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Privacy Policy

Privacy Policy

Effective July, 2023

PUMA, and the PUMA group of companies (collectively, “PUMA” or "we", "us", or "our") respects the privacy of all of our visitors and pledges to provide you with the best online experience possible. This PUMA Privacy Policy (“Privacy Policy”) describes what Personal Information (defined below) we collect from you via our Services (defined below), how we may use it and the steps we take to ensure that it is protected. This Privacy Policy applies to Personal Information we may collect from you through any PUMA online services that posts this Privacy Policy, including our mobile app(s) for users located in the U.S. and Canada, as well as offline collection through our retail stores located in the U.S. and Canada, PUMA sponsored events, PUMA emails originated from the U.S. and Canada, and official PUMA operated surveys and sweepstakes entry forms, or in any other instance when you contact our operations in the U.S. and Canada (collectively “Services”). This Privacy Policy does not apply to our job applicants or current or former employees or contractors except to the extent that they use our website and with regard to our biometric retention statement and with regard to how to make a privacy rights request.

BY ACCESSING OR USING THE SERVICES, ON ANY COMPUTER, MOBILE PHONE, TABLET, CONSOLE OR OTHER PHYSICAL OR ELECTRONIC DEVICE (COLLECTIVELY, "DEVICE"), OR BY OTHER METHOD, YOU CONSENT TO OUR PRIVACY POLICY.

PUMA may modify this Privacy Policy at any time effective upon its posting, and additional privacy notices or policies may also apply. Your continued use of our products and services constitutes your acceptance to this Privacy Policy, applicable additional notices and policies and any updates. By using our Services, you agree to the Service’s Terms & Conditions governing the use of the Services and accept our practices as outlined in this Privacy Policy. Do not use the Service if you do not ACCEPT this Privacy Policy and AGREE TO the Terms and Conditions.

  • INFORMATION WE COLLECT AND HOW
  • COOKIES AND DATA TECHNOLOGIES
  • USE OF INFORMATION
  • PROTECTION AND RETENTION OF INFORMATION
  • DISCLOSING AND TRANSFERING OF INFORMATION
  • CHILDREN’S PRIVACY
  • THIRD PARTY SERVICES
  • OPT-OUT, DELETE OR MODIFY INFORMATION
  • CONTACT US
  • CALIFORNIA PRIVACY NOTICE
  • VIRGINIA, COLORADO, CONNECTICUT AND UTAH PRIVACY NOTICE
  • NEVADA PRIVACY NOTICE

INFORMATION WE COLLECT AND HOW

We collect information you give us or permit us to access. We may also collect information regarding your interaction with, and use of, our products and services. Information we may collect includes, but is not limited to, your name, image, birth date, email and physical address, when necessary credit card information, IP address, telephone number or mobile phone identifier, gender, contact lists, social media information, location (including GPS) information, activity and performance information, Device identifier and hardware information, browser type and language, cookie information, system type, whether you have enabled software to access certain features, access times, referring website URLs, information about your purchases and other information about your interactions with us.

For example, we collect information you provide via any of our customer service channels including via phone, email, SMS and chat, and such information may be recorded, processed and disclosed for the purposes described in this Privacy Policy. We also collect information about gift and eGift Card recipients provided by the giver.

As more fully explained in the next section, we may automatically collect certain information about you when you access or use the Services, or shop in our stores, including:

  • Log and Usage Information: We collect information about your use of the Services, such as the type of browser you use, access times, pages viewed, items placed in your cart, links clicked, browsing behavior, and the referring URL (the webpage you visited before navigating to the Services). We also collect information regarding customer traffic patterns and site usage. This information is used to analyze and improve our Services, to provide our customers with a fulfilling shopping experience, and to personalize the Services, our communications with you, and your shopping experience.
  • Device Information: We collect information about the device you use to access the Services, including the hardware model, IP address, unique device identifiers and operating system and version.
  • Transaction Information: When you purchase or return a product, we collect information about the transaction, such as product details and the date and location of the purchase/return.
  • Video Data: We use video cameras in our stores for security purposes, loss prevention, and asset protection. We may also use cameras in our stores for operational purposes, such as traffic pattern analysis. We will not use cameras to personally identify you, without your consent, except when the identification is for safety, security, anti-theft, or law enforcement purposes.
  • RFID Data: We may use Radio Frequency Identification (RFID) for inventory management and logistics support. RFID tags consist of a small chip and antenna that provide a unique identifier for objects. RFID serves the same purpose as a bar code and must be scanned by a specific type of reader in close proximity to the tag to retrieve tag data. RFID is not used to track or monitor any items once you leave our stores.
  • WiFi Data: Some of our retail stores may offer free Wi-Fi services to visitors. Wi-Fi routers capture certain data, such as Device information and telemetry data related to signal strength and quality related to your use of our Wi-Fi service, and we may analyze Wi-Fi data automatically collected to provide operational insights such as foot traffic volumes, dwell times, and how customers move through our stores.
  • Information Collected by Cookies and Other Technologies: As more fully explained in the next section, we (and our service providers and third parties) may use cookies, web beacons (also known as "tracking pixels") and other collection or tracking technologies (“Data Technologies”) to record and collect information about you when you interact with the Services, including information about your interaction with the Services such as mouse movements, click and keystroke behavior, indicated preferences, mobile app or site visit behavior, browsing and purchasing behavior. We may combine this information with other information we collect about you and use it for various purposes, such as improving our websites and your online experience, understanding which areas and features of our sites are popular, counting visits, understanding campaign effectiveness, tailoring our communications with you, determining whether an email has been opened and links within the email have been clicked and for other business purposes. For more information about cookies and how to disable them, please see the Cookies section below.

