Privacy Policy

ETI, LLC

Introduction

ETI, LLC “ETI” (“Company” or “We”) respects the privacy of your Personal Information and is committed to protecting it through our compliance with this Privacy Policy.

This Policy describes the types of Personal Information we collect from you or that you may provide when you visit our website(s), www.ETIcomm.com, www.ETIComm.net or access, register with, or use our Mobile App or other services (our “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing Personal Information.

This Policy applies to Personal Information we collect:

• On this Website.
• In email, text, and other electronic messages we, and our vendors and service providers, send you.
• Through our Website, App and other Services you access or use.
• Through any devices that access or use our Website, Apps or other Services including devices operated by our vendors and/or their staff.
• When you interact with our advertising and applications on third-party websites and services.

It does not apply to Personal Information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Website, Apps or other Services.
• You provide to, or is collected by, any third party (see Third-Party Information Collection).

Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website, Apps or other Services. This Policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of our Website, Apps, or our other Services after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Children Under the Age of 16

Our Website, Apps and other Services are not intended for children under 16 years of age. No one under age 16 may provide any Personal Information on our Website or through our Apps or other Services. We do not knowingly collect Personal Information from children under age 16. If you are under 16 years old, do not use or provide any information on this Website or through any of our Apps or other Services or their features, including registering a user account, making purchases, or using any of the interactive or public comment features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

Personal Information We Collect and How We Collect It

We collect several types of Personal Information from and about visitors and users of our Website, Apps and other Services, including information:

• From which you can be personally identified, such as your name, postal address, e-mail address, telephone number, birthdate, and any other identifier by which you may be contacted online or offline (“Personal Information“);
• That is about you but does not identify you individually, such as dietary preferences, and military/veteran/first responder status for special offers, etc.; and/or
• About your internet connection, the equipment you use to access our Website, Apps or other Services, and your usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through this Website and use our Apps and other Services. Information collected automatically includes your usage details, your IP address and or device ID, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our vendors, business partners and/or service providers.

Personal Information You Provide to Us

The Personal Information we collect on or through our Website, Apps and other Services includes:

• Personal Information that you provide by filling in forms on our Website or in our Apps or other Services. This includes information you provide when you register to use our Apps and other Services, subscribe to our marketing communications, submit feedback, post content, or request help or other customer services. We also ask you for Personal Information when you enter a contest or promotion sponsored by us or our Hospitality Merchants, and when you report a problem about our Website, Apps or our other Services.
• Records and copies of your communications with us such as your email address or phone number, when you contact us.
• Your responses to surveys that we or our vendors, business partners or service providers ask you to complete for our research purposes.
• Details of transactions you carry out through our Website, Apps and other Services and of the fulfillment of your orders such as: date and time of transaction; day of week; location of transaction; items purchased; number of employees; form of payment; total spent; offers and coupons redeemed; and occasions such as birthday/anniversary, etc. You may also be required to provide financial information before placing an order through our Services.
• Your search queries on our Website, Apps or other Services.
• Information our vendors may request in order to provide you with special offers such as your anniversary, military/veteran/first responder status, and/or other preferences, etc.

You may also provide information to be published or displayed (hereinafter, “posted“) on public areas of our Website, Apps or our other Services or transmitted to other users or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Website, Apps or our other Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Personal Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, Apps and/or other Services, we use automatic data collection technologies to collect certain Personal Information about your equipment, browsing actions and patterns, including:

• Usage Details of your visits to, and use of, our Website, Apps and other Services, including traffic data, location data, logs, and other communication data and the content that you access and use on the Website, Apps and/or our Services.
• Device Information about your computer, mobile device, and internet connection, including your device’s unique device identifier (IP address/device ID), operating system, browser type, mobile network information and your mobile device’s telephone number.
• Location Information through our Website, Apps and other Services collect real-time information about the location of your device during the time that you are accessing and/or using our Apps and Services such as the location of your transaction.

If you do not want us to collect this information do not use our Website, Apps or other Services. For more information, see YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION below. Note, however, that opting out of our Website, Apps or other Services collection of location information will disable its location-based features.

We also use these technologies to collect information about your online activities over time and across third-party websites, apps, or other online services (behavioral tracking). Some web browsers may transmit “do-not-track” signals to our Website, Apps and other Services. At this time there is no industry standard about our Services should do when those signals are received. As a result, our Services do not currently respond to “do-not-track” signals.

The information we collect automatically is statistical data and does not include Personal Information but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties including our vendors and service providers. It helps us to improve our Website, Apps and other Services and to deliver better and more personalized services, including by allowing us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website, Apps and other Services to your individual interests and preferences.
• Speed up your searches.
• Recognize you when you return to our Website and use or access our Apps or other Services.
• Using location information we collect to provide you with content specific to your location and to personalize your service experience for you.

