Rev. 9/8/2023

This Bambu Privacy Act Notice which includes the California Consumer Privacy Act Notice Notice (collectively, “Notice” or “Policy”) applies to the Bambu Systems, LLC (hereinafter, “Bambu”, “we”, “our” or “us”) visitors to our website at any other websites to which this Privacy Policy is posted (collectively, the “Site”),users of our mobile banking application that provides access to mobile banking services (the “Bambu App”), and any other web property to which this Policy is linked.  These services permit consumers who are prepaid account holders at our sponsor bank, Metropolitan Commercial Bank (or such other sponsor bank as Bambu may use in the future) (“Sponsor Bank”), to perform banking functions and services (“Services”) through the use of an Apple or Android mobile device (e.g., smartphone or tablet).  Bambu’s principal address is 6525 N. Quail Hollow Road, Suite 300, Memphis Tennessee 38120, USA.

This Notice describes how we may collect, store, use, share and protect the personal information about consumers, including California residents, who visit our Site and users (the “users”, “you” or “your”) of the Bambu App in connection with any services, content, communications, and product features (services and products accessed by the Bambu App and the Site, the “Services”).  The following terms may change at any time, so we suggest you consult them periodically by visiting this Notice on the Bambu App or Site.

The Notice also explains certain rights that California residents have under the California Consumer Privacy Act (the “CCPA”).  This Notice explains how California residents can exercise their rights under the CCPA to request that we:  (1) provide certain personal information that we have collected about them during the past 12 months, along with related information described below or (2) delete certain personal information that we have collected from them.

This Notice applies to information about consumers, including residents of California.  However, if you are not a resident of California, we will not process your request as described in this Notice.  We reserve the right to change the practice of not accepting such requests from individuals who are not California residents at any time and without prior notice.

Under this Notice, including the CCPA, “personal information” is information that identifies, relates to, or could reasonably be linked with a particular consumer, including a California resident or their household.  This information is referred to in this Notice as “Personal Data.” or “Personal Information”.  This Notice explains how we collect, use, and disclose personal information about consumers, including California residents or their household.

Some information is NOT Personal Data:

  • De-identified information. Information delinked and disassociated from any identifying information that cannot be reidentified is not Personal Data.
  • Aggregated information. If a set of Personal Data is sorted into conclusions about a group, and the individual consumer identities have been removed and are not linked or reasonably linkable to a consumer or household, it is not Personal Data.

This Notice covers our privacy practices only.  This Notice does not apply to the practices of third-party websites, services or applications, including third parties with whom we partner or use such as our Sponsor Bank.  These third-party services are governed by each such third party’s privacy policy.  We are not responsible for the privacy policies and practices of websites other than that of ours, and we are not responsible for the failure of unaffiliated third parties to honor their privacy obligations.  The Sponsor Bank privacy policy will apply to information you provide in connection with opening and using your Bambu App account and in connection with your Bambu App account transactions.


This Notice is part of, and is governed by, our Bambu Mobile App Terms of Use (the “Agreement”).  Please read the Agreement, this Notice, and any other applicable policies carefully before you use our Services.  Terms not defined in this Notice shall have the meanings given to them in our Agreement.

By accepting the Agreement and by downloading, registering and/or using the Bambu App, you acknowlege you have read, understood and agreed to the terms and conditions set forth in this Notice, and you agree and give your consent for us, our representatives, agents and/or third-party service providers to use, process, and disclose your Personal Data and any other information about you in the manner described in this Notice.

Changes to this Policy

If we make a material change to this Policy, we will provide you with at least thirty (30) days notice before the new version takes effect including by sending an email to the email address associated with your account.  You are responsible for staying informed of any changes.  It is therefore very important that you make sure we have a current email address for you on file so that you will receive notice of any material changes.  In addition, if you want to continue to use the Services, you may also be required to affirmatively accept the revised Policy the first time you use the Services and log in to your user account after the new version takes effect.  By accepting the revised Policy or continuing to access or use the Services after applicable changes become effective, you agree to be bound by the revised Policy.  If any changes to the Policy are not acceptable to you, you must terminate your account and stop using the Services.  You can review the most current version of the Policy at any time by visiting the link at

Why?Companies choose how they share your Personal Information.  Federal law gives consumers the right to limit some but not all sharing.  Federal law also requires us to tell you how we collect, share, and protect your Personal Information.  Please read this Notice carefully to understand what we do.

The types of Personal Information we collect and share depend on the product or Service you have with us.  This information can include:

·         Social Security number and income

·         Account balances and payment history

·         Credit history and credit scores

When you are no longer our customer, we continue to share your information as described in this notice.

