PRIVACY POLICY

WELLBIZ BRANDS, INC. PRIVACY POLICY

 

Effective Date: May 27, 2025

Last Reviewed: May 25, 2025

Introduction

WellBiz Brands, Inc. and its Affiliates, Affiliated Brands and subsidiaries (collectively, “us,” “we,” “our,” or “WB”), are committed to providing clients with exceptional service. As part of our services, we may collect, use, and disclose your Personal Information (defined below).

This Privacy Policy explains our privacy practices, including what Personal Information we may collect, how we may use it, for what purposes, with whom we may share it, and your rights with respect to information we maintain about you. “Personal Information” is any information that, either on its own or in combination with other data, which uniquely identifies an individual.

This Privacy Policy applies to all WB websites, mobile phone applications, the website(s) at https://wellbizbrands.com, and specifically includes any branded website(s) or mobile phone applications developed for any of our Affiliates or Affiliated Brands (the “WB Sites”). WB Sites include:

• https://drybarshops.com/;
• https://elementsmassage.com/;
• https://amazinglashstudio.com/;
• https://fitnesstogether.com/;
• https://radiantwaxing.com/;
• https://theglowpass.com/; and
• https://wellbizbrands.com/.

By using or accessing the WB Sites and Affiliated Brands’ franchised locations sites, including storefronts, you agree to the collection and use of information in the manner described in this Privacy Policy. We shall have the right at any time and without prior notice, at our sole discretion, to revise this Privacy Policy. Such revisions and additions shall be effective immediately upon notice, which may be given by posting the revised or additional terms on WB Sites. You are responsible for reviewing the WB Sites periodically for any modification to this Privacy Policy.

This Privacy Policy and our Consumer Health Data Policy are part of our Terms of Service. If you do not agree to the practices in this Privacy Policy, Consumer Health Data Policy, and/or our Terms of Service, do not use or access the WB Services (defined below).

For the purposes of this policy, the term “Affiliate” shall mean any entity, individual, firm, or corporation, directly or indirectly, through one or more intermediaries, controlling, controlled by, or under common control with WB. The Amazing Lash Studio^®, Drybar^®, Radiant Waxing^™, Fitness Together^®, and Elements Massage^® franchise systems and GlowPass™ brand are collectively referred to as the “Affiliated Brands.”

Please note that franchisees of the Amazing Lash Studio, Drybar, Radiant Waxing, Fitness Together, and Elements Massage franchise systems (each a “Franchisee”) are each independent entities and their processing of information may be subject to their own privacy policies. For more information on how a specific Franchisee processes your information, please direct your request to the relevant Franchisee location.

This Privacy Policy does not apply to the online store and website located at www.thedrybar.com (“Drybar Products Online”), owned and operated by Drybar Products LLC, a Helen of Troy Ltd. subsidiary. Please note that while we work closely with the foregoing parties and allow users to use their WB online accounts at Drybar Products Online, we are not the same company, and their privacy policy located at www.thedrybar.com/privacy will govern the collection, use, and disclosure of your Personal Information in connection with Drybar Products Online.

WB is a U.S.-based company, but provides services in the United States and in other countries. Separate privacy policies govern services and operations at WB locations outside the United States. For services and locations within the United States, this Privacy Policy applies. The data protection laws and government access rights in your state, province, or country may differ from those in the United States. WB will process your Personal Information for Services controlled and offered from locations in the United States, as described in this Privacy Policy.

SECTION 1 – PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY COLLECT IT

Personal Information You Provide to Us. Personal Information you may provide to us includes:

