Privacy Policy - United States and Canada

Last Updated: January 1, 2024

Last Reviewed: January 1, 2024

SpotHero, Inc., its subsidiaries, related companies, and/or affiliates (“SpotHero,” “we,” “us,” or “our”) offer marketing services (“Marketing Services”) regarding the location and potential availability of certain parking spots (“Parking Spots”) to users (“Users”) through our website, www.spothero.com and associated software application(s) (“Apps”) (collectively, the “Site”). In so doing, we market the Parking Spots on the Site and facilitate the reservation (“Reservations”) of Parking Spots between Users of the Site and owners, lessors, managers or operators of Parking Spots (“Licensors”) (collectively, Users and Licensors of the Site may be referred to as “you” or “your”).

SpotHero values individual privacy rights and wants to give you the opportunity to understand the kind of information that we collect and how you can control our collection, use, and sharing of your information, including Personal Information (defined below), as detailed in this privacy policy (“Privacy Policy”). By using the Marketing Services or the Site, you agree that you have read and understood the Privacy Policy. The Privacy Policy describes:

  • the information that SpotHero collects from you;
  • how that information is used, transferred, and disclosed by SpotHero; and
  • the rights and options available to you.

This Privacy Policy is incorporated as part of the SpotHero Terms and Conditions, available at https://spothero.com/legal/terms-of-use. This Privacy Policy does not apply to workforce-related Personal Information collected from job applicants. You can view our Applicant Privacy Notice here or via our Careers page.

Important note for former Parking Panda users: Thank you for visiting SpotHero! If you are looking for the last version of the Parking Panda Privacy Policy prior to the shut down of the Parking Panda website, please follow this link: https://spothero.com/parking-panda-privacy.

Thank you for reading our Privacy Policy. We hope you enjoy using SpotHero!

Table of Contents

Please use this table of contents to quickly navigate to specific sections of the privacy policy that are of interest to you.

1. Information We Collect

We collect, transmit, and store information that you provide directly to us through (i) use of the Site or Apps, (ii) creation or modification of an account, (iii) requesting to use SpotHero’s Marketing Services as a User or Licensor, (iv) contacting of customer support or other similar communications; and (v) other instances where you may voluntarily provide it to us.

While our collection of information varies based upon our interactions with you, we may collect certain Personal Information. For purposes of this Privacy Policy, “Personal Information” means any 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 individual or household. Personal Information does not, however, include publicly available information from government records, deidentified or aggregate information, or information excluded from the scope of applicable data privacy laws.

The type of Personal Information we may collect, use, transmit, and store is described below:

  • Identifiers. When you create a SpotHero account as a User or Licensor, we store and use information you provide during the account creation process as a User or account onboarding process as a Licensor, such as first and last name, email address, phone number, postal address, login and password information, vehicle information such as, license plate information and make/model/year of a vehicle, and other similar account information (“Account Information”)
  • Payment Information. When you use our Site or Marketing Services as a Licensor, we may collect financial information, such as bank account or wire transfer information to facilitate payments directly to you. If you are using the Site to create Reservations, limited credit card and bank account information may be collected by SpotHero and more detailed credit card or bank account information may be collected by our payment processor, Stripe (https://stripe.com/en-ca/privacy). We never have access to your full credit card number, but, to administer your account and prevent fraud, we may have limited access to the following: the type of credit card you used (Visa, AmEx, etc.), the last four digits of the card number, and the card's expiration date;
  • Internet or Other Similar Network Activities. The IP address from which you access the Site; cookie data; network connection type; browser type; the name of the domain from which you access the internet; the type of device, browser and operating system used to access the Site; the date and time you access the Site and the duration and stop time of such access; the information about any person or entity from whom you were referred; the pages, files, documents and links that you visit; the internet address of the website from which you linked to the Site;
  • Commercial Information and Inferences. Information about your use of the Site or your usage of the Marketing Services generally; information you provide voluntarily when participating in surveys or product improvement interviews; and
  • Geolocation Information. Geolocation information including, with your consent, precise geolocation information.