How?Companies need to share customers’ Personal Information to run their everyday business.  In the section below, we list the reasons financial companies can share their customers’ Personal Information; the reasons Bambu chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Bambu share?

Can you limit this sharing?

For our everyday business purposes

such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus



For our marketing purposes

to offer our products and services to you



For joint marketing with other financial companies



For our affiliates’ everyday business purposes

information about your transactions and experiences



For our affiliates’ everyday business purposes

information about your creditworthiness



For our affiliates to market to you



For nonaffiliates to market to you



Questions or to limit our sharing:

Call us at (833) 882-2628; or submit your request via email at

Who we are

Who is providing this notice?

Bambu Systems, LLC (“Bambu”)

How does Bambu protect my personal information?

To protect your Personal Information from unauthorized access and use, we use security measures that comply with Federal law and industry standards. These measures include computer safeguards and secured files and buildings.

How does Bambu collect my personal information?

We collect your Personal Information, for example, when you:

·         Open an account or deposit money

·         Pay your bills

·         Use your prepaid card

·         We also collect your Personal Information from others, such as credit bureaus, affiliates, or other companies

Why can’t I limit all sharing?

Federal law gives you the right to limit only

·         Sharing for affiliates’ everyday business purposes – information about your creditworthiness

·         Affiliates from using your information to market to you

·         Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.  See below for more on your rights under state law.



Companies related by common ownership or control.  They can be financial and nonfinancial companies.


Companies not related by common ownership or control. They can be financial and nonfinancial companies.


Do Not Call Policy.  This notice is the Bambu Do Not Call Policy under the Telephone Consumer Protection Act.  We do not solicit via telephone numbers listed on the state or Federal Do Not Call lists, unless the law allows.  Bambu employees receive training on how to document and process


telephone marketing choices.  Consumers who ask not to receive telephone solicitations from Bambu will be placed on the Bambu Do Not Call list and will not be called in any future campaigns, including those of Bambu affiliates.

Call Monitoring and Recording. If you communicate with us by telephone, we may monitor or record the call.

For Nevada residents only. We are providing you this notice under state law.  You may be placed on our internal Do Not Call List by following the directions in the “to limit our sharing” section.  Nevada law requires we provide the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702.486.3132; email:; Bambu Systems, LLC  Address: P.O. Box 171 West Palm Beach, FL 33402; Phone number: (833) 882-2628, email:


For Vermont residents: Under Vermont law, we will not share information we collect about Vermont residents with companies outside of our company family, unless the law allows.  For example, we may share information with your consent, to service your accounts or under joint marketing agreements with other financial institutions with which we have joint marketing agreements.  We will not share information about your creditworthiness within our company family except with your consent, but we may share information about our transactions or experiences with you within our company family without your consent.


For California residents: Under California law, we will not share information we collect about you with companies outside of Bambu, unless the law allows.  For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to.  We will limit sharing among our companies to the extent required by California law.


Session Trackers: If you would prefer not to accept Session Trackers when using the Site, follow the instructions provided by your website or mobile browser (usually located within the “Help”, “Tools” or “Edit” facility) to modify your Session Tracker settings.  Please note that if you disable Session Trackers, you may not be able to access certain parts of our Site and other parts of our Services may not work properly.  As a result, we recommend that you leave Session Trackers turned on when accessing the Services because they allow you to take advantage of all of the Service’s features.


Geolocation data:  You may opt out of the collection of location data at any time by changing your settings on your mobile Device.  However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

Do Not Track Signals: Currently, we do not monitor or take any action with respect to Do Not Track signals or other mechanisms, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

Marketing: California law permits California residents to ask us for a notice that identifies the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us at the address provided under the “Contact Information” section. You may opt out of any email marketing communications that Bambu sends to you by following the instructions provided in the applicable email marketing communications you receive. You may also request that your Personal Data not be used for marketing activities by sending an email to Transactional communications about your account or our Service are not considered “marketing” communications.

Use of the Services by Children:  The Services are not directed to children.  You must be at least 18 years or older to use our Services. We also adhere to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect information from users under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us at  If we become aware that a child under 13 has provided us with Personal Data, we will take steps to delete the applicable information from our files.

No Mobile Text Messaging for Marketing Programs: When downloading or using the Bambu App, you must provide a mobile phone number.  You hereby certify that you are the account holder for any mobile phone number(s) you may supply to Bambu.  Message and data rates under your own plan with your phone carrier may apply for any text messages.  You expressly agree to receive text messages and phone calls (from us or our third-party providers) providing verification codes to complete your registration for or to use our Services.  If your mobile phone is off, out of range or subject to a variety of other conditions, you may not receive the message or messages may be delayed.  Wireless carriers are not liable for delayed or undelivered messages.  We will not text you messages for marketing programs. 

