Privacy Policy

Last modified: [November 19, 2021]

      1. Introduction


        This Privacy Policy describes how Culitrade collects and uses Personal Data about you through the use of our Platform, and through email, text, and other electronic communications between you and Culitrade.

        Culitrade, LLC, and our affiliates (“Culitrade”, “we”, “our”, or “us”) respect your privacy and are committed to protecting it through our compliance with this policy.
        This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.culitrade.com, and any subdomain of such websites, such as the subdomains for each of our authorized third party sellers (“Culitrade Authorized Seller”) (each, a “Website” and collectively, the “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

        This policy applies to information we collect:

        • on our Platform;
        • in email, chat, text, and other electronic messages between you and our Platform;
        • when you contact us by telephone; and
        • when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

        It does not apply to information collected by:

        • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Platform.
         

        Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using these Platform, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

      2. Children Under the Age of 18


        Our Platform is not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Platform. We will remove any information about a child under the age of 18 if we become aware of it.

        Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Platform. We do not knowingly collect Personally Identifiable Information from children under 18. If you are under 18, do not use or provide any information on our Platform or, on or through, any of its features/register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of our Platform or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personally Identifiable Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at customerservice@culitrade.com.

      3. Information We Collect About You and How We Collect It


        e collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

        Generally

        We collect several types of information from and about users of our Platform:

        • by which you may be personally identified, such as name, address, e-mail address, telephone number, tax identification number, banking or financial account information, and credit or debit card number (“Personally Identifiable Information”);
        • that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Platform, error information, clickstream data, and other communication data and the resources that you access and use on the Platform; and/or
        • about your internet connection, the equipment you use to access our Platform and usage details.
         

        We collect this information:

        • directly from you when you provide it to us;
        • automatically as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, GPS location data, device identifiers, device model, device carrier information, and information collected through cookies, web beacons, and other tracking technologies; and
        • From third parties, for example, our Culitrade Authorized Sellers, affiliates and other business partners who use our Platform and who may enter your Personally Identifiable Information onto our Platform.
         

        Information You Provide to Us

        The information we collect on or through our Platform are:

        • information that you provide by filling in forms on our Platform, such as information provided at the time of registering to use our Platform, purchase a service or product or request a service for a property. We may also ask you for information when you report a problem with our Platform;
        • records and copies of your correspondence (including email addresses), if you contact us;
        • your responses to surveys that we might ask you to complete for research purposes and feedback about the services;
        • details of the transactions you carry out through our Platform and of the fulfillment of your transactions you enter into with other users of our Platform. You may be required to provide financial information before engaging in transactions on or through our Platform; and
        • your search queries on the Platform.
         

        The Personally Identifiable Information we collect from you is required to enter into a contract with Culitrade, for Culitrade to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personally Identifiable Information or withdraw your consent to our processing of Personally Identifiable Information, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

        You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). For example, if you choose to post a review, comment, photo or other content related to a product, service or Culitrade Authorized Seller through the Platform, your information, including Personally Identifiable Information, such as your name, screen name or username, and any other information you supply may be visible to other users of the Platform. Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information while creating your account, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform 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.

        Information We Collect Through Automatic Data Collection Technologies

        As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

        • Usage Information. As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your access to and use of the Platform, including: traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, browsing actions, and patterns, and other communication data and the resources that you access and use on or through the Platform.
        • Device Information. Information about your computer and Internet connection, specifically your IP address, operating system, browser type, device identifiers, device model, device carrier information, and application version information.
        • Stored Information and Files. When you use the Platform, we may access or modify the contents of your metadata and other information associated with other files stored on your device, including photographs, audio and video clips, personal contacts, and address book information, and order details and shipping information, details, and documentation.
        • Precise Geolocation Data. When using the Platform, we may collect certain information regarding your location. You must exercise your own judgment as to the adequacy and appropriateness of sharing location information with us and our third-party service providers. If you do not want us to collect this information you can chose not to enable or you can turn-off collection of location information using the privacy settings in the Platform or your device. If you block the use of location information, some parts of the Application may then be inaccessible or not function properly.
         

        The information we collect automatically may include Personally Identifiable Information or we may maintain it or associate it with Personally Identifiable Information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service by enabling us to:

        • estimate our audience size and usage patterns;
        • store information about your preferences, allowing us to customize how our Platform appears to you according to your individual interests;
        • speed up your searches; and
        • recognize you when you return to our Platform.
         