• Contact information, including but not limited to your first and last name, email and mailing addresses, postal code, phone number, and social media aliases.
• Profile information, such as your username and password that you set to create an online account with us, and other information you include in your account profile.
• Haircare preferences, such as your hair type, hair concerns, and the products and services you have received from Drybar Products Online or in a Drybar shop, and services you have received from a Drybar shop.
• Service information, such as massage sessions, eyelash extension services, waxing services, personal training services preferences, products, gift cards, and other Services you purchase from us. This also includes information about you that is directly related to the Service you have requested, such as gender-related information, including non-binary or transgender, physical condition or diagnosis, and medications.
• Communications information, such as communications that we exchange when you contact us, such as when you request support, contact us with questions or feedback, or complete our surveys.
• Internet usage and device information, such as browsing history, search history, and information on your interaction with a website, application, email, or advertisement, including comments, text, images, audio, video, or other content you post to or provide through WB Sites or when interacting with our social media accounts.
• Appointment information, such as your past and upcoming appointment dates and locations and the Services you have requested.
• Payment and transactional information, such as the information needed to complete your in-store orders and purchases (such as name and credit card information), information about your payment transactions, and your order and purchase history.
• Information about your marketing preferences, such as your preferences for receiving communications about Affiliated Brands’ franchised locations, products, services, activities, events, and publications; details about how you engage with our communications; and information you provide when you participate in an event, contest, or promotion.
• Information about your health, known as “Consumer health data,” such as physical diagnosis, prescribed medications, and treatment information. We collect this information solely as it relates to the Services we provide. PLEASE NOTE: CONSUMER HEALTH INFORMATION IS COVERED BY OUR CONSUMER HEALTH DATA POLICY, AVAILABLE HERE.
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

• Sensitive Information Disclosure: We collect the following categories of sensitive personal information: gender information including whether an individual is non-binary or transgender; mental or physical condition or diagnosis; and precise geolocation data. We collect this information to process transactions, comply with laws, manage our business, provide you with our services, or protect our employees and patrons.

 

Third party sources. We may collect information about you from third party sources and may combine Personal Information we receive from you with Personal Information we obtain from those other sources, such as:

• Data providers, such as information services and data licensors.
• Public sources, such as public social media platforms.
• Business partners, such as joint marketing partners, licensors/licensees, joint venture partners, and event co-sponsors.
• Affiliates and Affiliated Brands franchised locations for which you may also be a consumer.

Automatic collection. We, our service providers, and our business partners may automatically collect information about you, your computer or mobile device, and your activity over time on the WB Sites and other online sites and services, including:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, internet service provider, the website you visited before browsing to our website, and general location information such as city, state, or geographic area.
• Online activity data, such as what pages you visit, what products or files you view, referring/exit pages, and the third-party sites that led you to our site or mobile application.
• Location Information: precise geolocation data, such as when you authorize our mobile application or your web browser to access your exact location.

Cookies and similar technologies. Some of our automatic data collection on WB Sites is facilitated by:

• Cookies, which are text files that websites store about a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of tracking user activity and patterns, helping you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience.
• Flash cookies, or locally stored objects, which are used for purposes similar to cookies but allow storage of a larger amount of data.
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened or that certain content was viewed or clicked, typically to compile statistics about the usage of websites and the success of marketing campaigns.
• Software development kits, or SDKs, which are used to incorporate third party computer code into our application that allows the third party service providers or advertising partners to collect data directly from it for a variety of purposes, including to provide us with analytics regarding the use of the Drybar mobile application, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.

Information about others. You may have the opportunity to share Personal Information about others with us, such as when you book an appointment for them through WB Sites, purchase a gift card for a third party, or refer friends or other contacts to WB Sites or Services. When you share the Personal Information of others with us, you are responsible for ensuring you have their permission to do so.

Information from Drybar Products Online. As part of our integration with Drybar Products Online, they will provide us with certain Personal Information about you, such as profile and contact data, including name, phone number, e-mail address, and product purchase history relating to your shared account on the WB Sites and with Drybar Products Online, your marketing preferences data, and certain transactional data relating to your online purchases.

SECTION 2 – HOW WE MAY USE PERSONAL INFORMATION

We may use Personal Information for business and commercial purposes such as to:

• provide, operate, and improve the WB Sites, such as when we or Affiliated Brands’ franchised locations use your Personal Information to schedule and confirm appointments with you and process your transactions for the blowouts services, massage sessions, eyelash extension services, waxing services, personal training services, products, gift cards, and other services you purchase in these locations or using the WB Sites;
• verify your identity;
• determine whether you may have, or have been exposed to, COVID-19 (strictly to safeguard our personnel and other patrons);
• prevent fraud and abuse;
• identify your shopping preferences and your shopping activities;
• open and manage your account;
• deliver requested products and services or respond to questions;
• process a reservation, as well as provide services;
• enroll you in a program;
• send you Affiliated Brands’ franchise location newsletters, coupons, updates, reminders, related email marketing, and other information;
• ensure a high standard of service to you;
• meet regulatory requirements;
• send SMS updates, appointment reminders, and special marketing promotions;
• promote Affiliated Brands’ franchised locations products or services to you;
• respond to your queries and communicate with you about the WB Sites, including by sending announcements, updates, security alerts, and support and administrative messages;
• keep track of customer feedback, understand your needs and interests, and personalize your experience with the WB Sites and Affiliated Brands’ franchised locations communications; and
• improve customer service and provide support and maintenance for the WB Sites.