Personal Information Collection and Tracking Technologies

The technologies we use for automatic data collection include:

• Cookies (or browser cookies/mobile cookies). A cookie is a small file placed on the hard drive of your computer or your mobile device for example to recognize you when you return to our Website, Apps and other Services. You may refuse to accept cookies by activating the appropriate setting on your browser or mobile device. However, if you select this setting, you may be unable to access certain parts of our Website, Apps or our other Services. Unless you have adjusted your device settings so that it will refuse cookies, our systems will issue cookies when you visit, access or use our Website, Apps and/or other Services. For more information see our More Cookie Info Page.
• Flash Cookies. Certain features of our Website, Apps and other Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website, Apps and other Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Your Choices About How We Use and Disclose Your Information below and our More Cookie Info Page
• Web Beacons. Parts of our the Website, Apps and other Services, and our e-mails contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain of our Website, App, or other Services content and verifying the integrity of our systems and servers).

Third-Party Collection of Personal Information and Use of Cookies and Other Tracking Technologies

Some content or functions on our Website, Apps and our other Services are provided by third-parties including content providers, application providers, our service providers and/or our vendors. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website, Apps and/or other 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, apps and other online services. They also use this information to provide you with interest-based (behavioral) advertising or other targeted content.

These third parties include:

• Our vendors.
• Our Service Providers (including payment processors).
• Advertisers, ad networks, and ad servers.
• Analytics companies (including Search Engine Analytics).
• Your mobile device manufacturer.
• Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use our Website, Apps or other 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, apps, and other online services websites.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly. For information about how you can opt out of receiving targeted advertising/content from many providers, see Your Choices About How We Use and Disclose Your Information below and our More Cookie Info Page.

How We Use Personal Information

We use Personal Information that we collect about you or that you provide to us to:

• Present our Website, Apps, and other Services and their content to you, and any other information that you request from us.
• Fulfill any other purpose for which you provide it, such as to process your orders including payment transactions and product & service delivery.
• To personalize your experience such as sending you offers from our vendors near the delivery address you have previously provided us.
• Provide you with notices about your account and or subscription, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you about changes to our Website, Apps or Services we offer or provide including when updates to our Website, Apps and other Services are available.
• Allow you to participate in interactive features on our Website, Apps and other Services.
• In any other way we describe when you provide the information.
• For other purposes with your consent.

We also use Personal Information to contact you about our own and our vendors’ products and services that may be of interest to you. If you do not want us to use Personal Information relating to you in this way, please check the relevant box located on the form where we collect information from you, or your order or registration form. You can also adjust your user preferences in your account profile through our Website, Apps and/or our other Services. For more information, see Your Choices About How We Use and Disclose Your Information below.

We may also use the information we collect to display advertisements to our 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.

Disclosure of Personal Information

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

In addition, we may disclose Personal Information that we collect, or you that you provide us as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• 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 assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Company about users of our Website, Apps and other Services is part of the assets transferred.
• To our vendors to market their products or services to you if you have consented to these disclosures. We contractually require our vendors to keep Personal Information confidential and to use it only for the purposes for which we disclose it to them. For more information, see Your Choices About How We Use and Disclose Your Information.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, Apps or other Services, we will transmit the contents of that email and your email address to the recipient. Note, we may block your use of our “email a friend” feature if we determine that your attempted use of that feature may violate any applicable laws including anti-SPAM laws. For more information, see our Terms of Use.
• For any other purpose disclosed by us when you provide the information to us.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our vendors, or others. This includes exchanging information with other companies and organizations for the purposes of fraud prevention and credit risk reduction.

Your Choices About How We Use and Disclose Personal Information

We strive to provide you with choices regarding Personal Information you provide to us. We have created mechanisms for you to control certain uses and sharing of over Personal Information:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow our Website, App and other Services to collect information through other tracking technologies. 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 our Website, Apps and other Services may not be accessible or not function properly.
• Location Information. You can choose whether or not to allow our Website, Apps or other Services to collect and use real-time information about your device’s location through your device’s privacy settings. If you block the use of location information, some parts of our Website, Apps and other Services may become inaccessible or not function properly.
• Disclosure of Personal Information for Promotional Offers from Us and Our Vendors. If you do not wish to have your email address or other contact information used by us to promote our own or our vendors’ products or services, you can opt-out by checking the relevant box located on the form where we collect Personal Information, your order or registration form or by visiting our Subscription Center through our Website, Apps or our other Services. You may also Opt-out from any account page, by replying STOP to an SMS message, or selecting “unsubscribe” from the footer of any email. You may also send us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to Personal Information you provided us related to a product purchase, customer service request or other transaction.
• Disclosure of Personal Information for Third-Party Advertising and Marketing. If you do not want us to share Personal Information about you with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out at any time by logging into your user account on our Website, Apps or other Services and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected].