        The technologies we use for this automatic data collection may include:

        • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
        • Web Beacons. Pages of a Website, or our e-mails, may 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 e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
        • Web Analytics Services. We may use certain web analytics services, for example, Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Platform. Google Analytics uses cookies to help our Platform analyze how users use the site. You can find out more about how Google uses data when you visit our Platform by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. We and third-party vendors may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to deliver advertisements, create a profile of you, measure your interests, detect your demographics, detect your location, personalize content, or create an account for management of our customer loyalty program.
        • Third-Party Advertising Technologies. We may use third-party technology to collect and use data in connection with interest-based advertising. These ad technology companies and advertisers may use, store, or access cookies, web beacons, and other storage technologies to collect or receive information from the Services and elsewhere on the Internet and use that information to provide advertising services to us, including interest-based advertising or advertisements targeted to your interests delivered over time and across online services and devices.
         

        Information From Third Parties

        We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. This supplemental information allows us to verify information provided to us and to enhance our ability to provide you with the Services. This may include details of the transactions initiated through our Platform and of the fulfillment of your transactions you enter into with other users of our Platform.

      4. How We Use Your Information


        We use your Personal Data for various purposes described below, including to:

        • provide our Platform to you;
        • provide products and services to you;
        • provide you with information you request from us;
        • enforce our rights arising from contracts;
        • notify you about changes; and
        • provide you with notices about your account.
         

        We use information that we collect about you or that you provide to us, including any Personally Identifiable Information:

        • to present our Platform and its contents to you;
        • to provide you with information, products, or services that you request from us or our Culitrade Authorized Sellers or that may be of interest to you;
        • to facilitate transactions between you and us for products and services you purchase through the Platform;
        • to facilitate transactions between you and our Culitrade Authorized Sellers for products and services you purchase through the Platform;
        • to provide you with notices about your account, including expiration and renewal notices;
        • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
        • to notify you about changes to our Platform or any services we offer or provide though them;
        • to allow you to participate in interactive features on our Platform;
        • to fulfill any other purpose for which you provide it;
        • to maintain, secure, or improve our Platform and services;
        • to administer surveys, sweepstakes, promotions and contests;
        • to provide you with newsletters or other promotional content related to our services;
        • to respond to your questions or inquiries;
        • in any other way we may describe when you provide the information; and
        • for any other purpose with your consent.
         

        We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications. For more information, see Choices About How We Use and Disclose Your Information.

      5. Disclosure of Your Information


        We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

        • with your consent to authorized third parties;
        • other users of our Platform, upon your request;
        • our subsidiaries and our affiliates;
        • our third-party service providers that we use to support our business;
        • to a company we merge, acquire, or that buys s, or in the event of change in strcture of our company of any form;
        • to comply with our legal obligations; and
        • to enforce our rights.
         

        We do not share, sell, or otherwise disclose your Personally Identifiable Information for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, publicly available information, and information that does not identify any individual, without restriction to the fullest extent permitted by law.

        We may disclose Personally Identifiable Information that we collect or you provide as described in this Privacy Policy:

        • to our subsidiaries and affiliates who help us provide the Platform;
        • to contractors, service providers, and other third parties we use to support our business. These entities may provide IT and infrastructure support services, customer service, advertising, marketing, sales tax and payment processing services;
        • to affiliates to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information;
        • 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 of Culitrade’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personally Identifiable Information held by Culitrade about our Platform’ users is among the assets transferred; and
        • for any other purpose disclosed by us when you provide the information.
         

        We may also disclose your Personally Identifiable Information:

        • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
        • to enforce or apply our Platform’ terms and conditions [https://www.culitrade.com/Terms-of-Use] and to enforce other agreements, including for billing and collection purposes; and
        • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Culitrade, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
         
      6. Choices About How We Use and Disclose Your Information


        We offer you choices on how you can opt out of our use of tracking technology and our advertising to you. However, we do not control the collection and use of your information collected by third parties.

        We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

        In addition, we strive to provide you with choices regarding the Personally Identifiable Information you provide to us. We have created mechanisms to provide you with control over your Personally Identifiable Information:

        • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. If you disable or refuse cookies, please note that some parts of the Platform may then be inaccessible or not function properly.
        • Promotional Offers from Culitrade. You may receive email from us for a variety of reasons; for example, if you took an action through the Platform or you purchased a product or service. If you wish to opt-out of such use, you can contact us at customerservice@culitrade.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link at the bottom of the email. This opt out does not apply to information provided to Culitrade for the processing of a service or other transaction.
        • Promotional Offers from Affiliates. Unless you opt out, we may share your Personally Identifiable Information with affiliates for promotional purposes. If you wish to opt out of this sharing, you may do so by sending us an email stating your request to customerservice@culitrade.com.
        • Text Messages. If you provide your phone number through the Platform, we or our third-party service provider may call or send you a transactional SMS message about the status of or issues with a recent transaction (e.g., an order you have placed with us). In addition to transactional SMS messages, we may send you marketing communications by SMS. However, we only send marketing SMS messages to those who have expressly opted‐in to receiving marketing communications by SMS message. If you no longer wish to receive SMS messages from us, you can opt out of future SMS messages by replying to one of our SMS messages with the word “Stop.” Additionally, you may request to stop receiving marketing communications by contacting us at customerservice@culitrade.com.
         

