This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“CA Privacy Notice”) supplements the information contained in the Privacy Policy of Caramel Inc, Doing business in California as Caramel Holdings. (“we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“California Consumers” or “you”).

I.                Information We Collect About Our California Consumers

A.              Types of Information We Collect

To maintain best-in-class standards and technologies, and to provide you with the best possible service, in the past twelve months we may have collected through the course of our business the following types of information:

B.              How We Collect  Information

We collect information in a variety of ways, each of which gives us a different opportunity to tailor our services (the “Services”) and provide you with the best experience possible. Our methods include gathering information from you through forms, applications, surveys, and other online fields offered throughout our Services; in email, text, and other electronic messages between you and us; and when you interact with our advertising and applications on third-party websites and services.

C.              Why We Collect  Information

We may use the information thatwe collect from you to:

• Provideyou with the services or products that we offer; or
• Respond to your inquiries, requests, or other service-related purposes; or
• Communicate with you to administer the Services, including notifying you about any updates,changes, or additions to the Privacy Policy; or
• Enhance your experience with us, such as tailoring content to your preferences or developing new products or services based on your interactions with the Services; or
• Send you information about products or services that we think may be of interest to you; or
• Carryout any specific purposes for which we have obtained your prior consent;or  
• Conduct any other legitimate business activities not otherwise prohibited by law.

We may also use your information for business 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 the consumer’s personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term,transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business,and to improve, upgrade, or enhance the service or device that is owned,manufactured, manufactured for, or controlled by the business.

II.                Information We Share or Collect About Our California Consumers

We will not sell your personal information such as name, email address, physical address, or phone number unless you give us permission. However, California law defines “sale” broadly in such a way that the term sale may include using targeted advertising on the Services or other affiliated sites. Like most online publishers and social networks, we use these services, which enable us to provide the Services and relevant offers to you, including at your request.  

As such, our use of these services may constitute a California-covered “sale” for the following categories of information to advertising partners in the last twelve months: identifiers such as Internet Protocol address, device IDs, cookie IDs, and advertising IDs;demographic information such as age bracket, commercial information such as the types of products or services you are interested in purchasing.

We may share information about you with relevant and appropriate third parties in the following situations:

• To our service providers that perform functions on our behalf; or
• To protect or enforce our rights or property, to protect your safety or the safety of others, or to investigate, prevent, or take action against fraud or other illegal activities; or
• In response to legal process or as otherwise required by law; or
• If we go through a business transition or corporate transaction, such as a merger, capital investment, acquisition by another company, or sale of all or a portion of its assets; or
• To conduct any other legitimate business activities not otherwise prohibited by law.

Notwithstanding anything else in the Privacy Policy, we may share aggregate or non-personally identifying information about California Consumers with third parties for marketing,advertising, research, or other business purposes.

III.               Your Rights as a California Consumer

As a California resident, you have certain rights regarding your personal information.

A.            Opting Out of “Sales”

As discussed above, we will not sell your personal information such as name, email address, physical address,or phone number unless you give us permission. However, like most online publishers and social networks, we use targeted advertising services on the Services or other affiliated sites, which enable us to provide the Services and relevant offers to you, including at your request. We may share (meaning communicating personal information to a third party for cross-context behavioral advertising) the following categories of information to advertising partners: identifiers such as Internet Protocol address, device IDs, cookie IDs, and advertising IDs; demographic information such as age bracket,commercial information such as the types of products or services you are interested in purchasing. 

We do not knowingly sell the personal information of consumers under 18 years of age.

You have the right to direct us not to “sell” or “share” your personal information by emailing us at privacy@drivecaramel.com.

B.            Your Access Rights

You have the right to request from us the following information: (1) the categories of personal information we have collected about you; (2) the categories of sources from which your personal information is collected; (3) the business or commercial purpose for collecting, selling, or sharing your personal information; (4) the categories of third parties to whom we disclose personal information; (5) the specific pieces of personal information we have collected about you; (6) the categories of personal information sold or shared about you and the categories of third parties to whom the personal information was sold or shared; and (7) the categories of personal information that the business disclosed about the consumer for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

To the extent that we sold any of your personal information or used any of your personal information for a business person, you have the right to request that we disclose to you: (1) the categories of personal information that we collected about you; (2) the categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and (3) the categories of personal information that we disclosed about you for a business purpose.

Please note that the CCPA and CPRA prohibits us from disclosing to anyone the following information in response to a request to know a consumer’s Social Security number, driver's license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password,security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.

You can exercise your right via the Do Not Sell My Personal Information or bye mailing privacy@drivecaramel.com.

C.            Your 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.
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You can exercise your right via the Do Not Sell My Personal Information or bye mailing privacy@drivecaramel.com.