Research and development. We may use your Personal Information for research and development purposes, including to customize the data activities on the WB Sites, improve the online experience, analyze the activities on the WB Sites, and improve our Sites and Services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from Personal Information we collect. We anonymize data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the data activities on the WB Sites and promote our businesses.

Marketing and advertising. We, our Affiliated Brands’ franchised locations, and our third-party advertising partners may collect and use your Personal Information for marketing and advertising purposes:

• Direct Marketing. We may send you direct marketing communications as permitted by law, including but not limited to communications from our Affiliates and Affiliated Brands’ franchised locations for their respective products or services. You may opt-out of marketing communications as described below.
• Interest-Based Advertising. We may contract with third-party advertising companies and social media companies to display ads on the WB Sites and other websites. These companies may use cookies and similar technologies to try to tailor the ads you see online to your interests based on your activity over time across the WB Sites and other websites or your interaction with Affiliated Brands’ email communications. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising in the “Advertising choices” section below.

Compliance and Operations. We may use your Personal Information in the following circumstances:

• When the collection, use, or disclosure of Personal Information is permitted or required by law;
• In an emergency that threatens your or others’ life, health, or personal security;
• To comply with orders of public health authorities and related obligations;
• When the Personal Information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer or for auditing and other professional services;
• For the purposes of collecting a debt or to protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law; and

To prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

For other purposes. We may also use your Personal Information for other purposes described in this Privacy Policy or disclosed at the time we collect the information.

SECTION 3 – HOW WE MAY SHARE YOUR PERSONAL INFORMATION

We may share your Personal Information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Other Users and the Public. If at any time the WB Sites offer any chat rooms, comment options, notice-board, review options, social media plug-ins, newsgroups, etc., information that you post or make available may be collected by other users or the public. Please note that we are not responsible for other parties’ use of the Personal Information you choose to share publicly, which you may make available to such third parties through any chat room, social media post, or “like,” comments, notice-board, newsgroup, etc. on the WB Sites or other public websites. Please be careful about what Personal Information you disclose in this way.

Affiliates. We may share your Personal Information with WB’s corporate parents, subsidiaries, Affiliated Brands, franchised locations, third-party vendors (including but not limited to Helen of Troy and Drybar Products Online), and Affiliates, for purposes consistent with this Privacy Policy.

Service Providers. We may share your Personal Information with unrelated companies and individuals that provide services on our behalf or help us operate the WB Sites or our Affiliated Brands’ franchised business (for purposes such as customer support, hosting, payment processing, appointment booking, analytics, email delivery, marketing, and database management services). These third parties may use your Personal Information only as authorized under our contracts with them. These third parties will only use your Personal Information for purposes consistent with this Privacy Policy and the services they provide.

Business Partners. We may share your Personal Information with our business partners, such as joint marketing partners, licensors/licensees, joint venture partners, and event co-sponsors. We may also share your information with Drybar Products Online and Helen of Troy Ltd. This information will only be shared as necessary to provide you with Services in accordance with our Terms of Service and this Privacy Policy. The purpose of this sharing is to facilitate providing joint services, internal statistics, and strategic decision-making. Your information will be shared consistent with your marketing preferences.

Advertising Partners. We may sometimes share your Personal Information with our advertising partners and may enable such partners to collect information directly via the WB Sites for the purposes described in the Marketing and Advertising section above.

Professional Advisors. We may share your Personal Information with professional advisors, such as lawyers, bankers, financial advisors, accountants, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and Others. We may share your Personal Information with law enforcement, government authorities, and private parties, when we believe in good faith it is necessary or appropriate as further described in the “Compliance and Operations” sub-section above.