If you participate in a contest or sweepstakes that we sponsor, we may, in addition to the above, collect the information to administer the sweepstakes, or as otherwise disclosed at the time of collection, such as your contact information, your product size information, your preferences, your location, and other information you provide to us.

Additionally, we may collect your mobile telephone number in connection with SMS/MMS programs, including for shipment notifications and marketing purposes. We will use mobile telephone information you provide through the Services to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, disclosing information to platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages. For more information regarding SMS/MMS programs, visit: https://www.sinch.com/privacy-policy.

We may also collect Personal Information in connection with the processing and evaluation of a job application and related materials submitted by you. For more information, click here.

We may derive Personal Information or draw inferences about you based on the other types of Personal Information we collect. For example, we may infer location based on IP address, or make product recommendations based on browsing or purchasing behavior in connection with the Services.

We may combine information you give us with other information from PUMA sources, transactions and communications. This may include, but is not limited to, information from PUMA retail stores, direct mail, catalogs, promotions, collaborations, events, products and applications, or other PUMA interactions. We may also combine that information with data that is publicly available and data from third parties. To the extent non-Service information is combined with Personal Information collected via the Services, we will treat it as Personal Information under this Privacy Policy.

COOKIES AND DATA TECHNOLOGIES

We, our service providers and third parties may use cookies and other Data Technologies, including but not limited to tracking pixels, to gather information about your visits on our website, mobile apps and other Services so we can enhance your experience. This information may be combined with other information, which will enable us to analyze and better customize your visits.

What Are Cookies? Cookies are data files stored within your browser when you interact with a website. These data files allow the website to recall important information about your visit, help better understand your preferences and improve your overall experience. For example, we use cookies to save products in your shopping cart while you browse our websites and to track the effectiveness of our marketing and advertising campaigns. Similarly, a tracking pixel or web beacon is a technology that can recognize specific cookies and convey information about that browser. We, and third parties, may also use technologies, such as our own, and third party, cookies, to provide you with personalized online display advertising tailored to your interests.

There are generally three categories of cookies used on the Services:

  • Functional: These cookies are required for basic functionality and are therefore always enabled. If you disable them our Services may not function properly. These include cookies that allow you to be remembered as you explore and use our Services within a single session or, if you request, from session to session. They help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.
  • Performance and Analytics: These cookies allow us to improve the Services' functionality by tracking usage, including through session replay. In some cases, these cookies improve the speed with which we can process your request and allow us to remember Services preferences you have selected. These cookies also help us learn things like what pages are most attractive to all of our visitors and what promotions visitors like to see, and to gauge the success of our advertising campaigns. Refusing these cookies will limit recommendations and customizations while using the Services.
  • Social media and Advertising: Social media cookies offer the possibility to connect you to your social networks and share content from the Services through social media. Advertising cookies collect information to help better tailor advertising to your interests. In some cases, these cookies involve the processing of your Personal Information. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.

Your browser can also help you manage cookies. Most, but not all, browsers accept cookies automatically. You may be able to set your browser to reject and/or delete cookies. You may limit or turn off cookies and other collection tools by adjusting your browser settings. If you turn off certain collection tools, you may not have access to many features that make your experience more efficient and some of our services and features may not function properly. We recommend that you leave cookies “turned on” so we can offer you a better shopping experience on our sites.

Some information about your use of the Services and certain other online services may be collected using Data Technologies across time and services and used by PUMA and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, PUMA currently does not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com , but we are not responsible for the completeness or accuracy of this third party information. Some third parties may, however, offer you choices regarding their tracking technologies. PUMA is not responsible for the completeness or accuracy of this tool or third-party notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see below. We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Data Technologies associated with the Services, but such tools rely on third parties and third party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective.

Some advertising and technology partners may also collect Personal Information when you use the Services. For example, we may work with other companies, such as Google, who use tracking technologies to analyze how users use the Services and to serve advertisements on our behalf across the Internet. For more information about how data is collected and processed in connection with the Google Analytics service and how to opt out, visit https://tools.google.com/dlpage/gaoptout. To learn more about data Google collects and how your data may be used, and to optout of certain Google browser Interest-Based Advertising, please visit http://www.google.com/settings/ads .

Some third party Data Technology operators that may be associated with our Services may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit: http://www.aboutads.info/choices/ (http://www.aboutads.info/choices/) (U.S.), http://youradchoices.ca/choices (Canada), and http://www.aboutads.info/appchoices  for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/ . Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g. from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g. mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. PUMA supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks we directly engage to serve you interest-based advertising will do so as well, though we cannot guaranty their compliance.

USE OF INFORMATION

We may use your information subject to this Privacy Policy, including information that is defined as personal information, personally identifiable information or personal data under applicable laws (“Personal Information”) except as restricted by applicable law, including without limitation for:

  • Enhancing, personalizing and customizing user experiences, such as placing an order and other activities.
  • Communicating with you about your purchase, account information or customer service.
  • Analyzing user behavior and trends to better understand our customers and gain consumer insights.
  • Providing and conducting marketing and promotions.
  • Communicating with you about our products, services and events, and for other promotional purposes.
  • Administering contests, promotions, events, surveys or other features.
  • Displaying relevant marketing to you and other information about PUMA.
  • Processing your registration, manage your account and/or upload your user generated content (“UGC”).
  • Transacting with you.
  • Improving the Service and for any other internal business purposes.
  • Preventing and addressing fraud, breach of policies or terms, and threats or harm.
  • Fulfilling other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so.

We only send you text communications or promotional emails if you have opted to receive PUMA emails and/or SMS messages. If you no longer want to receive SMS messages, or promotional emails, or want to delete/update your Personal Information, please visit the My Account page or opt-out by following the opt-out or unsubscribe instructions in the message or by Contacting Us.

