VI. YOUR RIGHTS

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

A. Right to Access

You have the right to know the information contained in this policy and our website Privacy Policy, and to request access to a copy of the Personal Information that we have collected about you directly or indirectly, including Personal Information collected by a service provider or contractor on our behalf.

B. Request to Know

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 to know, 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 that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we disclosed your Personal Information for a business purpose, the Personal Information categories that each category of recipient obtained.

C. Request to Delete

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

We may deny your request to delete if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

D. Right to Correct

In certain circumstances, you have the right to request correction of any inaccurate personal information.

E. Right to Opt-Out/Do Not Sell Personal Information

We do not sell your Personal Information for monetary or other valuable consideration.

We do not share your Personal Information for the purposes of cross-context behavioral advertising. Cross-context behavioral advertising under the CPRA is “the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.

F. Right to Limit the Use of Sensitive Personal Information

We limit our use of Sensitive Personal Information to only the purposes necessary to perform covered services, and for certain business and commercial purposes described above.

G. Right to Non-Discrimination

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

H. Exercising Your Rights

To exercise your rights to requests described above, please submit a verifiable consumer request to us by either:

• Calling us toll-free at 212-355-3595
• Using the web form available at TAIAMERICA.COM/CPRA-REQUEST/
• Emailing us at WPPInquiries@taiamerica.com with the subject line “California Rights Request”

Only you or a person legally authorized to act on your behalf, may make a verifiable consumer request to know or request to delete. You may also make a verifiable consumer request on behalf of your minor child.

A 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.

You may only make a verifiable consumer request to know twice within a 12-month period.

We cannot respond to your request to know or request to delete 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. Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfil your request.

To verify your identity, we will ask that you provide the following information when you submit your request:

• First Name
• Last Name
• Email Address
• Mobile Phone Number
• Address
• City
• State
• Zip Code
• Brief description of your relationship with TAI and the nature of your request.

We will only use this information to confirm your identity. If we cannot successfully verify your identity, we will inform you of that fact.

I. Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact WPPInquiries@taiamerica.com. 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. 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 to know or request to delete 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.