Email Marketing:  You may opt out of any email marketing communications that Bambu sends to you by following the instructions provided in the applicable email marketing communications you receive. For example, you can click on the “Unsubscribe” link in marketing communications emails. You may also request that your Personal Data not be used for marketing activities by sending an email to Transactional communications about your account or our Service are not considered “marketing” communications.

Social Sharing Features:  Our Services include social sharing features for common social networks to let users share content.  These features are served from third-party services that may serve their own cookies.  The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.  For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Analytics and Advertising Services Provided by Others.  We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the Internet.  These entities may use cookies, device identifiers, web beacons and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, web browser, pages viewed, mobile network information, time spent on pages or in apps, links clicked and conversion information.  This information may be used by us and others, to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity.  For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit  Your Device may also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.  Please review the settings of your Device for more information.

Voice Features:  When you use Siri, the things you say will be recorded and sent to Apple to process your requests.  Your device may also send Apple other information (collectively, your “User Data”).  All of this User Data is used to help Siri on your iOS device and any paired Apple Watch understand you better and recognize what you say.  If you have geolocation turned on, the location of your Device at the time you make a request will also be sent to Apple to help Siri improve the accuracy of its response to your requests.  You may choose to turn off Location Services or Siri at any time.  To do so, access Settings on your iOS device. Information collected by Apple will be treated in accordance with Apple’s Privacy Policy, which can be found at

We may share your Personal Information as follows:

  1. Third-Party Service Providers. We may use third parties to perform certain services on our behalf in connection with the Services such as:
  • to process and store data, including your Personal Information;
  • to track, analyze, and modify our Services;
  • for marketing, advertising, and distribution;
  • to assist us in providing you with customer support; and
  • to support our IT and security efforts.

Google Analytics. Google Analytics is as an analytics service provider. Learn more about how Google collects and uses data here To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.

The third parties we work with do not have permission to use the information we share with them beyond what is necessary to assist us. We execute agreements with third parties to ensure they use adequate safeguards when processing your Personal Information in accordance with this Policy.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

  1. Merger, Bankruptcy, or Corporate Reorganization. We may disclose and transfer your Personal Information to a subsequent owner, co-owner, or operator of Bambu or the Services, or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets (i.e., a bankruptcy proceeding), or other corporate change. We will notify you with any choices you may have regarding your Personal Information when we are engaged in a merger, bankruptcy, or corporate reorganization.


  1. Legal Obligations and Safety. We may share your Personal Information if it is reasonably necessary to:
  • Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);
  • Comply with requests or investigations by public authorities;
  • Comply with applicable laws or regulations;
  • Enforce or apply the Bambu policies or policies of our business partners;
  • Protect the security or integrity of the Services; or
  • Protect the rights, property, or safety of Bambu, our employees or users, partners and affiliates, or other natural persons.

For any other purpose, with your consent. We may share your Personal Information on your behalf or at your request. We will only do so with your specific consent. If you provide your consent to share your information, you may withdraw your consent at any time. Withdrawing your consent will not undo or reverse the lawfulness of any previous processing, and in some cases Personal Information may not be retrieved once shared. Contact us if you would like to withdraw your consent.

Bambu and California Consumer Privacy Act (“CCPA”) Privacy Statement


The following Bambu and CCPA Privacy Statement shall not apply to the collection, processing, sale or disclosure of any information (i) that a consumer provides to us to obtain a financial product or service from us, or (ii) about a consumer resulting from any transaction involving a financial product or service between us and the consumer; or (iii) we otherwise obtain about a consumer in connection with providing a financial product or service to that consumer.


To better understand your rights in respect of any such information excluded from the following Bambu and CCPA Privacy Statement, please instead reference excluded information below.


This PRIVACY STATEMENT FOR  CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy above.

We adopt this statement to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this statement.  For California residents, the provisions of this Privacy Statement prevail over any conflicting provisions of the Bambu Privacy Policy above.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including consumers or households subject to the CCPA (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:






Full name and Federal or state issued identification numbers including Social Security number, driver’s license number and passport or other U.S. or non-U.S. government identification number, physical characteristics such as government issued photo ID and photo image of your face (selfie), email address, mobile number, username and 4 digit Bambu App PIN, or other similar identifiers.