You can cancel text messages at any time. To stop receiving marketing text messages from PUMA, please reply “STOP” to the PUMA marketing text message. After you send "STOP", we may send you an additional text message to confirm that you have been unsubscribed. You will no longer receive text messages from that short code, but you may receive text messages if you are subscribed to other text lists. If at any time you have questions about the text messages, text "HELP". After you send "HELP" we will respond with instructions on how to use our service as well as how to unsubscribe. Please note this preference will only apply to the phone number in receipt of the text. Message and data rates may apply.

PROTECTION AND RETENTION OF INFORMATION

PUMA uses technical and organizational measures designed to protect your Personal Information against unauthorized access, theft, and loss. While PUMA strives to protect its user's Personal Information and privacy, we cannot guarantee 100% the security or confidentiality of any information that you provide to us or that is otherwise disclosed by you online. We recommend that you take additional measures to protect yourself and your information, such as installing anti-virus software, closing browsers after use, keeping confidential your log-in credentials and passwords. We will retain your Personal Information for as long as your account is active or as needed to provide you services. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We retain your Personal Information for as long as necessary to provide our products and services to you and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting, and preventing fraud and abuse, and enforcing our agreements. The criteria used to determine retention periods includes the legal limitation of liability period, agreed contractual provisions, applicable regulatory requirements, and industry standards.

While we do not collect biometric data from the public, in instances where we collect employee biometric data, we only retain such biometric data for as long as necessary for the purpose of the collection of the biometric data and delete such biometric data when the purpose for collecting such data has been satisfied or within one year of the employee’s last interaction with the Company, whichever is earlier to occur.

DISCLOSING AND TRANSFERING OF INFORMATION

Subject to applicable law, this Privacy Policy and any representations made by us in writing at the time of collection, we may disclose your information except as restricted by applicable law. For instance, we may disclose your information, including Personal Information, with our affiliates and subsidiaries, as well as to our partners, vendors, distributors, and suppliers, some of which may be outside the United States. We may transfer your information to certain service providers in order to conduct our business operations. For example, we may disclose your information to service providers who may provide the following services on our behalf: web hosting, credit card processing, shipping and order fulfillment, data management, email distribution, marketing, market research, analytics, customer service, website utilization, information analysis, and promotions management. We may also share some of your account details (such as your name, email address, password and date of birth) with our cloud service providers for the purposes of identification and authentication, so you can conveniently access your account. We may also disclose your information as is necessary to complete a transaction or provide a product, service, or feature that you have requested. These service providers will only use your information for the purpose of carrying out the services provided to PUMA. We may disclose information upon governmental request, in response to a court order, when required by law, to enforce our policies, or to protect our or others' rights, property or safety. We may disclose information to prevent illegal uses of PUMA's products and services or violations of the Terms & Conditions, or applicable additional terms, or to defend ourselves against third party claims. We may also disclose information to companies assisting in fraud protection or investigation. We may also disclose aggregated or de-identified information based upon your use of the Services.

Your information may be transferred to a third party as a part of our business assets in a sale of a part or all of PUMA, or in connection with a merger, financing or other corporate transaction.

You may also choose to disclose certain information publicly (e.g., when you post UGC) or with specific third parties (e.g., when you interact with third party Data Technologies or other services (e.g., social media plug-ins, links to other sites, etc.). When you use certain services, you agree to publicly share a basic amount of information, which may include your username, city location, and profile picture in accordance with the terms of those services. In order to participate in certain features, you may have to adjust your privacy settings and share additional information. You may also choose to disclose your activity on other platforms, such as Instagram, Facebook and Twitter. Please read the privacy policies of those platforms, because your PUMA activity published on those platforms will no longer be governed by this Privacy Policy.

Our digital operations are conducted, in whole or in part, in the United States and our services are intended for U.S. users. Regardless of where you live, you consent to have your information, including Personal Information, transferred, processed and stored in the United States, and other jurisdictions, and allow PUMA to collect and process your Personal Information in accordance with this Privacy Policy.

CHILDRENS' PRIVACY

We do not knowingly collect or solicit “Personal Information” as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) online from children under the age of 13. The Services are intended for a general audience. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA we will remove such data to the extent required by COPPA. If you believe that we might have any information from a child under the age of 13, please contact us as directed below in the “Contact Us” section.

THIRD PARTY SERVICES

The Services may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)) or other third-party services. These third-party services may use their own cookies, web beacons, and other Data Technologies to independently collect information about you and may solicit Personal Information from you.

Certain functionalities on the Service permit interactions that you initiate between the Service and certain third-party services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a third-party service; “liking” or “sharing” PUMA content; logging in to the Service using your third-party service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a third-party service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other third-party services, information you post or provide access to may be publicly displayed on the Service or by the third-party service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with PUMA in a tweet or status update), your post may be used on or in connection with the Service or otherwise by PUMA. Also, both we and the third party may have access to certain information about you and your use of the Service and any third-party service.

We may engage and work with service providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or cross-device data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”).

PUMA is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics service providers and third-party services associated with the Services. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

OPT-OUT, DELETE OR MODIFY INFORMATION

You may cancel your Account or opt-out of receiving promotional e-mail messages from PUMA at any time. To unsubscribe and stop receiving SMS text or commercial e-mail communications from PUMA, you can change your Account settings or follow the instructions enclosed within the e-mail, text message, notification or other promotional message or communication. You can access, update, or correct certain information stored within your Account at any time by logging into your account and updating your preferences. However, this will only affect your account profile and not other Personal Information that we have about you. You may also request access, correction, or deletion of your personal information by contacting us as described in the Contact Us section, however how we process this request will be within our discretion subject to the rights that certain state residents have. We may require you to prove your identity if you make such a request. PUMA may keep information and content in our backup files and archives as required or permitted by applicable law.

