Privacy Policy for California Residents (Effective January 1, 2023) 

This Privacy Policy for California Residents supplements the information contained in the Marquis General Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this policy to comply with the California Privacy Rights Act of 2020 amending and replacing the California Consumer Privacy Act of 2018 (CCPA), and any terms defined in the CCPA and/or CPRA have the same meaning when used in this policy.

Information We Collect

Our website, emails (with your consent, where required by law), and other products, services and platforms collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, our websites, digital applications, emails, and other products, services and platforms may have collected the following categories of personal information and sensitive personal information from California consumers, households or devices within the last twelve (12) months.

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

We obtained the categories of personal information and sensitive 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 and/or digital applications.
• Indirectly from public sources, such as social media platforms and online public databases.
• Indirectly from mailing list providers.

Use of Personal Information
We may use, sell, or disclose the personal information and sensitive personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we or our third-party service providers will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders and requests.
• To provide, support, personalize, and develop our websites, apps, emails, and other products, services and platforms.
• 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 investigating and addressing your concerns and monitoring and improving our responses.
• To personalize your website, apps, emails, or other product, service or platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, apps, emails, and other products, services and platforms.
• To help maintain the safety, security, and integrity of our websites, apps, emails, and other products, services and platforms, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our websites, apps, emails, and other products, services and platforms.
• 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 CPRA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

The Company will not collect additional categories of personal information or sensitive personal information, or use the personal information or sensitive personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
The Company may share your personal information and/or sensitive personal information by disclosing it to a third-party for a business purpose or for cross-context behavioral advertising purposes, or by selling it, subject to your right to opt-out of those sales or sharing (see ‘Sales or Sharing of Personal Information’ below).

We may share your personal information and/or sensitive personal information with the following categories of third parties:

When we disclose personal information and/or sensitive personal information for a business purpose or for cross-context behavioral advertising purposes, we enter a contract that describes the purpose and requires the recipient to both keep that personal information and/or sensitive personal information confidential and not use it for any purpose except performing the contract.

The CCPA prohibits third parties who obtain from us the personal information or sensitive personal information we hold from reselling it or sharing it for cross-context behavioral advertising purposes unless you have received explicit notice and an opportunity to opt-out of further sales or sharing (see ‘Sales or Sharing of Personal Information’ below).

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the categories of personal information identified in the above table for the following business purposes:

• Auditing:
  – counting ad impressions to unique visitors;
  – verifying positioning and quality of ad impressions; and
  – compliance with the CPRA and other standards.
• Helping to ensure security and integrity, specifically detecting or preventing security incidents or other illegal activity and prosecuting the responsible parties.
• Performing services on behalf of the business or its service provider, such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services.
• Undertaking internal research for technological development and demonstration.
• Verifying or maintaining quality or safety or improving or upgrading a service or device owned, manufactured, or controlled by or for the business.

Your Rights and Choices
The CPRA, as amended by the CPRA, provides consumers (California residents and households) with specific rights regarding their personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights.

Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information and sensitive personal information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you:

• The categories of personal and sensitive personal information we collected about you.
• The categories of sources for the personal and sensitive personal information we collected about you.
• Our business or commercial purpose for collecting, sharing or selling that personal and sensitive personal information.
• The categories of third parties with whom we share or sell that personal and sensitive personal information.
• If we sold or disclosed your personal information for a business purpose, or shared sensitive personal information for cross-context behavioral advertising purposes, three separate lists disclosing:

• • Sales, identifying the personal information categories that each category of recipient purchased;
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained; and
  • Sharing of sensitive personal information for cross-context behavioral advertising purposes, identifying the sensitive personal information categories that each category of recipient obtained.

• The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights
You have the right to request that we delete any of your personal and/or sensitive personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will delete or deidentify (and direct our service providers to delete) your personal and/or sensitive personal information 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, 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 et. 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 information that are compatible with the context in which you provided it.

Right to correct inaccurate personal information
You have the right to request that we correct any inaccuracies in the personal information we hold about you, taking into account the nature of the personal information and the personal information’s processing purposes.