2. How We Use the Information We Collect

Consistent with the permission you give us to collect Personal Information from you, SpotHero may use such Personal Information for the following legitimate business purposes:

  • To provide, personalize, and improve your experience with the Marketing Services and Site and our advertising made available on or outside of the Site;
  • To ensure technical functionality of the Marketing Services, develop new products and services, and analyze your use of the Marketing Services, including your interaction with applications, advertising, products and services that are made available, linked to, or offered through the Marketing Service;
  • To communicate with you for Marketing Service-related or research purposes including via e-mails, notifications, text messages, or other messages, which you agree to receive;
  • To communicate with you, either directly or through one of our partners, for marketing and promotional purposes via e-mails, notifications, or other messages consistent with any permissions you may have communicated to us;
  • To facilitate payment processing through our third party payment processor, Stripe, or prevent or detect fraud;
  • To facilitate payments directly to you as a Licensor;
  • With your consent, to calculate distance to available Parking Spots and show you Parking Spots near your location;
  • To enforce this Privacy Policy, the Terms and Conditions, and any other terms that you have agreed to, including to protect the rights, property, or safety of SpotHero, Users, Licensors, or any other person, or the copyright-protected content of the Marketing Services;
  • To fulfill the purpose for which you submitted the information and for other uses consistent with that purpose; and
  • As otherwise stated in this Privacy Policy.

3. How We Disclose Your Information

In certain circumstances, we may disclose your Personal Information to third parties for a business purpose, as described below. Otherwise, we do not sell, rent, lease, or “share” Personal Information, and will not disclose your Personal Information to third parties for purposes of their direct marketing without providing notice to you.

With our Affiliates. We share your Personal Information with our affiliates, subsidiaries, and other companies under common control, including companies within the SpotHero group, and require them to honor this Privacy Policy as well.

With Licensors. If you are a User, we share your Personal Information with Licensors for, among other things, facilitating Reservations, confirming your Reservation on-site, troubleshooting on-site Reservation issues, and otherwise for the Licensors’ own business uses, including marketing to you.

With Users. If you are a Licensor, we share your information with Users for, among other things, facilitating Reservations and providing customer support.

With our Service Providers. We share your Personal Information with our service providers who assist us in performing certain services and functions necessary to operate our business, the Site and provide our Marketing Services to you, including services related to communications and hosting, security and fraud prevention, technical and customer support, tracking and reporting usage, marketing, payment processing and other functions. SpotHero shares Personal Information with its service providers subject to obligations consistent with this Privacy Policy, and on the condition that Personal Information is only used on SpotHero’s behalf and pursuant to our instructions.

With Payment Processors. We share your Personal Information with our third party payment processor, Stripe, so that you can pay for Reservations made through the Site or Apps. If you are a Licensor, we share your Personal Information with banks and other financial institutions in order to make payments to you.

To Complete Business Transfers. If we become involved in a transaction involving the sale of all or substantially all of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your Personal Information as part of the transaction. If the surviving entity in that transaction is not us, the surviving company may use your Personal Information pursuant to its own privacy policies, and those policies may be different from this Privacy Policy.

With Marketing, Advertising, and Analytics Service Providers. We may share Personal Information about you with our data analytics and advertising service providers, such as Google Analytics and Rakuten Advertising, to help us measure traffic and usage trends for the Site and to understand more about the demographics and behaviors of our Users and Licensors. These companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. To learn more about Google's privacy practices, click here. To access and use the Google Analytics Opt-out Browser Add-on, click here. To learn more about Rakuten’s privacy practices, click here. To learn more about your rights with respect to Rakuten, click here.

To Protect Rights and Property.  We may disclose your Personal Information to third parties when we believe in good faith that disclosure is necessary to protect our rights, our property, personal safety, or the interests of you or any other person, and to detect, prevent and/or otherwise address fraud, risk management, security or technical issues.

To Comply with and as Required by Law. We may disclose your Personal Information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities. We may also disclose your Personal Information in the good-faith belief that such action is necessary to protect our rights, interests, or property, or to protect your safety or the safety of others.

Aggregate or Anonymous Information. We share User information in the aggregate with third parties, such as Licensors that use our Marketing Services. For example, we may disclose the number of Users that have booked a Reservation in a particular city or a particular location.

At Your Request. We also share your Personal Information as directed or requested by you, or otherwise with your consent.

4. Deidentified Information

In addition to Personal Information, we may also collect deidentified information from you and aggregate information that may not by itself reasonably identify you as the source when you navigate the Site (“Deidentified Information”). Deidentified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law. When we receive or use deidentified information, we maintain it in deidentified form and do not attempt to reidentify the information.