In addition, as discussed below, depending on where you reside, you may have broader rights such as to (i) object to or request the restriction of processing of your Personal Information, (ii) request to know more about and access the Personal Information we collect, use, and disclose about you, (iii) request deletion of your Personal Information, (iv) request correction of inaccurate Personal Information, or (v) opt out of the sale or sharing of Personal Information for the purpose of targeted advertising. For more information on these rights and how to exercise them, see our California Privacy Notice and State Notice below. These state specific rights must be exercised separately from the general rights described in the paragraph above.

CONTACT US

If you have any questions or comments relating to our Services and/or the Privacy Policy, please email us at customerservice.us@puma.com or write to us:

PUMA
Attn: Privacy Officer
455 Grand Union Boulevard
Somerville MA, USA 02145

You may also contact us via telephone at 1-888-565-PUMA (7862) (tel:1-888-565-7862).

TERMS OF USE

Your use of our products and services, and any disputes arising from them, is subject to this Privacy Policy as well as the Terms & Conditions governing the use of the Services, and any applicable additional terms.

Please visit the User Content Terms to view License Terms for use of Instagram Content on our Services and in advertising.

CALIFORNIA PRIVACY NOTICE

Effective Date July 1, 2023

California law provides consumers (that are California residents) with specific rights regarding their Personal Information. This California Privacy Rights Notice (“California Notice”) supplements the PUMA Privacy Policy. It applies solely to California consumers and addresses Personal Information we collect online and offline. This California Notice does not apply to PUMA employees or personnel, except with respect to how to exercise rights. This California Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations.

Notice of Collection and Use of Personal Information. We may collect (and may have collected during the 12-month period prior to the last updated date of this California Notice) the following categories of Personal Information about you:

Categories of Personal Information PUMA Has Collected in the Preceding 12 Months

Categories of Personal Information We Collected About California Consumers:

  • Identifiers such as name, physical address, unique personal identifier (such as pixels, cookies, web beacons), IP address, email address, phone number, customer number, account name, ID card information, phone call records, payment information or other similar identifiers;
  • Personal records such as signature, credit or debit card information, financial information;
  • Characteristics such as birthday, gender, sex, veteran or military status;
  • Customer Accounts/Commercial information such as products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
  • Online usage information such as Internet and other electronic network activity information including, but not limited to, browsing history, search history, information on a consumer’s interaction with our website, application, or advertisement, user-generated/submitted content;
  • Geolocation data such as physical location;
  • Audio/visual and similar information such as audio recordings of customer service calls, visual recordings of consumers in stores;
  • Inferences Derived From Personal Information such as your purchase preferences, interests, characteristics, predispositions, behavior, attitudes, to create a profile reflecting your preferences and recommendations for products you may be interested in.

There may be additional information that we collected that meets the definition of Personal Information under California law but is not reflected by a category, in which case we will treat it as Personal Information as required by California law, but will not include it when we are required to describe our practices by category of Personal Information.

As permitted by applicable law, we do not treat de-identified data or aggregate information as Personal Information and we reserve the right to convert or permit others to convert your Personal Information into de-identified or aggregate information. We have no obligation to re-identify such information or keep it longer than we need it for our own purposes.

Because there are numerous types of Personal Information in each category of Personal Information, and various uses for each Personal Information type, our retention periods vary for each of the categories of Personal Information described above. The length of time for which we retain each category of Personal Information depends on the purposes for our collection and use and requirements pursuant to applicable laws. For more information on our retention practices, see the Protection and Retention of Information section of our Privacy Policy above.

Categories of Sources of Personal Information that We Collected About California Consumers in the Preceding 12 Months:

  • Directly from you. For example, when you create an account, make a purchase, browse our website, or use our app(s), interact with our third party social media pages or services, or apply for or accept an employment position with us.
  • PUMA Affiliates. Other companies within the PUMA Group.
  • PUMA Customers. Your friends, family or other parties. For example, if you are the recipient of a gift card, we may collect Personal Information such as your name and email address.
  • Online Activity. Directly and indirectly from activity on the Services, and third-party social media pages and other services. For example, see the types of collection in the “Automatically Collected Information” section above.
  • Social Networks.
  • Advertising Companies.
  • Service Providers who provide services on our behalf such as those used to fulfill orders, process your payments and requests, verify your information, monitor activity in connection with our Services, provide analysis and analytics, maintain databases, administer and monitor emails and marketing, administer and send mobile messages, serve ads on this and other services, and provide consulting services.
  • Third Parties such as data providers, operating systems and platforms.
  • Government Entities and other public sources.

Business or Commercial Purposes for Which We Collected, “Sold,” or “Shared” Personal Information of California Consumers in the Preceding 12 Months: Business Purposes: (1) performing services and providing products, (2) quality control or safety, (3) internal research, (4) auditing interactions, (5) debugging, (6) short-term transient use, and (7) security and fraud prevention. Additional business purposes include disclosing PI to third parties for other than a “sale”/“share” or one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with applicable law or legal process, and to the consumer or other parties at the consumer’s request, as well as for the additional purposes explained in our Privacy Policy or at the time of collection (“Other Business Purposes”).

Commercial Purposes: In addition, we may process Personal Information for our commercial purposes which are to advance our commercial interests, such as by encouraging another person to buy a product or enabling or effecting a commercial transaction.

For more detailed examples of our business and/or commercial processing purposes see the Use of Information section of our Privacy Policy and the Purposes for which Personal Information is Processed section of our State Notice.

