Privacy Portal

3. Understanding "Sale" and "Sharing" Under Privacy Laws

Privacy laws define "sale" and "sharing" broadly, which can be confusing for consumers. Here is what these terms mean under major privacy laws:

Sale (CCPA/CPRA Definition): A "sale" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for monetary or other valuable consideration. This includes some advertising-related data sharing even when no money changes hands.

Sharing (CPRA Definition): "Sharing" means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

What This Means for iQs Group: We engage in limited advertising activities that may technically fall under these definitions. Specifically, we may share certain identifiers with advertising platforms to measure the effectiveness of our marketing campaigns or to show relevant advertisements to previous website visitors (remarketing). By opting out, you are instructing us to stop these specific activities with respect to your information.

Exemptions: Certain disclosures are not considered "sales" or "sharing" under the law, including disclosures to service providers performing services on our behalf under written contracts, disclosures at your direction, and disclosures required by law. We will continue to make these permitted disclosures even after you opt out.

4. Additional Privacy Rights You Can Exercise

In addition to opting out of sales and sharing, you may have additional privacy rights depending on your state of residence. Through this Privacy Portal, you can exercise the following rights:

4.1 Right to Know (Access)

You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you. This includes information about the sources of collection, the purposes for processing, and the categories of third parties with whom we share your information. We will provide this information in a portable, readily usable format.

4.2 Right to Delete

You have the right to request that we delete personal information we have collected from you. Upon receiving a verified deletion request, we will delete your information from our records and direct our service providers to do the same, unless an exception applies. Exceptions include information needed to complete a transaction, detect security incidents, comply with legal obligations, or exercise free speech rights.

4.3 Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you. We will use commercially reasonable efforts to correct the information in our records and instruct our service providers to do the same. In some cases, we may request documentation to verify the accuracy of the corrected information.

4.4 Right to Limit Use of Sensitive Personal Information

If we collect sensitive personal information as defined by the CPRA (such as Social Security numbers, financial account information, precise geolocation, racial or ethnic origin, religious beliefs, health information, or biometric data), you have the right to limit our use and disclosure of such information to what is necessary to perform the services or provide the goods you requested.

4.5 Right to Data Portability

When you exercise your right to access your personal information, we will provide the information in a format that allows you to transmit it to another entity without hindrance. This typically means providing the information in a commonly used, machine-readable format such as CSV or JSON.

5. How to Submit a Privacy Request

You can submit privacy requests through any of the following methods:

When submitting a request, please provide sufficient information to verify your identity and specify which right(s) you wish to exercise. We may need to request additional information to verify your identity before processing your request. We will not fulfill requests if we cannot verify your identity or authority to make the request.

6. Verification Process

To protect your privacy and prevent unauthorized access to your personal information, we implement a verification process for all privacy requests. The level of verification depends on the sensitivity of the request:

Standard Verification: For requests to opt out of sales/sharing or to know categories of information, we will verify your identity by matching at least two pieces of information you provide against information we have on file. This typically includes email address, name, and other account-related information.

Enhanced Verification: For requests to access specific pieces of personal information or to delete information, we require a higher level of verification. This may include matching three or more data points, providing a signed declaration under penalty of perjury, or other methods appropriate to the sensitivity of the request.

If we cannot verify your identity, we will explain why and may ask you to submit additional verification information. If you have an account with us, you may be asked to log in as part of the verification process. For requests made by authorized agents, we require written authorization from the consumer and verification of the agent's identity.

7. Response Timeframes

We are committed to responding to your privacy requests promptly. Here are our standard response timeframes:

Acknowledgment: We will confirm receipt of your request within 10 business days. This acknowledgment will include information about how we will process your request and our expected timeline for completion.

Substantive Response: We will respond to your request within 45 calendar days of receipt. If we need additional time to process your request, we will notify you and may extend the response period by an additional 45 days (for a total of 90 days). We will explain the reason for the extension.

Opt-Out Requests: Opt-out requests will be processed within 15 business days. We will confirm when your opt-out has been implemented across our systems.

You may make up to two requests to know during any 12-month period. There is no limit on opt-out, deletion, or correction requests. If we deny your request, we will explain the reason for the denial and inform you of your right to appeal.

8. Appeal Process

If we deny your privacy request in whole or in part, you have the right to appeal our decision. To file an appeal:

Submit Your Appeal: Send an email to [email protected] with the subject line Privacy Request Appeal. Include your original request details, our response, and the reason you believe the decision should be reconsidered.

Appeal Review: A different member of our Privacy Team will review your appeal and the original decision. We will respond to your appeal within 60 days.

Further Recourse: If your appeal is denied and you remain dissatisfied, you may have the right to contact your state's Attorney General or other regulatory authority to file a complaint. We will provide information about relevant regulatory contacts in our appeal response.

9. Non-Discrimination Commitment

iQs Group will not discriminate against you for exercising any of your privacy rights. We will not:

• •Deny you goods or services
• •Charge you different prices or rates for goods or services
• •Provide you a different level or quality of goods or services
• •Suggest that you will receive a different price or rate or different level or quality of goods or services

However, we may offer financial incentives for the collection, sale, or deletion of personal information. If we offer such incentives, we will provide you with clear information about the terms and obtain your opt-in consent. You may withdraw from any financial incentive program at any time.

10. Updates and Contact Information

This Privacy Portal and the information contained herein may be updated periodically to reflect changes in our practices or applicable laws. We encourage you to check back regularly for updates. The "Last Updated" date at the top of this page indicates when changes were last made.