5. Location Information

When you use the Site, we may collect and store general location information, such as an IP address. If you permit us to access location services through the permission system used by your mobile operating system or browser, we may also collect the precise geolocation of your device when the Site is running in the foreground or background of your device. This information may be used to help you locate parking spots near you. You do not have to enable precise geolocation data to use the Site, but its functionality may be affected by your choice.

6. Text Messaging

SpotHero may use the mobile phone number or similar contact information that you provided to us to send text messages to provide you with the Marketing Services and to facilitate your Reservations. For example, SpotHero may send you a text message containing a parking pass or other information allowing you to access a Parking Spot or garage. SpotHero may also use the mobile phone number or similar contact information that you provided to us to send marketing and promotional text messages with your consent. Additionally, SpotHero may send you a text message containing a link to download its Apps, based on your request. Each text will contain instructions permitting you to “opt-out” of receiving future text message communications. However, you cannot revoke your authorization for fraud related communications or legally required communications.

7. Use by Children

The Marketing Services and Site are not intended for use by persons under the age of 16 in the United States (or under the age of majority in Canada, as applicable). We do not seek or knowingly collect Personal Information from individuals under the age of 16, and we request that such individuals do not provide such information.If you are under 16 and a resident of the United States (or under the age of majority in your respective Canadian jurisdiction), you may not use either the Marketing Services or Site. If we learn we have collected or received Personal Information from a child under the age of 16, we will take reasonable measures to promptly delete such information from our systems.

8. Cookies and Interest Based Advertising

Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags, are small bits of text, that are stored on browsers or devices by websites, apps, online media and advertisements. We use cookies and similar tracking technologies for purposes such as: authenticating Users, remembering Users’ preferences and settings, and understanding the behaviors and interests of Users who interact with or use the Site or Marketing Services.

Note that some content or applications, including advertisements, on the Site may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

You can learn more about our use of cookies, as well as your choices related to various tracking technologies, by visiting our Cookie and Interest-Based Advertising Policy.

9. Your Rights and Choices

SpotHero provides ways for you to access and delete your personal information as well as exercise applicable data rights that give you certain control over your personal information. Your Rights and Choices include:

Email Subscriptions. We may, from time to time, communicate with you via email. If you no longer wish to receive promotional emails from us, please let us know by clicking unsubscribe in those messages or by emailing us at support@spothero.com.  Please note that, although you can opt not to receive promotional emails, we reserve the right to send you informational emails about any administrative notices regarding the Site and Marketing Services or important information about your account, as permitted under the CAN-SPAM Act (15 U.S.C. §7701 et seq.).

Text Messages. You can opt-out of receiving text messages by texting STOP from the mobile device receiving the messages. Opting-out of receiving text messages may limit your ability to take advantage of our full range of features and services.

Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Site or Marketing Services.

Location Information. You can prevent your device from sharing location information through your device’s system settings. If you do, this may limit our ability to provide you our full range of features and services.

Cookie Tracking. You may also enable online, where available, a universal opt-out preference tool (such as the Global Privacy Control (“GPC”) signal) that automatically communicates your opt-out preferences, which we intend to respect. Some internet browsers may transmit “do-not-track” signals to websites with which the browser communicates. The Site does not currently respond to these “do-not-track” signals.

Accessing Your Account. You can access or correct your account information at any time by logging into your account or by contacting support@spothero.com (if you are a User) or sellersupport@spothero.com (if you are a Licensor). If you wish to close your account, please contact support@spothero.com (if you are a User) or sellersupport@spothero.com (if you are a Licensor).

Deleting Your Account. You can delete your User account through the SpotHero iOS mobile app by opening the SpotHero app, clicking Account --> Privacy --> Delete My Account. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. Please note that deleting your account is permanent and cannot be undone.

State and Country Specific Rights. Some states provide specific, additional rights to their residents regarding Personal Information. For more information about these rights and how to exercise them, see the State and Country Specific Rights section below.

10. Linked Sites and Third Party Use of Information

The Site may contain links to other websites or applications (“Linked Sites”) that are not owned by SpotHero, such as websites of Licensors.  We do not control the collection or use of any information, including Personal Information, which occurs while you visit Linked Sites. Therefore, we make no representations or warranties for—and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Site are framed within the Site.