        You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

      7. Do Not Track Signals


        We may use automated data collection technologies to track you across Platform. We currently do not honor do-not-track signals that may be sent by some browsers.

        We also may use automated data collection technologies to collect information about your online activities over time and across third-party Platform or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to Platform and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us. To learn more about “Do Not Track” signals, visit www.allaboutdnt.com.

      8. Data Security



        Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Platform confidential.

        We have implemented measures designed to secure your Personally Identifiable Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

        The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this 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 the Platform and when transmitting messages to other users. The information you share in public areas may be viewed by any user of the Platform.

        Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personally Identifiable Information, we cannot guarantee the security of your Personally Identifiable Information transmitted to our Platform. Any transmission of Personally Identifiable Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

      9. Data Retention Periods


        We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example, we may keep it:

        • on our backup and disaster recovery systems;
        • for as long as necessary to protect our legal interests; and
        • to comply with other legal requirements.
         

        Culitrade will retain your Personally Identifiable Information for the entire time that you keep your account open. After you close your account, we may retain your Personally Identifiable Information:

        • for as long as necessary to comply with any legal requirement;
        • on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
        • for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
        • for data that is publicly available, has been aggregated, or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
         
      10. State-Specific Privacy Rights


        The law in certain states may provide their residents with additional rights regarding our use of your personal information.

        The law in some states may provide you with additional rights regarding our use of Personally Identifiable Information. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum, if any, for your state that is attached to this Privacy Policy.

        California residents may click here [Culitrade Privacy Addendum for California Residents] to view our Privacy Addendum for California Residents.

        Nevada residents may click here [Culitrade Privacy Addendum for Nevada Residents] to exercise their Privacy Rights.

      11. Changes to Our Privacy Policy


        We will post any changes to our Privacy Policy on our Platform. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review the changes.

        We may from time to time modify this Privacy Policy. We will promptly make any changes available at [https://www.culitrade.com/Privacy-Policy]. Changes will be effective as soon as the revised Privacy Policy is posted unless otherwise stated. In certain circumstances, we will provide a more prominent notice before the changes goes into effect (including, for certain of our services, email notifications of material changes to this Privacy Policy). The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Platform and this Privacy Policy to check for any changes (and, where applicable, for ensuring we have an up-to-date email address for you).

      12. Contact Information


        You may contact us through the contact information below.

        If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personally Identifiable Information pursuant to applicable laws, or otherwise need to contact us, you must contact us at the contact information below.

        To Contact Culitrade:

        Culitrade, LLC
        20 N. Martingale Rd., Suite 410
        Schaumburg, IL 60173

        customerservice@culitrade.com

 

Culitrade Privacy Addendum for California Residents


Effective Date: [November 19, 2021]
Last Reviewed on: [November 19, 2021]

This Privacy Addendum for California Residents (“Privacy Addendum”) supplements the information contained in the Culitrade Privacy Policy that this Privacy Addendum is attached to and applies solely to users who reside in the State of California (“consumers” or “you”). We adopt this Privacy Addendum 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 Privacy Addendum. Personal Information that is regulated under the CCPA may represent a limited portion of personal data as described in the Culitrade Privacy Policy; therefore, this Privacy Addendum applies solely to the Personal Information as defined below. We may update this Privacy Addendum as necessary and in the event of changes in the CCPA. Note that this Privacy Addendum does not apply to our personnel. Please contact your supervisor if you are personnel and would like additional information about how we process your personal information.

  1. INFORMATION WE COLLECT


    Our Platform collects 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 device (“Personal Information”). In particular, Culitrade collects and has collected Personal Information through its Platform from its consumers, as provided below.