Business Transferees. We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, with relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, WB, our parents, subsidiaries, or Affiliates, and Affiliated Brands  (including, in connection with a bankruptcy or similar proceedings). If WB, any Affiliate, or any Affiliated Brand is acquired or merged with another company, your information may be transferred to the new owners so that they may continue to service or sell products to you.

For Other Purposes. We may also share your Personal Information for other purposes described in this Privacy Policy or with your consent.

Information We May Share with Third Parties

Personal Information we collect that may be shared with the parties described in this section includes all information described within Section 1 “Personal Information We May Collect and How We May Collect It.”

Sensitive Information Disclosure

We may share with third parties the categories of sensitive personal information described in Section 1 “Personal Information We Collect.” This information is shared only to process transactions, comply with laws, manage our business, provide you with Services, or safeguard our personnel and other patrons.

SECTION 4 – YOUR CHOICES

In this section, we describe the rights and choices available to all users.

Opt-Out of Marketing Communications. If you no longer wish to receive marketing-related emails from us, you may opt out by clicking the “unsubscribe” option in the email message, informing us at [email protected], or mailing us at: Legal Dept / 1890 Wynkoop St., Unit 1, Denver CO 80202, call (866) 969-5666. You may continue to receive service-related and other non-marketing emails.

If you consent to receive text messages, you may receive auto-dialed appointment confirmations and reminders in addition to marketing or promotional texts. You may receive SMS or MMS messages. Message and data rates may apply, check with your cellular or data carrier for information. Appointment confirmations and reminders will be based on the number of appointments you make. Consent to receive text messages is not required/not a condition for purchase of products or Services. You can opt out of receiving text messages. To stop receiving text messages, reply STOP to any text message you receive.

Choosing Not to Share Your Personal Information. Subject to certain exceptions (e.g., the Personal Information is necessary to provide our Services or products, or when we must use your Personal Information to perform a legal obligation), you can choose not to share your Personal Information with us. If you do not provide this Personal Information when requested, it may restrict our ability or the ability of our Affiliated Brands’ franchised locations to provide a particular service or product. If so, we will explain the situation to assist you in making the decision that is right for you by telling you what information you must provide to receive the services by designating it as required at the time of collection or through other appropriate means.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the WB Sites and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the WB Sites may not work properly. Similarly, if you would like to remove previously stored cookies, your browser settings may allow you to clear your browser web storage.

Location Data. Users of our mobile application also have the choice whether to allow us to access their precise location data. Your device settings may provide the ability for you to revoke our ability to access location data. Most web browsers also have the choice to allow us to access your precise location data. To disable this feature, please check your browser settings.

Advertising Choices. Some of the business partners that collect information about users’ activities on or through the WB Sites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targeted advertising on websites from members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our or our partners’ ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

SECTION 5 – SECURITY

The security of your Personal Information is important to us. We employ a number of organizational, technical, and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Information.

SECTION 6 – OTHER SITES, MOBILE APPLICATIONS AND SERVICES

The WB Sites may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites, mobile applications, and services follow different rules regarding the collection, use, and sharing of your Personal Information. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

SECTION 7 – CHILDREN

The WB Sites are not intended for use by children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If you are aware that we have collected the Personal Information of a child under the age of 13 without required consent, please let us know so that we can delete any such information in our control.

SECTION 8 – CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated from time to time for any reason. If we make material changes to this Privacy Policy, we will notify you by posting the new Privacy Policy on the WB Sites and changing the “Effective Date” above. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the WB Sties. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the WB Sites after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

SECTION 9 – HOW TO CONTACT US

Please direct any questions or comments to: Legal Dept / 1890 Wynkoop St., Unit 1, Denver CO 80202, [email protected], or call (866) 969-5666.

SECTION 10 – IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

This section applies only to California residents. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018, (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”), but does not include information exempted from the scope of the CCPA.

Personal Information that We Collect, Use and Share. We have created a table below which summarizes the Personal Information we have collected by reference to the categories specified in the CCPA, during the preceding 12 months.