11. Data Integrity and Security

We utilize information technology security to keep the information that you provide to us through the Site secure. We also attempt to have privacy protection controls in place with our vendors in order to ensure that your Personal Information is protected from unauthorized access or disclosure. Only authorized employees are permitted to access your personally identifiable information or that of other visitors touring the Site. Notwithstanding, as effective as our reasonable security measures may be, no security system is impenetrable nor is any method of transmission over the Internet or via mobile device, or method of electronic storage, 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information we cannot guarantee its absolute security.

12. International Users

SpotHero is based in the United States of America (“U.S.”), and, regardless of where you use our Site from or otherwise provide information to us, the information may be transferred to and maintained on servers located in the U.S. Please note that any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations and standards, which may not be equivalent to the laws in your country of origin or residence. By using the Site or by providing us with your information, you consent to this collection, transfer, storage, and processing of information to and in the U.S. SpotHero only offers Marketing Services in the U.S. and Canada.

13. Retention

We will retain your Personal Information while you maintain an account with SpotHero or to the extent necessary to provide the Site or Marketing Services. Thereafter, we will keep Personal Information for as long as reasonably necessary: (i) to respond to any queries from Users or Licensors; (ii) to demonstrate we treated Users and Licensors fairly; (iii) for ordinary business continuity procedures; or (iv) to comply with any applicable laws. We delete Personal Information within a reasonable period after we no longer need the information for the purposes set out in this Privacy Policy.

14. Modifications to this Privacy Policy

We may modify this Privacy Policy from time to time in our sole discretion without prior notice to you. The most current version of the Privacy Policy will govern our collection, use, and disclosure of information about you. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically reviewing this Privacy Policy for changes. We will indicate at the top of the Privacy Policy when it was most recently updated. Accordingly, please refer to this Privacy Policy frequently as it may change.

If we make material changes to the Privacy Policy which lessen your rights, we will notify you by email and/or by positing a notice through the Site and/or Apps prior to or on the effective date of the changes. By continuing to access or use the Site or Marketing Services after those changes become effective you agree to the terms of the revised Privacy Policy.

15. Contact Information

If you have questions about this Privacy Policy or wish to contact us regarding our privacy practices, we can be reached via any of the following:

SpotHero, Inc.
125 S. Clark St., Ste. 200
Chicago, IL 60603

Privacy Contact: legal@spothero.com

16. State and Country Specific Rights

Pursuant to certain state laws, you may have additional rights that you may exercise with respect to SpotHero’s collection, use, and sharing of your personal information, as further described below.

SpotHero will not discriminate against you for exercising your rights under any state law.

A. California Residents: Your California Privacy Rights

California Rights Regarding Your Personal Information. If you are a California resident, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (together, the “CCPA”), grants you certain data privacy rights. Your rights include the:

  • Right to Access: You have the right to request a copy of the specific pieces of Personal Information that we have collected about you in the previous twelve (12) months. The information will be delivered by mail or electronically. Upon receipt of a Verifiable Consumer Request, described below, we will disclose: (i) The categories of Personal Information we have collected about you; (ii) The categories of sources from which Personal Information is collected; (iii) Our business purpose for collecting Personal Information; (iv) The categories of third parties with whom we share Personal Information, if any; and (v) The specific pieces of Personal Information we have collected about you.
  • Right to Data Portability: You have the right to receive your Personal Information in a portable, readily usable format that allows you to transmit your information to another entity without hindrance.
  • Right to Correct Inaccurate Information: You have the right to request that we correct inaccurate information about you that we maintain.
  • Right to Deletion: You have the right to request that we delete your Personal Information.
  • Right to Be Free from Discrimination: You have the right to not be discriminated against by us for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not: (i) Deny goods or services to you; (ii) Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (iii) Provide a different level or quality of goods or services to you; or (iv) Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

To exercise your rights, please use the Verifiable Consumer Request method described below. Please be aware that your rights (including those enumerated elsewhere in this Privacy Policy) are limited to the extent permitted by applicable law.

To opt-out of the “sharing” of your Personal Information for personalized or targeted advertising purposes, follow the instructions here or visit our Cookie Preference Center in the footer of our website.

Categories of Information Collected, Disclosed, and Shared. The categories of Personal Information we collect and the sources from which we collect such information are described in Section 1 of our Privacy Policy; the business purposes for which we use this information are described in Section 2 of our Privacy Notice; and the categories of third parties to whom we may disclose this information are described in Section 3 of our Privacy Policy. We have not sold consumers’ Personal Information in the preceding twelve (12) months.

