Privacy Policy

The purpose of this Privacy Policy (“Privacy Policy”) is to inform you about SmartBorder’s practices relating to the processing of personal information of our former, current or prospective customers, vendors, website visitors or others (“you”, “your”) that may be provided through access to or use of our websites (www.smartborder.com and related sites (the “Sites”) or services and related products (collectively the “Services”) or that may otherwise be collected by us, including when you engage with us. Where processing of personal information is undertaken by our affiliated companies, they are joint controllers with SmartBorder for your personal information. By purchasing our products or using our services or website, you consent to the collection, use, storage and disclosure of your personal information described herein.

This Privacy Policy also explains how you can contact us if you have a question about or would like to exercise your privacy rights in regard to any personal information that we may be processing about you. We strongly recommend that you take the time to read this Privacy Policy.

Not In Scope. This Privacy Policy does not apply to the personal information that we collect and process about our employees.

Additional Notices. In some cases, additional or supplemental privacy notices (each an “Additional Notice”) may be provided and will apply to certain personal information collected and processed by us. The Additional Notice will control to the extent there is a conflict with this Privacy Policy, with respect to your personal information that is subject to that notice.

Additional Information and Rights. For information about the privacy choices you have regarding your personal information, review the section “Your Privacy Rights and Choices” below. If you are a resident of California (USA) please see the “Additional Information for California Residents” section below for important information about the categories of personal information we collect and disclose and your privacy rights and choices under California privacy laws.

Personal Data Collected Directly. We may collect personal information directly from you during your dealings with us or while visiting our websites, for example when you contact us by e-mail or phone, subscribe to a service or register on our website. You do not have to provide us with your personal information. However, if you chose not to disclose certain information, we may not be able to provide you with access to certain services or features, including account registration. The information we collect depends upon how you use our Services or otherwise interact or engage with us, but generally includes the following:

• Account and profile information: name, company name, industry, address, e-mail address, telephone number as well as usernames and passwords for access to SmartBorder solutions and tools.
• Communications and interactions: when you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also maintain records communications and information that you post on our social media channels, and information you provide to us related to any customer support requests.
• Demographic information: education and occupation.
• Comments or feedback: from client and prospective client services.
• Applicant information: where you are applying for employment with us, you will be asked to provide certain additional information, for example about your educational, employment history, and right to work, pursuant to a specific privacy notice for job applicants.
• Events and other requests: we also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event. When you fill out a ‘Contact Us’ form, signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests.
• Information we collect and receive from clients: as part of providing our services to clients, we may process the following information on our client’s behalf: proof of identity (such as a signature, passport and driver’s licence; vehicle information (such as the vehicle identification number (VIN) and licence plate number; billing details; and shipping information (such as shipping-related contact details, signature for proof of delivery, account number and information provided to us regarding the content of certain shipments).

Personal Data from Third Parties. We may collect personal information about you from third party sources, such as public databases, social media platforms or other third parties.

• We may receive lead and prospect information from third parties, about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information.
• If you post information about us or engage with us on third party (social media) platforms, we may collect personal information about you from that third party platform. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.

Automatically Collected Information. In addition, SmartBorder may automatically collect the following information related to your use of the Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:

• Device and browsing information: we use cookies, log files, pixels, web beacons, and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see below. Please see the “Cookies, Tracking and Analytics” section below for more information about our use of cookies or visit our Cookie Policy.
• Activities and usage: we also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services.
• Location information: we may collect or derive location information about you, such as through your IP address.

How We Use Your Personal Information

Purposes. We collect, use disclose and otherwise process your personal information for the following purposes:

