Privacy Notice for California and Connecticut Residents

Effective Date: May 2023

This Privacy Notice for California and Connecticut Residents supplements the information contained in the Company’s Privacy Notice and applies solely to all visitors, users, and others who reside in the States of California and Connecticut (“consumers” or “you“). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), and the Connecticut Data Privacy Act of 2023 (“CTDPA”, with the CPRA and CCPA the “Laws”)).Any capitalized terms in this Notice not otherwise defined in this Notice have the same meaning as provided in the CCPA.

This Privacy Notice applies to all information collected through our website including the leapingfox.com, the Express Console application, any related websites or applications which we own or control (collectively, the “Sites”), and/or any related services, products, software, tool, data feed, sales, marketing, or events we perform (collectively, the “Services“). This Privacy Notice does not apply to any non-affiliated third-party sites or services.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some its requirements.

Information We May Collect

We collect information that identifies, relate to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from OUR consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal Information Records (Cal. Civ. Code § 1798.80(e))	Name, signature, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information.	YES
C. Protected Classification Characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, mental or physical disability, sex, pregnancy or childbirth and related medical conditions, sexual orientation, veteran or military status, genetic information.	YES
D. Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric Information	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke patterns, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or Other Network Activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation Data	Physical location or movements.	NO
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or Employment-Related Information	Current or past job history or performance evaluations.	NO
J. Non-Public Education Information	Education records directly related to a student maintained by an educational institution, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or disciplinary records.	NO
K. Inferences Drawn from Other Personal Information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.	NO

We reserve the right to obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Sites. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information for future use.
To provide, support, personalize, and develop our Sites, products, and Services.
To create, maintain, customize, and secure your account with us and to provide experiential and custom products in collaboration with our affiliates.
To process your requests, purchases, transactions, and payments.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your experience on our Sites and to deliver content, products, and Services relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Sites, products, Services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Sites, products, and Services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the Laws.

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

Sale of Personal Information

We do not sell your personal information to third parties for business purposes and will notify you in advance of any change in this policy.

Reselling Personal Information

We do not sell your personal information to third parties for business purposes and will notify you in advance of any change in this policy.

Deidentified Patient Information

We do sell and/or disclose deidentified patient information exempt from the Laws to third parties. To deidentify the patient information, we followed the HIPAA expert determination method and/or the HIPAA safe harbor method.

Your Rights and Choices

The Laws provides consumers that are California or Connecticut residents with specific rights regarding their personal information. This section describes your rights under the Laws 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. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
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.

We do not provide these deletion rights for B2B personal information except as required by applicable law.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at support&leapingfox.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12month period. The verifiable consumer request must:

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

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

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

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

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we 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.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers at this time. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at [email protected] with the title “Do Not Sell My Personal Information”.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing such request to [email protected]

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

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the Laws. Unless permitted by the Laws, 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 you certain financial incentives permitted by the Laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Leaping Fox LLC, 11 Dean Street, #2, Stamford CT 06902. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Sites and update the notice’s effective date. Your continued use of our Sites and/or Services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described here and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California or Connecticut law, please do not hesitate to contact us at Leaping Fox LLC, 11 Dean Street, #2, Stamford CT 06902.