Categories of Third Parties to Whom Personal Information was “Sold”, “Shared” or Disclosed in the Preceding 12 Months:

While we do not sell (as “sell” is traditionally defined) your Personal Information to third parties, we do share information with third parties such as Advertising Companies for advertising purposes which may be considered a “sale” of “personal information” under California law.

We may disclose PI to our service providers, other vendors (including those that facilitate interest-based and other advertising and marketing), affiliates, and/or third parties to which we “sell” or “share” your Personal Information including without limitation, the following Categories of Personal Information and the Categories of Recipients in the preceding 12 months:

Identifiers
Business Purpose Disclosure: Service providers for services related to payment processing, data accuracy, fraud detection and security, order processing and management, logistics, shipping, customer relationship management, web and mobile development, email marketing and advertising Sale/Share: Marketing and Advertising providers

Personal records

Business Purpose Disclosure: Service providers for services related to payment processing, data accuracy, fraud detection and security, order processing and management, logistics, shipping, customer relationship management, web and mobile development, email marketing and advertising Sale/Share: None

Characteristics

Business Purpose Disclosure: Service providers for services related to data accuracy, fraud detection and security, customer relationship management, web and mobile development, email marketing and advertising

Sale/Share: None

Customer Account Details / Commercial Information
Business Purpose Disclosure: Service providers for services related to order processing and management, logistics, shipping, customer relationship management, email marketing and advertising
Sale/Share: Marketing and Advertising providers

Online Usage Information
Business Purpose Disclosure: Service providers for services related to order processing and management, logistics, shipping, customer relationship management, email marketing and advertising
Sale/Share: Marketing and Advertising providers

Geolocation Data
Business Purpose Disclosure: Service providers for services related to order processing and management, logistics, shipping, customer relationship management, email marketing and advertising
Sale/Share: Marketing and Advertising providers

Audio/Visual and Similar Information

Business Purpose Disclosure: Service providers for services related to security, loss prevention, asset protection, traffic pattern analysis, data accuracy, fraud detection, order processing and management, logistics, shipping, customer relationship management, web and mobile content development, email marketing and advertising.

Sale/Share: None

Inferences Derived From Personal Information

Business Purpose Disclosure: Service providers for services related to web and mobile development and site personalization, email marketing and advertising
Sale/Share: None

California Consumer Privacy Rights

California residents may have certain rights pursuant to California law, as described below.

  1. Right to Know (Access and Portability Rights)
  2. Right to Correct
  3. Right to Deletion
  4. Right to Opt Out of Sale or Sharing
  5. Right to Nondiscrimination
  6. Right to Limit Use of Sensitive Information

I. Right to Know. If you are a consumer who resides in California you have the right to request, twice in a 12-month period, a report that details the categories of Personal Information collected about you, the categories of sources from which the Personal Information is collected, the purposes for collecting the Personal Information, the categories of Personal Information that we disclose for a business purpose, sell or share and the categories of third parties with whom the information is shared, and the specific pieces of Personal Information collected about you. To exercise your rights, please see the “Exercising Your Rights” section of this California Notice.

II. Right to Correct. If you are a consumer who resides in California you have the right to correct inaccurate Personal Information we hold about you. To exercise your rights, please see the “Exercising Your Rights” section of this California Notice.

III. Right to Deletion. If you are a consumer who resides in California you have the right to request that we 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, as explained below, we will delete (and direct our service providers to delete) your Personal Information, unless an exception applies. If an exception applies, we will inform you of that and limit retention and use to the permitted purpose. To exercise your rights, please see the “Exercising Your Rights” section of this California Notice.

IV. Right to Opt Out of Sale or Sharing. If you are a customer who resides in California, you also have the right to opt out of the “sale” or “sharing” of your Personal Information. While we do not sell (as “sell” is traditionally defined) your Personal Information to third parties, we do disclose information to third parties for advertising purposes which may be considered a “sale” or “sharing” of “Personal Information” under California law for which you are entitled to opt-out. California residents may opt out of the “sale/share” of Personal Information by submitting a Do Not Sell/Share My Personal Information (https://us.puma.com/us/en/do-not-sell-my-personal-information) request. To exercise your rights, please see the “Exercising Your Rights” section of this California Notice. Note that you also can use the Global Privacy Control (“GPC”) to signal your opt-out preference as explained in the Exercising Your Rights section below. We do not knowingly sell Personal Information of consumers under the age of 16.

V. Right to Nondiscrimination. You have the right to not receive discriminatory treatment for the exercise of your privacy rights under California law.

Financial Incentives

We offer various financial incentives that might qualify as a “financial incentive” program under the CCPA. For example, we may provide discounts, coupons and other benefits for customers who sign up to receive our marketing emails. When you participate in a financial incentive, we may collect Personal Information from you, such as identifiers such as your name and email address and commercial information such as your purchase history. Participation in financial incentive program is optional for California consumers and any terms and conditions will be made available at the point of opt-in or in a confirming email. You can opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt-out of the financial incentive, or our subsequent use of your Personal Information in connection with a financial incentive, at any time by contacting us as set out above, or as otherwise described in program terms, or by making a deletion request. If we condition the benefits on any limitation of your California privacy rights (e.g., you must consent to continued receipt of marketing to receive ongoing benefits), the benefits provided will be reasonably related to the value of the Personal Information provided, as will be more fully explained in the program terms. If you do not believe that the value you receive is reasonably related to the value of your applicable Personal Information, do not participate.