Category of Personal Information (PI) as specified in the CCPA (Definitions are available  here)	Details of PI we collect (See the “Personal Information We Collect” section above for more details)
Identifiers	Contact data Profile data Communications Information about others (such as the name and address of gift card recipients)
Financial Information	Payment and transactional data
Commercial Information	Blowouts services, massage sessions, eyelash extension services, waxing services, personal training services, products, gift cards, and other services you purchase in franchise locations or using the WB Sites Communications Appointment information Payment and transactional data Marketing data Online activity data
Internet or Network Information	Marketing data Device data Online activity data
Online Identifiers	Contact data Profile data Device data Online activity data
Geolocation data	Precise geolocation data
Inferences	May be derived from your: Blowouts services, massage sessions, eyelash extension services, waxing services, personal training services, products, gift cards, and other services you purchase in franchise locations or using the WB Sites Appointment information Payment and transactional data Marketing data Device data Online activity data
Physical Description	Profile data Blowouts services, massage sessions, eyelash extension services, waxing services, and personal training services
Sensory Information	Your content Security data, such as security camera footage recorded at our salons or offices
Protected Classification Characteristics	Other than your COVID-19 screening information, we do not intentionally collect this information, but it may be revealed in other information we collect, such as profile data, haircare preferences and your content.

 

The sources from which we collect this Personal Information are described in the section above titled “Personal Information We May Collect and How We May Collect It” and the categories of third parties with whom we share Personal Information are described in the section above titled “How We May Share Your Personal Information.” The business and commercial purposes for our collection, use, and disclosure of Personal Information are described in the section above titled “How We May Use Your Personal Information.”

We disclose each of the categories of Personal Information for a business purpose (as defined in the CCPA). In addition, the CCPA and CPRA require us to disclose which categories of Personal Information we share with third parties for “valuable consideration.”

We share the following categories of Personal Information with the advertising partners and business partners described in the section above titled “How We May Share Your Personal Information”: Identifiers, commercial information, internet or network activity, online identifiers, inferences, and physical description. You may opt out of this sharing by following the instructions below.

Your California Privacy Rights. If you are a California resident, you can request to exercise your privacy rights as detailed within CCPA and CPRA and listed below.

• Opt-Out of Sales. If we “sell” your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your Personal Information covered by that law with third parties for their direct marketing purposes.
• Deletion. You can ask WB to delete the Personal Information that we have collected about you.
• Access. You can ask WB for a copy of the Personal Information that we have collected about you.
• Correction. You have the right to request corrections of any inaccuracies in your Personal Information.
• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

• • The categories of Personal Information that we have collected.

• • The categories of sources from which we collected Personal Information.

• • The business or commercial purpose for collecting and/or selling Personal Information.

• • The categories of third parties with whom we share Personal Information.

• • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.

• • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.

• You are entitled to exercise your CCPA and CPRA privacy rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our services.

How To Exercise Your Rights. You may request to exercise your California privacy rights described above as follows:

• Right to information, access, correction, and deletion.

• • You can click https://www.drybarshops.com/privacy-policy/

• • Call us at (866) 969-5666

• • If either of these don’t work, send us an email to [email protected].

• The CCPA and CPRA allow you to limit the sale and sharing of your Personal Information. We do not sell any of your Personal Information for monetary consideration. We share your Personal Information for limited purposes as specified in this Privacy Policy. You have the right to opt-out of the “sale” of your Personal Information. You can request to opt-out of the “sale” of your Personal Information by emailing us at [email protected] or by clicking here: Do Not Sell or Share My Personal Information

Limit The Use or Disclosure of Sensitive Personal Information .

• The CCPA and CPRA also allow you to limit the use or disclosure of Sensitive Personal Information (“SPI”) as defined above. We collect SPI to protect our clients and our personnel and to provide you with your requested Services. We do not collect SPI for general marketing or any other purpose and this information is not shared with any third party.

WB is happy to process your privacy rights requests. We will process all non-verifiable requests consistent with the requirements of the CCPA and our internal processes.

Verifiable requests will only be processed after we have confirmed your identity and validated that you reside in California. As part of this process, if we require verification to process your request, we will first attempt to do so by comparing the information within your request to the information we have on record. If we are unable to verify your identity after this comparison, we will contact you to request additional verification, as permitted by law. If you are unable to verify your identity after we contact you for additional verification, we reserve the right to deny your rights request, consistent with applicable law.

