHARING OF PERSONAL INFORMATION.

In the preceding twelve (12) month period, the Company has not sold any Personal Information of consumers, or shared any Personal Information for cross-context behavioral advertising, to any third parties.

In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in Section 5 (Disclosures of Your Personal Data) of our Privacy Policy above.

CONSUMER REQUESTS. This section describes the rights of California residents under California law and how to exercise those rights by submitting a consumer request ("Consumer Request"). In some instances, where we are acting as a "service provider," we may direct consumer requests to the business who holds your Personal Information. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your Personal Information.

  1. Access to Specific Information and Data Portability Rights. You have the right to request that the Company disclose certain or all of the following information to you about our collection and use of your Personal Information over the past 12 months. Once we receive a verifiable Consumer Request, we will be able to disclose to you the specific pieces of Personal Information we collected about you (also may be called a data portability request).
  2. Deletion Request Rights. You have the right to request that we delete any or all of your Personal Information that we collected from and about you, subject to certain statutory exceptions. Once we receive a verifiable Consumer Request, we will identify the Personal Information, confirm that you want that Personal Information deleted, and then delete (and notify our service providers to delete) your Personal Information from our records, unless an exception applies.
  3. Right to Correct. You have the right to request inaccurate Personal Information be corrected.
  4. Right to Restrict Sensitive Personal Information Processing. You have the right to restrict how your Sensitive Personal Information is used and disclosed, subject to certain uses permitted by California law (such as, the use necessary for the performance of services, use to ensure security and integrity).
  5. Non-Discrimination. We will not discriminate against you for exercising any of your legal rights regarding your Personal Information, unless permitted by law. We will not take any of the following actions solely because you chose to exercise any of your legal rights regarding your Personal Information:
    1. Deny you goods or services.
    2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
    3. Provide you with a different level or quality of goods or services.
    4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

HOW TO SUBMIT A CONSUMER REQUEST. To exercise your rights, please submit a Consumer Request to the contact information below. The Consumer Request must describe the request with sufficient detail that allows us to properly understand, evaluate and respond to it. Please specify if your Consumer Request pertains to all specific pieces of your Personal Information, or only with respect to the categories of Personal Information. You may only make a Consumer Request for access or data portability twice within a 12-month period.

HOW WE WILL VERIFY CONSUMER REQUESTS. Only you, or a person or entity that you authorize to act on your behalf, may make a Consumer Request related to your Personal Information. To designate an authorized agent, we will ask you to provide us with legal documentation (such as power of attorney documentation) or written permission and the agent will need to verify their own identity with us.

We reserve the right to require you to provide additional information to enable us to reasonably verify that you are the person about whom the Personal Information pertains in order to release the requested information to you (or your authorized representative). If you have an account with us, you will be asked to use the standard authentication procedures to access your account. If you do not have an account with us, you will be asked to verify certain pieces of your Personal Information. If we are unable to verify your identity, we may be unable to provide you with information responsive to the request.

HOW WE WILL RESPOND TO CONSUMER REQUESTS. We endeavor to respond to verifiable Consumer Requests within 45 days after receipt. If we require more time (up to 45 days) we will inform you of the reason and extension in writing. If you have an account with us, we will deliver our written response(s) to that account. If you do not have an account with us, we will deliver our written response(s) by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the Consumer Request. If we deny (or cannot comply with) the Consumer Request, we will explain why. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity. We do not charge a fee to process or respond to your Consumer Request unless such request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide you with a cost estimate before completing your request.

ADDITIONAL RIGHTS UNDER CALIFORNIA LAW. California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us at the address listed in the Contact Information section below.

If you are a California resident under the age of 18, you may request removal of content or information you have posted publicly on our Website. To request deletion or de-identification of a post publicly on our Website, please contact us directly at the address below in the Contact Information section. Please understand that there may be de-identified or recoverable elements of your content or information on our servers in some form, and will not remove content or information that we may be required to retain under applicable federal or state laws.

CONSUMER RIGHTS UNDER OTHER STATE PRIVACY LAWS. Additional states (such as Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia) provide (now or in the future) their state residents with rights to:

  1. Confirm whether we process their Personal Data.
  2. Access and delete certain Personal Data.
  3. Correct inaccuracies in their Personal Data, taking into account the information's nature processing purpose.
  4. Data portability.
  5. Opt-out of Personal Data processing for:
    1. Targeted advertising;
    2. Sales; or
    3. Profiling in furtherance of decisions that produce legal or similarly significant effects.
  6. Either limit (opt-out of) or require consent to process sensitive Personal Data.

The exact scope of these rights may vary by state. To make such a request, please email us at the address listed in the "Contact Information" section below. In the event that we deny a resident's data request, the resident may appeal said decision by emailing the address listed below in the "Contacting Us" section. If a Colorado resident has concerns about the result of the appeal, they have the right to contact the Attorney General for the state of Colorado.

13. CONTACT INFORMATION

To ask questions or comment about this Policy and our privacy practices, please email us at: support@bestcoastpairings.com.

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