• Provide our services: to provide and operate our SaaS solutions and related tools or services.
• Customer support: to provide support and respond to and communicate with you about your quotes, requests, questions and comments.
• Process claims: to investigate and process claims received in connection with our services.
• Customization and personalization: to develop and maintain our relationship with you by tailoring content we send or display to you in order to offer location customization and personalized help and instructions, and to otherwise personalize your experience using the services. This includes communication regarding participation in special events, programs, surveys, contests and other offers or promotions.
• Marketing and promotions: to send direct marketing and promotional materials. For example, we may use contact information such as your email address to send you newsletters, special offers, or promotions, or to otherwise contact you about SmartBorder products or information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. As explained below, we do not use your content for direct marketing purposes. You may opt-out of receiving marketing emails by following the opt-out instructions in the email. We may still email you customer service and transaction-related communications, even if you have opted-out of receiving marketing communications.
• Establishment and maintenance of your account; invoicing: to provide online accounts and access of SmartBorder software solutions and tools; bill you for contracted products and services or outstanding debts.
• Applicants: To process applications for employment consideration.
• Analytics and improvement: to better understand how users access and use the services, and for other research and analytical purposes, such as to evaluate and improve the services and to develop additional products, services and features. While we may collect and analyze usage details (e.g., storage size used, access logs, etc.) related to content, we do not actually access content for these purposes.
• Advertising: to advertise our services on third-party sites and social media services.
• Planning and managing events: for event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
• Research and surveys: to administer surveys and questionnaires, such as for market research or member satisfaction purposes.
• Protect our legal rights and prevent misuse: To protect our customers, employees or property, and the services, prevent unauthorized access and other misuse, and where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or third party or violations of our Terms of Use or this Privacy Policy, or other unauthorized activities or misconduct.
• Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.
• Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping, and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business.
• Comply with legal obligations: including to comply with the law, our legal obligations, or legal proceedings; for example, we may disclose information in response to warrants, subpoenas, court orders, and regulatory or law enforcement.

How We Disclose Your Personal Information

Except with your consent, we will not sell, license, trade or rent your personal information for monetary value to or with third parties. We may disclose the personal information that we collect for the purposes described above, in order to provide our Services to you, to respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and as follows:

• Enterprise customers: SmartBorder is a data processor with respect to the information and personal information it processes in providing services related to customs clearance and brokerage services, vehicle transportation, international freight forwarding, management of business processes, trade management and consulting, and software products to our clients. We will only process this personal information under the instructions and on behalf of our clients, who are the controller of the data, and not for any other purposes except if specified in this Privacy Policy or with your consent.
• Vendors and service providers: we may share information about you with third-party vendors, consultants and other service providers (data processors) who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service and support providers. We obtain appropriate contractual and technical protections to limit these service providers’ use and disclosure of any information about you that we share with them.
• Third party platforms, providers and networks: we may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information that includes personal information available to third parties we may work with that provide advertising, campaign measurement, online and/or mobile analytics and related services. These third parties may receive or access browsing history and/or other data about your use of the Sites, in order to help us better reach individuals with relevant ads, measure our ad campaigns and/or to better understand how individuals interact with our Sites over time and across devices. (See the “Cookies, Tracking and Analytics” section below for more information)
• Our affiliates: we may disclose personal information we collect to our affiliates or subsidiaries, who will use and disclose this personal information in accordance with the principles of this Privacy Policy.
• As required by law: we release information about you if we believe we must do so to comply with the law or a subpoena, bankruptcy proceeding, or similar legal process.
• To protect rights: we may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of SmartBorder, you, or others.
• Business transfers: if SmartBorder is involved in a merger, acquisition, or sale of all or a portion of its assets, we may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, in order for you to continue to receive the same products and services from the third party in accordance with applicable law.

Aggregate and Non-identifiable Data

We may also collect, use, share, disclose and otherwise process aggregate, anonymized, and in some cases de-identified information related to our business and the Services for quality control, analytics, marketing, advertising, research or similar purposes. Where we use, disclose or otherwise process de-identified data we will maintain and use the information in de-identified form and not to attempt to reidentify the information, except in accordance with applicable privacy laws.

Your Privacy Choices and Rights

Subject to applicable laws, you have the right to access, correct, or request the deletion of your personal information. In certain circumstances, you may have the right to object to the processing of your personal information. We make available a number of ways that you can manage your privacy choices and submit privacy requests related to your personal information. These include:

Content: requests to access, delete, or modify content will be directed to the client who owns the account. If you wish to request access to personal information contained in content to delete, modify or limit use, please provide us with the name of the client who submitted your information to our Services. We will refer your request to that client and will support them as needed.

Access, review and correction you can help us maintain the accuracy of your personal information by notifying us of any changes to this information. You may contact SmartBorder via our Contact Us form and/or by emailing us at privacy@livingstonintl.com to request access to or correct or update of your personal information to request access to or correct or update of your personal information.