Right to restrict sensitive personal information processing
You have the right to restrict how we use and disclose your sensitive personal information. Please note, however, that this restriction right does not apply to sensitive personal information that we collected or processed without the purpose of inferring characteristics about you.

Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, Share, Opt-Out, Restrict Processing), we will review your request to see if an exception allowing us to process the information applies. We may deny your request if processing the information is necessary for us or our service provider(s) to:

• Ensure security and integrity, if the use is reasonably necessary and proportionate.
• Provide short-term, transient use of the information, including but not limited to non-personalized advertising shown as part of your current interaction with us, if we do not:
  • disclose the sensitive personal information to another third party; or
  • use it to build a profile about you or otherwise alter your experience outside your current interaction with us.
• Perform services for us, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing, storage, or providing similar services for us.
• Activities required:
  • to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us; and
  • to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
• As otherwise authorized by regulations the California Privacy Protection Agency may adopt.

Exercising Your Rights to Know, Delete, Correct, Opt-Out from, Restrict, and your Data Portability Right
To exercise your rights to know, delete, correct, opt-out from, or restrict processing described above, please submit a request to us by either:

• Calling us at (844) 394-6946; Monday-Friday, 9:00 a.m. to 5:00 p.m. (U.S. Eastern Time)
• Emailing us at datarights@marquisww.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your child under 18 years of age.

You may only make a request to know, delete, correct, opt out from, restrict processing, or for data portability twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal and/or sensitive personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal and/or sensitive personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a request does not require you to create an account with us.

We will only use personal and/or sensitive personal information provided in a request to verify the requestor’s identity or authority to make the request.

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

Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us using the contact information under Exercising Your Rights to Know, Delete, Correct, Opt-Out from, Restrict, and your Data Portability Right.

We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time, 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 option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your 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 and/or sensitive personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your 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.

Personal Information Sales or Sharing 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 or share your sensitive personal information for cross-context behavioral advertising purposes at any time (the “right to opt-out”). We do not sell or share for cross-context behavioral advertising purposes the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers 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://donotsellorshare.marquiswhoswho.com/

Note that although we will not sell or share your personal and/or sensitive personal information after you click that button, we will continue to share some personal and/or sensitive personal information with our partners (who will function as our service providers in such instance) to help us perform advertising-related functions such as, but not limited to, measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads and/or reducing ad fraud.

Additionally, although clicking the “Do Not Share or Sell My Info” link will opt you out of the sharing or sale of your personal and sensitive personal information for advertising purposes, it will not opt you out of the use of previously collected, shared and sold personal information (except for personal information shared or sold within 90 days prior to your exercising your right to opt out) or all interest-based advertising. If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. t.

Sensitive Personal Information Use Limitation
If you are age 16 or older, you have the right to direct us to limit the use of not sell your sensitive personal information at any time (the “right to opt-out”). We do not use the sensitive personal information of consumers we actually know are less than 16 years old[, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old]. Consumers who opt-in to the use of their sensitive personal information may opt-out of future use 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://limituse.marquiswhoswho.com/

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or the sharing of your sensitive personal information for cross-context behavioral advertising purposes. However, you may change your mind and opt back in to personal information sales or to the sharing of your sensitive personal information for cross-context behavioral advertising purposes at any time by clearing cookies from your browser or emailing optout@marquisww.com.

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

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA (as applicable), we will not:

• Deny you goods or services.
• Charge you different prices or rates for like-goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of like-goods or services.
• Suggest that you may receive a different price or rate for like-goods or services or a different level or quality of like-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 and/or CPRA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value 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.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites, mobile applications, and other products, services and platforms 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 datarights@marquisww.com or write us at: Marquis Who’s Who Ventures, LLC, 350 RXR Plaza, Uniondale, NY 11556 .

Changes to Our Privacy Notice
The Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website at https://www.marquiswhoswho.com/pages/privacy-policy update the notice’s effective date. Your continued use of our websites, and other products, services and platforms following the posting of changes constitutes your acceptance of such changes.

Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

If you need to access this notice in an alternative format due to having a disability, please contact us using any of the above contact information.