Consistent with the CCPA, you may also designate an authorized agent to make a request on your behalf. If you designate an authorized agent to make a verifiable rights request on your behalf, in addition to the verification methods described above, we will require the agent provide us with a written instrument demonstrating you have authorized them to act on your behalf.

For all verifiable requests, we will only require verification in compliance with the CCPA and in proportion to any potential risk to you from complying with the request.

For all requests, we cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

If you are somehow affiliated with WB, in that perhaps you are an employee, vendor, contractor, or hold any other position for or within the company, and you reside in California, you may exercise your CCPA rights using the methods detailed in this section. Note that privacy rights requests are not the mechanism through which you may request human resource-related information or other (examples may be; payroll, PTO, benefits, contract information); therefore, we cannot provide you such information, but we will process your privacy rights request in the same manner that we would for any other California Resident. Requesting to exercise your CCPA and CPRA privacy rights will not change the affiliation you have with WB in any way.

Your California privacy rights are not absolute, and in certain cases we may decline your request as permitted by law. For example, WB may reject privacy rights requests if there is any suspected malice, including any which may be deceptive, fraudulent, illegal, or pose a security threat. WB may also reject requests related to legal or criminal matters, or if they are related to any in-progress transactions or purchases.

SECTION 11 –OTHER STATE PRIVACY RIGHTS AND YOUR RIGHTS

Other U.S. state consumer privacy laws may provide their residents with rights regarding our use of their Personal Information.

Iowa provides its residents with rights to:

1. Confirm whether we process their Personal Information
2. Access and delete certain Personal Information
3. Data Portability
4. Opt-out of the processing of Personal Information for sales.

Utah provides its residents with the rights to:

1. Confirm whether we process their Personal Information
2. Access and delete certain Personal Information
3. Data Portability
4. Opt-out of the processing of Personal Information for sales.
5. Opt-out of the processing of Personal information for targeted advertising

Colorado, Connecticut, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas and Virginia each provide their state residents with rights to:

1. Confirm whether we process their Personal Information
2. Access and delete certain Personal Information
3. Data portability
4. Opt-out of the processing of their Personal Information for targeted advertising
5. Opt-out of the processing of their Personal Information for sales
6. Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects

Authorized Agents

Additionally, some states may permit you to designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We may deny a request from an authorized agent if the authorized agent does not submit written proof that they have been authorized by you to act on your behalf. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law, we may still require that you verify your own identity directly to us.

If you are an authorized agent submitting a request on behalf of an individual, you must include a copy of the written, signed permission indicating that you are permitted to act on that person’s behalf.

To exercise any of these rights please either:

Call us at: (866) 969-5666 or

Submit a request to: [email protected].

SECTION 12 – APPEALING A DENIED REQUEST TO EXERCISE STATE PRIVACY RIGHTS

In some circumstances, we may deny your request to exercise one or more of the rights described above. If you disagree with our decision to deny your request or any portion of our request, you have the right to appeal our decision within 60 days of receipt of notice that your request has been denied. If you submit an appeal to a denied request more than 60 days after you have been notified of our decision to deny the request, we may deny your appeal. If you submit an appeal, we will respond within forty-five (45) days of our receipt of your appeal.

• If you wish to appeal a decision, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our decision or by submitting your appeal using the information provided below. We will review your appeal and either amend or uphold our decision. In either case, we will provide a written explanation of the reason for the decision. This decision will be final.

To submit an appeal please either:

Call us at: (866) 969-5666 or

Submit a request to: [email protected].

SECTION 13 – DATA RETENTION

We will retain your Personal Information only for as long as is necessary for the purposes set forth in this Privacy Policy or as disclosed at the time of collection.

Identifiers which may include a real name, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers will be retained for as long as Services are performed and thereafter for record keeping purposes or as otherwise required by law or legal process.

Commercial information which may include records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies will be retained for as long as Services are performed and thereafter for record keeping purposes or as otherwise required by law or legal process.

Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement will be retained only for as long as Services are performed and for record keeping purposes or as otherwise required by law or legal process.

Section 14 – CONTACT US

If you have any questions related to this Privacy Policy or our privacy practices in general, please do not hesitate to contact us using the information below:

Call us at: (866) 969-5666 or

Email us at: [email protected].

 

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