California Consumer Privacy Policy

This California Addendum supplements the “The Recreational Group Privacy Policy”; capitalized terms that are undefined in the California Addendum have the meanings defined in the Privacy Policy. If you are a California consumer, the following provisions apply to the processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“California Personal Information”) collected by or on behalf of The Recreational Group, LLC (collectively, “TRG”, "we", "us", or "our"). For California consumers, the provisions of this California Addendum prevail over any conflicting provisions in other sections of the Privacy Policy. We share California Personal Information such as California residents’ use of our Online Services with our marketing and advertising partners for cross-contextual advertising purposes as further described below. Otherwise, we do not sell California Personal Information. Additionally, we do not sell or share, and we have not sold or shared, California Personal Information of individuals we know to be under 16 years of age.

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We have collected the following categories of California Personal Information:

(a) Identifiers, such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties such as Linked Sites, your family and friends, Franchised Operators and Licensees, and public databases.

(b) Personal information described in subdivision (e) of Section 1798.80 (California customer records statute), such as a name, address, telephone number, or email address. This category of information is collected from you, your devices, other TRG Group entities, Franchised Operators, or other third parties such as our business partners.

(c) Characteristics of protected classifications under California or federal law such as age, gender, race, ethnicity or national origin. This category of information is collected from you when you choose to provide it to us directly or indirectly through our service providers and business partners as part of our surveys and market research.

(d) Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category of information is collected from you, your devices, other TRG entities, Franchised Operators and Licensees or other third parties such as our business partners.

(e) Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding a consumer’s interaction with a website, application, or advertisement. This category of information is collected from you and your devices.

(f) Geolocation data, including physical location or movements. This category of information is collected from you and your devices.

(g) Sensory data, including electronic, visual, or similar information. This category of information, such as photos, is collected from you and third parties such as Linked Sites, TRG entities, our service providers, or Franchised Operators.

(h) Inferences, such as a profile about a consumer’s preferences, characteristics, and behavior, drawn from information we collect and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.

(i) Sensitive personal information, such as account login information allowing access to an account, precise geolocation data, race, and ethnicity, in each case as further described above in the relevant categories. Please note we do not collect sensitive personal information for the purpose of inferring characteristics about you.

Please see the TRG “Information we share” Section of the Privacy Policy to learn more about the types of information we collect and how we collect them. We retain each category of California Personal Information as described in the “Retention” section of the Privacy Policy.

For each of the above categories, we use the California Personal Information for a variety of purposes such as:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Helping to ensure security and integrity to the extent the use of a consumer's personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors in our systems;
• Short-term, transient use including contextual non-personalized advertising shown as part of a consumer’s current interaction with us;
• Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
• Conducting internal research to develop and demonstrate technology;
• Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
• Other purposes described in the “How we use your Information” Section of the TRG Privacy Policy.

We may also use the information we collect for our operational purposes, purposes for which we provide you additional notice, provided that such additional purposes are compatible with the context in which the California Personal Information was collected, or with your consent.

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Your California Privacy Rights

If you are a California consumer, you have certain rights related to your California Personal Information, including:

• The right to know what California Personal Information we have collected about you, including the categories of personal information, the categories of California Personal Information, the categories of sources from which the California Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing California Personal Information, the categories of third parties to whom we disclose California Personal Information, and the specific pieces of California Personal Information we have collected about you.
• The right to correct inaccurate California Personal Information that we have collected about you.
• The right to delete California Personal Information that we have collected from you, subject to certain exceptions. For example, we may not be able to delete your information when you have an account credit on your TRG or TRG Entity account. If you have an account credit and would like to understand options available to you, please contact us at privacy@recreationalgroup.com.
  • Please note, processing your deletion request will result in the elimination of your TRG or TRG Entity account, which will also limit your ability to utilize the full suite of features available in TRG applications.
• The right to opt out of the sale or the sharing of California Personal Information.
  • We do not sell California Personal Information, but if you wish to opt out of the sharing of California Personal Information for cross-context behavioral advertising, please contact us at privacy@recreationalgroup.com.
• The right to limit the use or disclosure of your sensitive personal information.
  • We do not use or disclose sensitive personal information for purposes that, under applicable law, require us to support the right to limit the use or disclosure of sensitive personal information.
• The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by applicable law, including the right not to be retaliated against for the exercise of your rights.
  • We will not discriminate against you for exercising your privacy rights, however you may miss out on promotional offers.

You may request to exercise these rights by emailing us at privacy@recreationalgroup.com

As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.

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. We will require the agent to provide proof of that written permission. To the extent 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.