VI. Right to Limit the Use or Disclosure of Sensitive Personal Information. Except with regard to our HR data subjects (i.e., California job applicants and current or former employees and independent contractors), we only process sensitive Personal Information for purposes that are exempt from choice under California law. If you are a HR data subject who resides in California, you may request PUMA limit sensitive Personal Information processing to certain purposes and if you do so we will explain in a response what processing purposes California law does not allow you to limit. To exercise your rights, please see the “Exercising Your Rights” section of this California Notice.

You may also obtain information on how to make, and may submit, a request by asking a manager at any of our California retail locations. We will not discriminate against you for exercising any of the rights that are provided to you under California law.

Exercising Your Rights

To exercise your rights to know, delete, correct, and/or limit our processing of sensitive Personal Information, please submit a verifiable consumer request to us by either:

PUMA
Attn: Privacy Officer
455 Grand Union Boulevard
Somerville MA, USA 02145

To exercise a Do Not Sell/Share My Personal Information request:

  • Opt-out for non-cookie Personal Information: To opt-out of the sale/sharing of your non-cookie Personal Information (e.g., your email address), you may make an opt-out request here (https://us.puma.com/us/en/do-not-sell-my-personal-information).
  • Opt-out for cookie Personal Information: To opt-out of the sale/sharing of such Personal Information, you need to exercise a separate opt-out request on our cookie management tool by selecting the “Cookie Settings” link in the footer. This is because we have to use different technologies to apply your opt-out of cookie Personal Information and to non-cookie Personal Information. Our cookie management tool enables you to exercise such an opt-out request and enable certain cookie preferences on your device. You must exercise your preferences on each of our websites you visit, from each browser you use, and on each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again via our cookie management tool. Beware that if you use ad blocking software, our cookie banner may not appear when you visit our services and you may have to use the link above to access the tool.
  • Use of Global Privacy Control: Businesses are required to process global privacy control (“GPC”) signals, which is referred to in California as opt-out preference signals (“OOPS”), which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the sale and sharing of Personal Information. To use an OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC. We have configured the settings of our consent management platform to receive and process GPC signals on our website. We process OOPS/GPC with respect to sales and sharing that may occur in the context of collection of cookie Personal Information by tracking technologies online by third-party digital businesses and apply it to the specific browser on which you enable OOPS/GPC. We currently do not, due to technical limitations, process OOPS/GPC for opt-outs of sales and sharing in other contexts (e.g., non-cookie Personal Information). We do not: (1) charge a fee for use of our service if you have enabled OOPS/GPC; (2) change your experience with any product or service if you use OOPS/GPC; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the OOPS/GPC. To learn more about the GPC, please visit https://globalprivacycontrol.org/. If you delete cookies or reset your device, you may need to set your preference again to ensure we continue to honor your preferred choice.

You may also obtain information on how to make, and may submit, a request by asking a manager at any of our California retail locations.

Verifying and Fulfilling Requests

To protect your privacy and comply with the California law, and except in connection with a Do Not Sell/Share request, we will need to verify your request (i.e., verify you). The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information, and in the cases more sensitive or important Personal Information we require that be done to a high degree of certainty. We do this in a number of ways depending upon how we have interacted with you in the past, as more fully described in the next section. For security purposes, we will not collect sensitive Personal Information as part of the verification process. We do not use Personal Information you provide during verification for other purposes other than to keep a record of your request.
  • Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it.

We may not be able to fully respond to your right to know, deletion, or correction requests if we cannot verify your identity consistent with the standards for verification and security and confirm that the Personal Information relates to you. Once we receive your request, we are required to verify that you are the person that is the subject of the request, or an authorized agent property acting on behalf of a specific consumer. How we do this will depend on the content of the consumer relationship with us and the sensitivity of the Personal Information. Typically, this consists of matching identifying information provided by you with the information we have about you in our records.

Upon making a request, you will be asked to provide your full name, e-mail address, shipping address and telephone number. Providing accurate information that matches our records is necessary so that we can locate the correct information within our systems and among our service providers. To verify your request, we may ask you to submit evidence beyond your basic Personal Information in order to prove your identity, especially if you seek to delete Personal Information or obtain copies of it. You may submit this information simultaneously with your initial request (by email) or after your request (as a second step). For requests of specific pieces of sensitive Personal Information about a consumer, we will verify your identity to a reasonably high degree of certainty; whereas for requests to know the categories of Personal Information collected and used about a consumer, we will verify your identity to a reasonable degree of certainty. We may give you options, such as (i) submitting a signed statement and a redacted copy of identifying information (such as a government-issued ID), or (ii) verifying your identity with a third party verification company that we may hire for this purpose. If we ask you to verify your identity, you must promptly cooperate with our efforts so that we can fulfill your request. If you do not comply, your request cannot be fulfilled; and if you delay in complying, the fulfillment of your request is likely to be delayed, and may be denied, as a result. If we cannot verify your identity, we will not be able to fully respond to your request. However, if we cannot verify you sufficiently to provide specific pieces, we will treat the request as a categories request, and if we cannot reasonably verify you for that, we will refer you to this Notice for our general practices. If we cannot sufficiently verify you as necessary for a deletion request, we will give you the opportunity to opt-out of sale.

If you are a California resident, we will make commercially reasonable efforts to accommodate your request within 45 days. We may, however, extend the timeframe to total of 90 days, if an extension is reasonably necessary. We reserve the right to deny any request, in whole or in part, to the extent permitted by applicable law, but will explain the basis for that in our response to you. We will fulfill a right to know request from an individual up to two times in any twelve-month period. As permitted by California law, if a request is unduly burdensome or unfounded, we may reject it or condition further efforts on payment of reasonable costs. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request. Some Personal Information we maintain about consumers is not sufficiently associated with enough Personal Information about the consumer for us to be able to verify that it is a particular consumer’s Personal Information when a consumer request that requires verification pursuant to the verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). Accordingly, we do not include that Personal Information in response to those requests.