Categories of Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Full name, date of birth, Social Security number, physical characteristics such as government issued photo ID and photo image of your face (selfie), physical address (including proof of address such as a utility bill), mobile number, passport number, driver’s license or state identification card number, financial information such as Bambu or external (Bambu linked) bank account number, bank name and any related bank information, education, employment, employment history, personal bank name or any other financial information, medical information, or health insurance information.  If you opt in and agree that in order to provide or make more convenient using the Services, we may collect names, address, email addresses and mobile phone numbers in your contact list and/or your mobile phone address book on a regular basis.




Protected classification characteristics under California or Federal law

Age (40 years or older), national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).



Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.



Biometric information

Behavioral or activity patterns used to extract a template or other identifier or identifying information, such as keystroke or other physical patterns.



Internet or other similar network activity

Device identifiers such as information regarding the computer, mobile device, technology or other device (collectively “Device”) you use to access the Services, including your Device’s manufacturer, model number, mobile phone plan carrier, operating system type and version, browser type and version, standard web log information, network connection type, language and other settings, mobile network information including phone number, other Device identifiers, performance and usage data, and other similar technical data.  We collect this information through your use of our Site and Bambu App, your mobile phone plan carrier and our risk investigation and mitigation vendor.


Internet protocol (“IP”) addresses from your internet service provider (“ISP”), who assigns it of the various ISPs associated with you or your Devices.


Web beacons (transparent graphic images placed on our Site or in an email to identify you) and customized links (also known as “clear GIFs” or “pixel tags”) to indicate that you have viewed our Site or an email; tell your browser to get content from another server; and measure traffic to or from, or use of, our online content and your related browsing behavior and provide you with more focused communication.


Cookies, session trackers, local shared objects and similar session-tracking technologies (“Session Trackers”) to identify you and your Site sessions or information on your interaction with an application, or advertisement. 



Geolocation data

Physical location or movements.  Geolocation data from your Device about your location while you are accessing or using the Bambu App and while you are not accessing or using the Bambu App. 



Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information



Professional or employment-related information

Current or past job history or performance evaluations



Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records



Inferences drawn from other Personal Information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


Under the CCPA, Personal Information does not include:


  • The excluded Personal Datadescribed above


  • Other information to the extent excluded from the CCPA’s scope, like:


  • Information lawfully available from government records and used for a purpose consistent with its availability is not Personal Data.


  • Personal Information covered by certain sector-specific Federal and California privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (CalFIPA) and the Driver’s Privacy Protection Act of 1994; and


  • Health or medical information that constitutes clinical trial data or that is otherwise covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH), or the California Confidentiality of Medical Information Act (CMIA).



With respect to each of the categories of Personal Information listed in the table above, we obtain such Personal Information from a variety of sources, including from:

  • our customers and consumers, with respect to both online and offline interactions they may have with us or our service providers and other entities with whom you transact;


  • others with whom you maintain relationships who may deal with us on your behalf;


  • the Devices you use to access our Sites, mobile applications and online services;


  • credit bureaus;


  • identify verification and fraud prevention services;


  • marketing and analytics providers;


  • public databases;


  • social media platforms; and


  • others consistent with this Privacy Notice.

Use of Personal Information


With respect to each of the categories of Personal Information listed in the table above, we may use or disclose such Personal Information for any one or more of the following business purposes:

·         To fulfill or meet the reason for which the information is provided.  For example, if you provide us with Personal Information in order to open a bank account;

·         To provide you with information, products or services that you request from us;

·         To provide you with email alerts, event registrations and other statements concerning our products or services;

·         To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;

·         To detect and protect against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecute the same;

·         To debug to identify and repair errors in our systems;

·         As otherwise necessary or appropriate to protect the rights, property or safety of us, our customers, consumers or others;

·         To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

·         For such purposes as may be necessary or appropriate in connection with audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;

·         To improve our Site and Bambu App and present their content to you;

·         For testing, research, analysis and product development;

·         For short-term, transient use including contextual customization of ads; and/or

·         As otherwise described to you when collecting your Personal Information or as otherwise set forth in this Privacy Notice and the CCPA.

Sharing Personal Information

With respect to each of the categories of Personal Information listed immediately below, we may disclose such Personal Information to a third party for a business purpose.

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

Category A:


Category B:

California Customer Records Personal Information categories

Category C:

Protected classification characteristics under California or Federal law

Category D:

Commercial information

Category E.

Biometric Information

Category F:

Internet or other similar network activity

Category G:

Geolocation Data

Category H:

Sensory Data

Category I:

Professional or employment-related information

Category J:

Non-public education information

Category K:

Inferences drawn from other Personal Information

With respect to each of the categories of Personal Information listed immediately above, we may disclose such Personal Information for a business purpose to the following categories of third parties:


  • Our affiliates
  • Service providers
  • Such third parties as our customers or consumers may direct us to disclose (or consent to the disclosure of) their personal information


We have not within the preceding twelve months, and will not, sell (as that term is defined by the CCPA) any Personal Information that we collect.