    Categories of Personal Information Culitrade has collected in the preceding 12 months:

    • Identifiers (e.g., name, mailing address, email address, unique personal identifier, online identifier, Internet Protocol address (IP address), or other similar identifiers)
    • California Customer Records statute personal information statute (e.g., name, address, telephone number, credit card number, debit card number, or any other financial information. Note, some of this information may overlap with other categories)
    • Commercial information (e.g., records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
    • Internet or other similar network activity (e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement)
    • Geolocation data (e.g., physical location of your device, including real-time GPS location)
    • Inferences drawn from other Personal Information (e.g., profile reflecting a person’s preferences)
     

    Personal Information does not include information that is: (a) publicly available information from government records; (b) deidentified or aggregated consumer information; or (c) certain information excluded from the scope of CCPA, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

    Categories of sources from which Culitrade has collected Personal Information:

    • Directly from you. For example, from forms you complete when purchasing a product
    • Indirectly from you. For example, from our operating systems and platforms
    • Affiliates, parents and subsidiary organizations of Culitrade
    • Service providers
    • Business partners who we partner with to offer our products
    • Advertising networks
     
  2. USE OF PERSONAL INFORMATION


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

    • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
    • To fulfill or meet the reason you provided the information. For example: if you share your name and contact information to ask a question about our products, we will use that Personal Information to respond to your inquiry. We may also save your information to help you check out faster and to provide recommendations for future purchases.
    • To provide, support, develop and improve our Platform and products.
    • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses.
    • To help maintain the safety, security, and integrity of our Platform and products, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • Undertaking internal research for technological development and demonstration.
    • 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 Culitrade assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Culitrade about our customers are among the assets transferred.
     

    Culitrade 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.

  3. SHARING PERSONAL INFORMATION


    We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another organization for monetary or other valuable consideration. However, Culitrade may disclose your Personal Information to a third party for one or more business purposes. 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.

    Disclosures of Personal Information for a business purpose:

    In the preceding twelve (12) months, Culitrade has disclosed the following categories of Personal Information for a business purpose:

    • Identifiers
    • California Customer Records statute personal information categories
    • Commercial information
    • Internet or other similar network activity
    • Geolocation data
    • Inferences drawn from other Personal Information

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

    • Service providers
    • Business partners
    • Affiliates
    • Advertising networks

    Sales of Personal Information:

    In the preceding twelve (12) months, Culitrade had not sold Personal Information.

     

  4. YOUR RIGHTS AND CHOICES


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

    Access request rights

    You have the right to request that Culitrade disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), 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.
    • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
      • sales, identifying the Persnal Information categories that each category of recipient purchased; and
      • disclsures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

    Deletion request rights

    You have the right to request that Culitrade delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), we will delete (and direct our service providers to delete) your 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:

    • 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.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    Exercising Access and Deletion Rights

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

    Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf (an “Authorized Representative”), may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

    You 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 you are the person about whom we collected Personal Information or an Authorized Representative. Before completing your request to exercise the below, we will verify that the request came from you by asking you one or more knowledge-based questions about you.
    • 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 Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. With few exceptions, we will only review and fulfill a request from your Authorized Representative if (a) you grant the Authorized Representative written permission to make a request on your behalf, (b) you or the Authorized Representative provides us notice of that written permission, and (c) we are able to verify your identity in connection with that notice and the request.

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

    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.

    Response Timing and Format

    We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 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 the contact information you provided in 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 the verifiable consumer request’s receipt. 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.

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

    Personal Information Sales Opt-Out and Opt-In Rights

    We do not sell the Personal Information of consumers and therefore do not provide any opt-in or opt-out capabilities on our Platform or otherwise.

     

  5. 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.
     
  6. ADDITIONAL CALIFORNIA RIGHTS


    California law permits minors under the age of 18 to request the removal of your User Contributions, subject to certain exceptions. If you are under the age of 18 in California, you may contact us at webmaster@culitrade.com, or by telephone at +1 (224) 848-4060 (if you contact us via email, please use the subject “California Eraser Law Request”). We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor’s information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Platform or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the Internet in the future. We do not advertise or market any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age.

    California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Platform that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please send an email to webmaster@culitrade.com.

  7. CHANGES TO OUR CALIFORNIA ADDENDUM


    We reserve the right to amend this Privacy Addendum as described in our Privacy Policy. When we make changes to this Privacy Addendum, we will inform you of such updates as described in our Privacy Policy.

Culitrade Privacy Addendum for Nevada Residents


Effective Date: [November 19, 2021]
Last Reviewed on: [November 19, 2021]

Culitrade respects your privacy and is committed to protecting it through our compliance with this policy.

Culitrade does not sell your personal information to any outside companies; therefore, Culitrade does not provide any opt-out capabilities on our Platform or otherwise.

You are entitled, nevertheless, under Nevada law to formally request that we not sell any of your personal information. Please email us at webmaster@culitrade.com to submit your request and we will confirm your request.