Targeted advertising/cookie preferences: as described in “Cookies, Tracking, and Analytics Information” section below, there are several ways that you can manage your preferences for targeting cookies and advertising by us and on our website. You can review or change your preferences for cookies and tags on our website, other than those that are necessary to operation and functionality, by adjusting your cookie settings here. These preferences are browser and devices specific. So, you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies you may need to reapply these settings.

Direct marketing choices: you can always opt-out of being contacted by us for direct marketing or promotional purposes by following the opt-out instructions located in the promotional communications we send, such as clicking an unsubscribe link in our marketing emails. Please note that if you opt-out of marketing communications, SmartBorder will continue to send you transactional or service-related communications, such as service announcements and administrative messages.

Complaints: we will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.

If you are a California resident, please review the “Additional Information for California Residents” section below, for specific information about your California privacy rights and how to exercise them.

How We Protect Your Personal Information

SmartBorder makes commercially reasonable efforts to ensure that personal information collected from you is protected against loss, theft and unauthorized access, disclosure, copying, use, or modification. This protection applies in relation to information stored in both electronic and hard copy form. Access to your personal information is restricted to selected employees or representatives. In addition, SmartBorder employs generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect personal information against loss and unauthorized access. Please note that no transmission over the Internet is 100% secure or error-free, and that processes, systems, and technologies used and maintained by SmartBorder may be subject to compromise. You acknowledge that we cannot be held responsible for any unauthorized or unintended access that is beyond our control.

Cookies, Targeting and Analytics

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, APIs and other mechanisms to automatically collect and record information about your browsing activities, and use of the Services, device and similar information within our Services and to target advertising and content across our Services and third-party sites and services. We may combine this “usage data” with other personal information we collect about you. We use this usage data to understand how our Services are used, track and resolve bugs and errors, provide, optimize and improve our performance of the Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes. You have certain choices about our use of cookies and tracking within the Services, as described in this section. For more information on the types of personal information we collect via cookies and similar mechanisms, please review the subsection “Automatically Collected Information” above and our Cookie Policy.

Cookies. When you visit our website, we or one of our third-party service providers may place a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is an alphanumeric identifier that is transferred to your device’s hard drive through your web browser for record-keeping purposes. The cookie cannot be read by any website other than the one that placed the cookie.

Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service. For example, we and our third-party service providers use cookies to collect and store Internet log information, such as what time the visits occurred, whether the visitor has been to this site before, and what site referred the visitor to the web page. General geographic data is also determined by the IP Address of the visitor’s computer. This information collected by the cookie is transmitted to our third-party service providers and is then used to evaluate visitors’ behaviour and to generate statistical reports for the website activity on our website and may be used for marketing or advertising purposes.

Pixel tags. Pixel (also referred to as web beacons, web bugs or clear GIFs) tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags, in connection with our services to, among other things, help us manage ads and content, and compile statistics about usage of our services. We may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“Third-Party Ad Companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these Third-Party Ad Companies, and we and them may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.

Managing Your Cookie Preferences

We make available several ways for you to manage your preferences regarding targeted advertising, matching and cookies within our Services. Many of these are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Services; in addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. Remember that you may continue to receive generic or “contextual” ads from us. You can manage your cookie preferences for our websites and opt-out of certain cookies as explained below.

• Cookie Settings: you can review or change your preferences for targeting cookies and tags by adjusting your cookie settings via our Cookie Preference Manager, accessible from the footer of our websites. Please note, that your preferences are browser and device specific.
• Browser Settings: in addition, you can block or disable cookies for the device and browser you are using, through your browser settings by following the procedure described in the ‘Tools or Preferences’ menu in your browser; however, certain features on our Sites may not be available or function properly if you block or disable cookies.
• Industry Ad Choice Programs: you can learn more about the information collection practices and “opt-out” procedures of many Third-party Ad Companies by visiting https://optout.networkadvertising.org/?c=1. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Sites. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

Links to Third-Party Sites

• Links to other websites: our services may include links to other websites with privacy practices that may differ from ours. Any information you submit to a website not belonging to SmartBorder is governed by that site’s privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.
• Plugins and social media widgets: our sites may include social media features and widgets (collectively “Widgets”), such as a “share this” button or other interactive mini-programs that run on our Sites. Widgets can be used to provide you specific services from other companies (e.g., displaying the news, opinions, music, etc.). Personal information, such as your email address, may be collected through the Widgets. Cookies may also be set by the Widgets to enable them to function properly. Widgets displayed on our sites are not hosted by SmartBorder and are subject to the privacy policies of the third-party company providing the Widget, and not this Privacy Policy.