As further described in our Privacy Policy, in the preceding twelve (12) months, we or our service providers may have collected the following categories of Personal Information, as defined in the CCPA, for a business purpose:

  • Identifiers
  • Financial Information
  • Commercial Information
  • Internet or Other Electronic Network Activity Information
  • Geolocation Data Sufficient to Identify a Precise Physical Location
  • Inferences About Preferences and Characteristics Based on Other Personal Information

Sensitive Personal Information. SpotHero does not use or disclose “Sensitive Personal Information,” as that term is defined by applicable law, other than to provide you the Site and Marketing Services, as permitted by California law. SpotHero does not sell or share sensitive Personal Information for the purpose of cross-context behavioral advertising.

California’s “Shine the Light” Law. Separate from the CCPA, California’s “Shine the Light” law permits Users of the Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not disclose your Personal Information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed above in Section 15 (Contact Information).

B. Other State Privacy Rights

Residents of certain states, such as Colorado, Connecticut, Nevada, Virginia, and Utah may have additional Personal Information rights and choices.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their Personal Information;
  • Access and delete certain Personal Information;
  • Data portability;
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their Personal Information, taking into account the information's nature processing purpose;
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Nevada provides its residents with a limited right to opt-out of certain Personal Information sales.  SpotHero does not sell your Personal Information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us at legal@spothero.com.

To exercise your state-specific privacy rights, please use the Verifiable Consumer Request method described below.

To opt-out of the “sharing” of your personal information for personalized or targeted advertising purposes, follow the instructions here or visit our Cookie Preference Center in the footer of our website.

C. Canada Residents: Your Canadian Privacy Rights

Under applicable Canadian privacy legislation, you have the following rights:

  • Access. SpotHero permits the reasonable right of access to your Personal Information. Upon written request and authentication of identity, we will provide you with access to your Personal Information under our control, subject to any legal requirements and applicable exceptions to the right of access. We will make the information available within thirty days or provide written notice where additional time is required to fulfill the request. Where an access request is refused, we will notify you in writing and provide our rationale for refusal along with a list of next steps available to you.
  • Accuracy. If you demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third party service providers to whom the information has been disclosed.
  • Complaint. You may also have the right to complain to the Office of the Privacy Commissioner of Canada or the appropriate provincial Information and Privacy Commissioner if you have concerns related to our privacy practices.

If you are a resident of Canada and would like to exercise any of the aforementioned rights, please click on this link and complete the webform.

Depending on your use of our Site and Marketing Services, you may have the following choices:

  • Cookies Settings and Preferences. You may disable cookies and other tracking technologies through the settings in your browser. While doing so may negatively affect your experience with the use of our Site and Marketing Services, it will not prevent us from transacting with you. You can also update your cookie settings by using our “Cookie Preference Center” tool available in our Site footer.
  • Marketing e-mails. You may sign up for our mailing list in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive marketing e-mails from us, you may choose to unsubscribe at any time by clicking on the “unsubscribe” link in our emails or by contacting us at support@spothero.com.
  • Opt-Outs. You may contact us to opt out of the use or sharing of your Personal Information, including for marketing or advertising purposes, and/or the provision of your Personal Information to our business partners for such purposes.
  • Online behavioural advertising. As outlined further below, we use Google Analytics on our Site. For more information on how Google Analytics collects and processes information, as well as how you can control the information sent to Google, please review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You may control your advertising preferences or opt-out of certain Google advertising products (i.e. the Google Analytics cookies) by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.

17. Verifiable Consumer Request

You can exercise your legal rights by submitting a Verifiable Consumer Request to us by:

Please note that we reserve the right to ask for information verifying your identity and residency prior to disclosing any information to you or acting on your request.  Should we ask for verification, the information you provide to verify your identity and residency will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

If you make a request to exercise your rights, we will strive to respond or act on your request within 45 days of receiving your verifiable request. Notably, however, we reserve the right to extend the time to respond to 90 days when reasonably necessary. 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.

You may only make a Verifiable Consumer Request for access to personal information twice in a 12-month period. We do not charge a fee to process or respond to Verifiable Consumer Requests, 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.

If you wish to appeal SpotHero’s decision to deny a request, please contact us via email within fourteen (14) days at the address listed above in Section 15 (Contact Information) using the subject line: Data Subject Rights Appeal.

18. Effective Date

This Privacy Policy was last modified as of the effective date printed above. This version of the Privacy Policy replaces and supersedes any prior privacy policies applicable to the Site or Marketing Services.

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