Consistent with California law and our interest in the security of your Personal Information, we will not deliver to you your driver’s license number or other government-issued id number, financial account number, any health or medical identification number, an account password, security questions or answers, or unique biometric data generated from measurements or technical analysis of human characteristics in response to a privacy rights request; however, you may be able to access some of this information yourself through your account if you have an active account with us.

Requests from Authorized Agents

California law permits an authorized agent to exercise any of the above California privacy rights on an individual’s behalf, subject to certain requirements. If you submit a request, other than opt-out of sale, on behalf of a consumer other than yourself, you will be required to demonstrate your legal authority to act on behalf of that person, and we may contact you and/or the consumer for verification purposes as permitted by California law. As permitted by California law, we may require that you provide information necessary to verify the identity of the person who is the subject of the request, or that such person verify his/her own identity directly with us before we fully respond to your request as an authorized agent. We reserve the right to deny requests, including an opt-out of sale request, where we reasonably suspect that the request is fraudulent. For the protection of our customers, we must receive all information requested and must verify an agent’s legal authority to our satisfaction consistent with what California law requires or permits before we can fulfill a request by an authorized agent.

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

California HR Data Subjects

California HR data subjects can learn more about our data practices as relates to them by contacting us via email at usprivacy@puma.com.

California Do Not Track Notice

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently is no industry or legal standard for recognizing or honoring DNT signals, we don't respond to them at this time. A DNT signal is not a global privacy control signal. For more information on global privacy control, see the Exercising Your Rights section above.

California’s Shine the Light law

If you are a California resident, you are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their own direct marketing purposes in the preceding calendar year. To request the above information, please Contact Us and identify yourself as a California consumer making a “Shine the Light” request. Please note that we currently do not disclose any Personal Information to third parties for their direct marketing purposes under California’s Shine the Light law.

California Minor Eraser

Additionally, if you are a registered user under the age of 18 and a resident of California, you may request removal of content you have posted to our online services. Requests can be made by Contacting Us. Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third party we do not own or control may copy the posting and repost it elsewhere.

VIRGINIA,COLORADO AND CONNECTICUT PRIVACY NOTICE

Last updated date July 1, 2023

This State Privacy Notice (“State Notice”) supplements the PUMA Privacy Policy. It applies only to consumers located in Virginia, Colorado and Connecticut and addresses Personal Information we collect online and offline. This State Notice does not apply to PUMA personnel or job applicants.

This State Notice uses certain terms that have the meaning given to them in the applicable laws and implementing regulations in Virginia, Colorado and Connecticut.

In addition of what is already disclosed in the general section of this Privacy Policy, please find the following additional information relevant for the State Notice.

Categories of Personal Information Collected:

We may process the categories of personal information listed in the Information We Collect and How and California Privacy Notice sections of our Privacy Policy.

Purposes for which Personal Information is Processed:

We may process the Personal Information we collect about you for the purposes listed in the Use of Information section of our Privacy Policy and as outlined below:

Processing Purposes and Categories of Personal Information

Providing customer service, including responding to your requests or inquiries: Identifiers, Personal records, Characteristics, Customer Account information, Online usage information, Geolocation data, Audio/visual and similar information, Inferences

Processing and completing your transactions including, as applicable, order confirmation, billing, enrollment in programs, and delivering products or services: Identifiers, Personal records, Characteristics, Customer Account information, Online usage information, Geolocation data, Audio/visual and similar information

Personalizing your experience with the Website and our products or services with content and offers that are tailored to you: Identifiers, Characteristics, Customer Account information, Online usage information, Geolocation data, Inferences,

Delivering relevant advertisements to you: Characteristics, Customer Account information, Online usage information, Geolocation data, Inferences

Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings offers, event invitations, and other information: Identifiers, Characteristics, Customer Account information, Online usage information, Geolocation data, Inferences

Including you in market research, surveys, promotions, sweepstakes, and contests: Identifiers, Geolocation data

Improving the Services based on the experiences and purchasing decisions of our customers and improving the interactions visitors have with the Services, including counting ad impressions to unique visitors, verifying positioning and quality of ad impressions: Online usage information, Geolocation data

Evaluating your shopping experience or our products and services or to create new products or services: Identifiers, Customer Account information, Online usage information, Geolocation data, Audio/visual and similar information, Inferences

Alerting you about a product safety announcement or recall or correction of an offer, promotion, or advertisement: Identifiers, Customer Account information

Keeping a record of our interactions with you if you place an order or otherwise deal with our representatives over the telephone or online: Identifiers, Customer Account information, Geolocation data, Audio/visual and similar information

Verifying and validating your identity or otherwise preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Information, and the Website or data systems: Identifiers, Personal records, Customer Account information, Online usage information, Geolocation data

Complying with our legal obligations including complying with law enforcement or governmental authority requests, participating in judicial proceedings, responding to requests from third parties based on their statutory rights against us (IP infringement, piracy, other unlawful activity) and investigating fraudulent activity: Identifiers, Personal records, Characteristics, Customer Account information, Online usage information, Geolocation data, Audio/visual and similar information

Processing and evaluating your application and related materials you submit as a job applicant: Identifiers, Characteristics

Interacting with you when you contact us as a vendor or on behalf of another business: Identifiers, Audio/visual and similar information

Enabling you to interact with third parties (e.g., content service providers), whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment: Identifiers, Online usage information, Geolocation data,

Creating aggregated, pseudonymized, or de-identified information for analytical and statistical other purposes: Identifiers, Characteristics, Customer Account information, Online usage information, Geolocation data, Inferences