We do not disclose Personal Information of individuals we know to be under the age of 16 to any business or third parties for monetary or other valuable consideration as a “sale” under California law, without affirmative authorization

Your Rights and Choices


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

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (“Access Request”).  Once we receive and confirm your verifiable consumer request, we will disclose to you:

·         The categories of Personal Information we have collected about you.

·         The categories of sources for the Personal Information we have collected about you.

·         Our business or commercial purpose for collecting or selling that Personal Information.

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

·         The specific pieces of Personal Information we collected about you (also called a data portability request).

If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

·         the categories of Personal Information about you that we have sold within the meaning of the CCPA and the categories of third parties to whom the Personal Information was sold; and

·         the categories of Personal Information about you that we disclosed for a business purpose.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions “Deletion Request”).  Once we receive and confirm your verifiable Deletion Request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.


Privacy and data protection laws, other than the CCPA, apply to much of the Personal Information that we collect, use, and disclose.  When these laws apply, Personal Information may be exempt from, or outside the scope of, Access Requests and Deletion Requests.  As a result, in some instances, we may decline all or part of an Access Request or Deletion Request related to this Personal Information.  This means that we may not provide some or all of this Personal Information when you make an Access Request.  Also, we may not delete some or all of this Personal Information when you make a Deletion Request.

As examples, our processing of or response to an Access Request or Deletion Request may not include some or all of the following Personal Information:

  • Consumer Accounts.  Personal Data connected with consumer accounts used for personal, family or household purposes.  Our sponsor bank has privacy notices describing use and sharing of this data.  Examples of this exemption are the collection of Personal Information to open a bank account or complete the transaction for which we collected the Personal Information, otherwise 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; the detection of security incidents, protection against malicious, deceptive, fraudulent, or illegal activity, or prosecution of those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality.
  • Employment.  Personal Information about an individual who is a current or former employee or job applicant, and we use that Personal Information within the context of that individual’s role as a current or former employee or job applicant.
  • Business-to-Business Relationships.  Certain Personal Information we collect in the course of providing a product or service to another business, or in the course of receiving a product or service from another business.


We also may deny your Deletion Request if retaining the Personal Information is necessary for us or our service providers to:

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • 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.

The types of Personal Information described above are examples. We have not listed all types of Personal Information that may not be included when we respond to or process Access Requests or Deletion Requests.

In addition to the above examples, we may not include Personal Information when we respond to or process Access Requests or Deletion Requests when the CCPA recognizes another exception.  For example, we will not provide the Personal Information about another individual where doing so would adversely affect the data privacy rights of that individual.

Exercising Access, Data Portability, and Deletion Rights

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

·         by writing us at P.O. Box P.O. Box 171 West Palm Beach, FL 33402;

·         by calling the Customer Service telephone number which is (833) 882-2628

·         and by emailing us at


Only you or a person who you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information.  Under California law, you may designate an authorized agent to make a request on your behalf.  You may make such a designation by providing the agent with written permission to act on your behalf.  Your agent may be subject to the same verification procedures that we use to verify consumers who do not currently have a relationship with us.  As permitted by law, we may require you to verify your own identity in response to a request even if you choose to use an agent and may require that you sign and submit a notarized form.


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.

·         Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Verifying Your Request

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.  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 your identity or authority to make the request.  We may otherwise limit our response to your request as permitted under applicable law.


Whenever feasible, we will match the identifying information provided by you to the Personal Information we maintain or use a third-party identity verification service that complies with the CCPA.  However, if we cannot verify your identity from the Personal Information that we maintain, we may request additional information from you, which shall only be used for the purposes of verifying your identity.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we reasonably require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  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. Under the CCPA, we are only obligated to respond to requests twice per twelve month period.


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.


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

·         Deny you goods or services.

·         Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

·         Provide you a different level or quality of goods or services.

·         Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


However, we may offer, and you may consent to receive certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.  You may revoke your consent to participate or receive such financial incentive at any time.

Accessibility Statement

If you use assistive technology and the format of this privacy statement interferes with your ability to access information, please contact us at  To enable us to respond in a manner most helpful to you, please indicate the preferred format in which to receive the material and your contact information.  Users who need accessibility assistance can also contact us at

Contact Information

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


·         by writing us at P.O. Box P.O. Box 171 West Palm Beach, FL 33402; or

·         by calling the Customer Service: (833) 882-2628