We do not control third parties’ collection or use of Personal Information to serve interest-based advertising. However, these third parties may provide you ways to choose not to have Personal Information about you 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 website here https://optout.networkadvertising.org/

California residents may have additional Personal Information rights and choices. Please see our Privacy Notice for California Residents, below.

Accessing and Correcting Personal Information in General

You can review and change your Personal Information by logging into our Website, App and other Services and visiting your account profile page.

You may also send us an email at [email protected] to request to correct any Personal Information that you have provided to us. We may not accommodate a request to change Personal Information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from our Website, App, or other Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users. Proper access and use of information provided on our Website, App, and other Services including User Contributions, is governed by our Terms of Use.

Security of Personal Information

We have implemented reasonable measures designed to protect the security, confidentiality, and integrity of Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All Personal Information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of Personal Information also depends on you. Where you may have chosen a password for access to certain parts of our Website, App or other Services, you are responsible for keeping your password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our Website, Apps and other Services like message boards. The information you share in public areas may be viewed by any user of our Website, Apps and other Services.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted through our Website, App or other Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Privacy Policy on this page with a notice that the Privacy Policy has been updated on the home page of our Website and in our Apps and other Services. We will notify you by email and/or text message to the primary email address or mobile phone number specified in your account and through a notice on the Website home page. The date the Privacy Policy was last revised is at the top of the page. You are responsible for making sure we have an up-to-date active and deliverable email address and phone number for you, and for periodically reviewing this Privacy Policy to check for any changes.

Our Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

[email protected]

ETI, LLC Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in our General Privacy Policy/Notice above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Where noted in this Notice, the CCPA temporarily exempts Personal Information reflecting a written or verbal business-to-business communication (“B2B Personal Information“) from some its requirements.

CCPA Personal Information We Collect

We collect Personal Information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information“). Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:

• • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website, Apps and other Services.

Use of CCPA Personal Information

We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the Personal Information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your Personal Information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, App and other products, and Services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience on our Website, Apps and other Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, Apps and other Services, our vendors, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, Apps, and other Services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, Apps, and other Services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To 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 Website, Apps or other Services users/consumers is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing CCPA Personal Information

We may disclose Personal Information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see CCPA Personal Information Sales Opt-Out and Opt-In Rights below). When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share Personal Information with the following categories of third parties:

• Service providers.
• Data aggregators.

Disclosures of CCPA Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category K: Inferences drawn from other Personal Information.

We disclose Personal Information for a business purpose to the following categories of third parties:

• Our Vendors
• Our Service Providers

Sales of CCPA Personal Information

In the preceding twelve (12) months, Company has sold the following categories of Personal Information:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category K: Inferences drawn from other Personal Information.

We sell Personal Information to the following categories of third parties:

• Our Vendors
• Data aggregators

CCPA Rights and Choices

The CCPA provides California residents with specific rights regarding Personal Information. This section describes CCPA rights and explains how to exercise those rights.

Access to Specific CCPA Personal Information and Data Portability Rights

California residents have the right to request that we disclose certain information to them about our collection and use of Personal Information about them over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising CCPA Access, Data Portability, and Deletion Rights below), we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold or disclosed Personal Information about you for a business purpose, two separate lists disclosing:

• • sales, identifying the Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B Personal Information.

CCPA Deletion Request Rights

California residents have the right to request that we delete any Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising CCPA Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) Personal Information about you from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B Personal Information.

Exercising CCPA Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1.856.753.9840
• Emailing us at [email protected]
• Visiting https://eticomm.com/ccpa/

Only California residents, or someone legally authorized to act on their behalf, may make a verifiable consumer request related to Personal Information. You may also make a verifiable consumer request on behalf of your minor child. Please note that Company does not make its App and other Services available to children under the age of 16.

California residents may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with enough detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to Personal Information requests or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights below.

CCPA Response Timing and Format

We endeavor to respond to a verifiable CCPA consumer request within forty-five (45) days of receiving it. If we require more time up to 90 days, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your choice.

Any disclosures we provide will only cover the 12-month period before we receive the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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 without hindrance, specifically text formatted file(s) which may contain plain text or delimited data.

We do not charge a fee to process or respond to your verifiable CCPA consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

CCPA Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not collect or sell the Personal Information of consumers we actually know are less than 16 years of age. California residents who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://www.eticomm.com/CCPA

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by emailing us at [email protected]

You do not need to create an account with us to exercise your CCPA opt-out rights. We will only use Personal Information provided in a CCPA opt-out request to review and comply with the request.

CCPA Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of the Personal Information’s and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. Americana does not currently provide any financial incentives.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website 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 send an email to [email protected]

CCPA Contact Information

If you have any questions or comments about this notice, the ways in which Company collects and uses CCPA Personal Information described here and in our general Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1.856.753.9840

Website: www.eticomm.com/CCPA

Email: [email protected]

Postal Address:

ETI, LLC

Attn: Legal Department

51 Everett Dr, Ste A40, Princeton Jct, NJ 08550