For compliance purposes, including enforcing our Terms & Conditions, other agreements and policies or other legal rights, or as may be required or permitted by applicable law or requested by any judicial process or governmental agency: Identifiers, Personal records, Characteristics, Customer Account information, Online usage information, Geolocation data, Audio/visual and similar information, Inferences

Disclosure of Personal Information:

We disclose the following categories of your Personal Information with the categories of third parties listed in the Disclosing and Transferring of Information section of our Privacy Policy:

  • Contact information and other information about you (including your name, email address, physical address, shipping address, telephone number) and other demographic information.
  • Internet or other electronic network activity information (including cookies and mobile device IDs, and related browsing information).
  • Commercial information (including products and services purchased, products and services you are considering purchasing that are placed in your virtual shopping cart, information about products that you have returned, product orders you have cancelled, and product reviews).
  • Location information (including geolocation information).
  • Transactional information such as information you provide to us via customer service calls, emails, SMS and chats. This information may be recorded and processed consistent with our Privacy Policy.

Processing Personal Information for Sale and Targeted Advertising:

We may share your Personal Information with our social media, Data Analytics, Online Advertising Services and Advertising Networks and other such third parties for the purposes of targeted advertising.

We do not sell your Personal Information in exchange for monetary consideration. We may share your Personal Information with certain third parties as described above, which may be considered a “sale” under some state laws when the Personal Information is exchanged for non-monetary consideration.

We will not discriminate against you for exercising any of the rights that are provided to you under applicable state laws.

We may sell/share for targeted advertising the following categories of your Personal Information with the categories of third parties listed in the Disclosing and Transferring of Information section of our Privacy Policy: Identifiers, Customer Account information, Online usage information, Geolocation data.

We do not conduct profiling in furtherance of decisions that produce legal or similarly significant affects for consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Consumer Privacy Rights

Depending on where you reside, you may have certain rights pursuant to the applicable state laws, as described below.

Right to Delete: You have the right to request that we delete certain Personal Information we collected from you.To exercise your rights, please see the “Exercising Your Rights” section of this State Notice.

Right to Know: You have the right to request, twice in a 12-month period, a report that details the categories of Personal Information collected about you, the categories of sources from which the Personal Information is collected, the purposes for collecting the Personal Information, the categories of third parties which whom we share the Personal Information and the specific pieces of Personal Information collected about you.To exercise your rights, please see the “Privacy Rights” section of the Privacy Policy.

Right to Correct: You have the right to correct inaccurate Personal Information we hold about you. For existing customers, you may log in your account to correct your Personal Information. For non-customers, please see the “Exercise of Your Rights” section of this State Notice.

Right to opt-out of Processing for Purposes of Sale and Targeted Advertising: You have the right to opt-out of sharing information with third parties for the purposes of sale and targeted advertising. To exercise your rights, please see the “Exercising Your Rights” section of this State Notice. Note that you also can use the Global Privacy Control (“GPC”) to signal your opt-out preference. To learn more about the GPC, please visit https://globalprivacycontrol.org/. If you delete cookies or reset your device, you may need to set your preference again to ensure we continue to honor your preferred choice.

Right To Limit Sensitive Personal Information Processing: We only process sensitive Personal Information for purposes that are exempt from consumer choice under Virginia, Colorado and Connecticut laws. 

We will not discriminate against you if you exercise any of your privacy rights.

Exercising Your Rights

To exercise any of your consumer privacy rights, please submit a verifiable consumer request to us by either:

  • Calling us at: 1-888-565-PUMA (7862) (tel:1-888-565-7862)
  • Emailing us at: usprivacy@puma.com, or
  • Writing to us at:

PUMA
Attn: Privacy Officer
455 Grand Union Boulevard
Somerville MA, USA 02145

You may also obtain information on how to make, and may submit, a request by asking a manager at any of our relevant retail locations.

Verifying Requests. We have various procedures to verify that you are authorized to exercise your rights under the applicable state laws. If you have an account with us, we may ask you to verify your identity by requiring you to sign-in to your account or complete a form requesting certain information. If you do not have an account and request access to, correction of or deletion of your Personal Information, we may require you to provide any of the following information: first and last name, email address, country, street address, city and zip code. You also can designate an authorized agent to make these requests on your behalf, though we will need to verify the authority of such agent pursuant to our procedures. For more information on our verification procedures, see the Verifying and Fulfilling Requests section of our California Privacy Notice.

Authorized Agents. For information on how to submit an authorized agent request, see the Requests from Authorized Agents section of our California Privacy Notice.

Appeals. If we deny your request, we will notify you and provide our reasons for the denial and instructions regarding the rights you may have under applicable laws to appeal the decision. If the appeal is denied, we will notify you of your rights under applicable laws to contact the Attorney General to submit a complaint. If you are a resident of Virginia and your appeal is denied, you can contact the Virginia Attorney General’s Office through the following link: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

CONTACT US

If you have any questions, you may contact us as follows:

  • Calling us at: 1-888-565-PUMA (7862) (tel:1-888-565-7862)
  • Emailing us at: usprivacy@puma.com, or
  • Writing to us at:

PUMA
Attn: Privacy Officer
455 Grand Union Boulevard
Somerville MA, USA 0214

NEVADA PRIVACY NOTICE

If you are a resident of Nevada, you have the right to opt out of sales of your Personal Information. Although we currently do not sell Personal Information as defined by Nevada law (Nevada Revised Statutes, Chapter 603A, Section 1.6), you can submit an opt-out request to us at usprivacy@puma.com identifying yourself and your Nevada residency status and requesting to exercise your Nevada opt-out of sale rights in the event we do sell covered information under the law in the future. We have the right and obligation to verify you.

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