SmartBorder is not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarize yourself with their privacy policies before providing them with your personal information.

Retention and Storage of Your Personal Information

We generally follow the rule to only keep your personal information for as long as required to fulfill the purposes for which it was collected. This means that we retain your personal information for a period of time corresponding to a statute of limitation setting out the period during which related legal claims may be filed in court. We may also retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity, or if you are also subject to another privacy policy which we provided to you.

Use or Disclosure for Marketing Purposes

If you have subscribed to receive SmartBorder’s updates, we may also use your personal information to send you relevant information based on your subscription preferences (for example, SmartBorder Insider for the latest trade news, product and information updates from us and/or our affiliates in the areas of trade compliance consulting, customs brokerage, vehicle transportation, freight forwarding, trade software and trade management, and up-coming webinar topics and registration information), including by means of direct marketing. We may also disclose your personal information to our affiliates so that they can send you promotional materials directly.

You can also unsubscribe from all updates on this page or by following the unsubscribe instructions in our e-mail. Note, however, that clients of SmartBorder will continue to receive periodic e-mails that relate to their business relationship with us. You can also choose not to allow us to use your personal information for marketing purposes by contacting us as outlined below in “Contacting Us”.

Children

We do not knowingly collect personal information from children under the age of 16. If we become aware that we have collected personal information from a child under the age of 16 without parental consent, we take steps to delete that information. If you are under the age of 16 and believe that you provided us with your personal information, please ask your parent(s) or guardian(s) to notify SmartBorder so we can delete all such personal information.

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will provide you in advance with reasonable notice of such changes, such as via prominent notice on our website or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt-out of such changes. The Privacy Policy posted at any time or from time to time via this website shall be deemed to be the Privacy Policy then in effect.

Contacting Us

In the event that you have any questions about SmartBorder’s Privacy Policy, or if you have reason to believe that we may have failed to adhere to this Privacy Policy, or if you want to exercise any of your rights, you may contact our Chief Privacy Officer via e-mail at privacy@livingstonintl.com or via mail at 405 The West Mall, Suite 400, Toronto, Ontario, M9C 5K7.

Effective Date: January 1, 2023

This section provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights, under California privacy laws.

Categories of Personal Information Collected and Disclosed. Our collection, use, and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out, generally, the categories of personal information (as defined by the CCPA) that we collect and have collected about California residents, as well as the categories of third parties third parties to whom we may disclose this information for a business or commercial purpose. In some cases (such as where required by law), we may ask you to consent or give you certain choices prior to collecting or using certain personal information.

Personal Information collected		Categories of third parties to whom we may disclose this information
Categories	Description
Identifiers	Includes direct identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers.	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries event organizers business partners who provide services you request advertising networks analytics providers social networks internet service providers operating systems and platforms others as required by law, or authorized or directed by you
Categories of Personal Information Described in Cal. Civ. Code § 1798.80	Includes personal information, such as name, contact information, account number, and financial or payment information) that individuals provide us in order to obtain our products and services. For example, this may include information collected when an individual registers for an account or enters into an agreement with us related to our services.	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries business partners who provide services you request others as required by law, or authorized or directed by you
Commercial Information	Includes records products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers.	service providers government entities and law enforcement our affiliates and subsidiaries business partners who provide services you request others as required by law, or authorized or directed by you
Internet and Electronic Network Activity Information	Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, and other services, and our marketing emails and online ads.	service providers government entities and law enforcement our affiliates and subsidiaries advertising networks analytics providers social networks operating systems and platform providers others as required by law, or authorized or directed by you
Audio, Video and Other Electronic Data	Includes audio, electronic, visual, thermal, olfactory, or similar information such as, thermal screenings and CCTV footage (e.g., collected from visitors to our offices/premises, photographs and images (e.g., that you provide us and customer support call recordings.	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries others as required by law, or authorized or directed by you
Employment information	Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries others as required by law, or authorized or directed by you
Education Information	Information about an individual’s educational history.	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries others as required by law, or authorized or directed by you
Characteristics of Protected Classifications Under California and Federal Law	Includes characteristics of protected classifications under US state or federal laws, such as race, sex, age, marital status, disability information and medical conditions (e.g., which we may collect in order to make available appropriate accommodations for events and other activities we host).	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries event organizers business partners who provide services you request others as required by law, or authorized or directed by you
Geolocation Information	Location information about a particular individual or device.	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries business partners who provide services you request others as required by law, or authorized or directed by you
Profiles and Inferences	Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries analytics providers others as required by law, or authorized or directed by you
Sensitive Personal Information	In limited circumstances, we may collect: Social security, driver’s license, state identification card, or passport number.	service providers advisors and agents government entities and law enforcement our affiliates and subsidiaries others as required by law, or authorized or directed by you

Sales and Sharing of Personal Information. The CCPA defines a “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. We do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available to third-party ad companies (e.g., through third-party tags on our websites) Identifiers and Internet and Electronic Network Activity Information to advertising networks, social networks, and service providers in order to improve and measure our ad campaigns and reach customers and potential customers with more relevant ads and content. Users can at all times opt out of third-party tags and cookies, other than those that are “essential”, by adjusting their cookie settings. Our Cookie Preference Manager is also accessible through the “Manage Cookies” or if you are in California, the “Do Not Sell or Share My Personal Information” link in the footer of our website. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.

Sources of Personal Information. As further described in the Information We Collect section above, we may collect personal information from the following sources:

• directly from you
• advertising networks
• data analytics providers
• social networks
• internet service providers
• operating systems and platforms
• public sources and entities
• business clients
• others as directed by

Purposes of Collection and Use. As described in more detail in the How We Use Your Personal Information section, we collect, use and otherwise process the above personal information in order to provide our Services to you, respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:

• Provide our services
• Customer support
• Process claims
• Customization and personalization
• Marketing and promotion
• Establishment and maintenance of your account and invoicing
• Analytics and improvement
• Advertising
• Planning and managing events
• Research and surveys
• Protect our legal rights and prevent misuse
• Auditing, reporting, corporate governance, and internal operations
• Comply with legal obligations

Notwithstanding the above, we only use and disclose sensitive personal information as authorized pursuant to the CCPA (section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)). Accordingly, we will only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.

As described in more detail in the How We Disclose Your Information section above, we may disclose your personal information for the purposes described above, in order to provide our Services to you, to respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and as follows:

• Enterprise clients
• Vendors and service providers
• Our affiliates
• Other website users
• Third party platforms, providers and networks
• In support of business transfers
• To comply with law and legal obligations
• To secure and protect rights
• In support of business transfers

CCPA Rights. You may request to review, make amendments, have deleted, or otherwise exercise your rights, under applicable privacy laws, with respect to your personal information that we hold by emailing us at the contact information below. Please note that we may maintain copies of information that you have updated, modified, or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law.

Under the CCPA, California residents have the following rights (subject to certain limitations):

• Right to know/access rights: The right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of personal information we have collected about them.
• Correction: the right to correct inaccurate personal information that we maintain about them.
• Deletion rights: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
• Opt out of sales and sharing: the right to opt-out of our sale and sharing of their personal information.
• To limit certain uses and disclosures of sensitive personal information: the right to limit our use or disclosure of sensitive personal information to those uses authorized by the CCPA. However, as explained above, we do not use and disclose sensitive personal information beyond what is authorized pursuant to the CCPA.

Submitting requests. California residentsmay exercise their privacy rights and submit CCPA requests as set forth below.

• Request to know/access, correct, delete and limit: California residents may submit CCPA requests to access/know, correct and delete their personal information maintained by us online by submitting a request via our Contact Us Form. Alternatively, California residents may submit a request by calling us at 1-800-387-7582(toll free).
• Requests to Opt Out: California residents may exercise their right to opt out online by submitting an opt out request via our Cookie Preference Manger, which is available from the footer of our websites. We will apply your opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In addition, our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org/.

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must email us with any requested information (or otherwise provide us with this information via the above toll-free number) to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual through the above-listed methods; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Your Privacy Rights Under California Shine the Light Law

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at privacy@livingstonintl.com and include in your request a current California address and your attestation that you are a California resident.

For more information about our privacy practices, you may contact us as set out in the Contacting Us section above.