D.            Your Correction Request Rights

You have the right to request that we correct your personal information that we maintain that is inaccurate, taking into account the nature of the personal information and the purposes of the processing of the personal information. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information.

You can exercise your right via the Do Not Sell My Personal Information or by emailing privacy@drivecaramel.com.

E.            Your Right to Limit the Use and Disclosure of Sensitive Personal Information

You have the right to direct us to limit our use of your sensitive personal information that we have collected to the following,subject to any exceptions provided under the law:

• Use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
• To perform the following services:
  
  o  Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; or
  o  Short-term,transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with us, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with us; or
  o  Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf; or
  o Undertaking activities to verify or maintain the quality or safety of a service or device that is owned,manufactured, manufactured for, or controlled by us, and to improve, upgrade,or enhance the service or device that is owned, manufactured, manufactured for,or controlled by us; or
• As authorized by regulations adopted pursuant to the CCPA and CPRA.

Sensitive personal information that we collect or processed without the purpose of inferring characteristics about you is not subject to this right to limit.

E.            How to Exercise Your Rights

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. To exercise any of the rights listed above, please submit a verifiable consumer request to us by submitting the appropriate request via email. We will only use personal information provided in a consumer request to verify the requestor's identity or authority to make such a request.Please note you may only make a verifiable consumer request for access or data portability twice within a 12-month period. However, you may change your mind and opt back into personal information sales at any time by e-mailing Caramel at privacy@drivecaramel.com. If we are unable to comply with a request, we will inform you of the reason why.  

Please note that Caramel must verify the identity of the requestor by requesting your full name, email address and phone number associated with your account, and account number. You may designate an authorized agent to make a request on your behalf by providing proof of a valid power of attorney, your valid government issued identification, and the authorized agent’s valid government issued identification. We cannot respond to requests where the identity and authority of the request or cannot be confirmed. We do not charge afee 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.

G.            Non-Discrimination Policy

California residents that choose to exercise such rights will not be denied any goods or services,charged different prices or rates, or be provided a different level or quality of goods or services unless those differences are related to your personal information.

H.            Shine the Light Disclosure

You may request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.

IV.                Changes to Our Privacy Notice for California Residents

We reserve the right to modify this CA Privacy Notice at any time. If we make changes to this CA Privacy Notice, we will make the modified version available on our Privacy Hub. Your continued use of the Services after any modification to this CA Privacy Notice will constitute your acceptance of such modification.

V.                Contact

If you have any questions about this policy, please contact us in any of the following ways: (1) call us at the following toll-free number: (800) 976-8305, or (2)send us an email at privacy@drivecaramel.com; or mail your questions orcomments to Caramel, Inc. , Attn: General Counsel, 16350 Ventura Blvd, SuiteD53, Encino, CA 91436.

PRIVACY NOTICE FOR CONNECTICUT RESIDENTS

Effective September 01, 2022

Pursuant to Connecticut General Statutes Sec. Section 42-471, it is the policy of Caramel to protect the privacy of your personal information by doing the following:

1. Safe guarding any data, computer files and documents containing your personal information from any misuse by third parties; or
2. Destroying,erasing, or making unreadable any data, computer files and documents containing your personal information prior to their disposal; or
3. Protecting the confidentiality of your Social Security number and other personal information;or
4. Prohibiting the unlawful disclosure of your Social Security number and other personal information; or
5. Limiting and/or restricting the access to your Social Security number and other personal information to other third parties and
6. Limiting the access of your Social Security number and other personal information only to our employees who need access to your personal information to allow us to provide legal services to you, limiting the access of these employees to the extent that it is needed, and otherwise imposing restrictions and reasonable safeguards on our employees to prevent them from accessing your personal information.

PRIVACY NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to restrict us from selling certain personal information about you to third parties. Specifically, you have the right to restrict us from selling information about you that we have collected through our online services and is tied to or includes a personal identifier indicating your identity. Personal identifiers include your name, Social Security Number,email or physical address, telephone number, or other information that could be used to verify your identity or contact you. We do not sell your personal information, so you don’t need to tell us not to. 

Notice Of Rights Of Virginia, Colorado, Connecticut, And Utah Residents Regarding Processing Of Sensitive Data And Right To Opt Out Of The Sale Of Personal Data, Processing Of Personal Data For Targeted Advertising,And Profiling In Furtherance Of Decisions That Produce Legal Or Similarly Significant Effects
‍As provided by the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), and the Utah Consumer Privacy Act (“UCPA”), we do not process your sensitive data without obtaining your consent. We do not process sensitive data concerning a known child without processing such data in accordance with the federal Children’s Online Privacy Protection Act (15 U.S.C. § 6501 et seq.). Additionally, you have the right to opt out of the sale of your personal data to third parties,the use of your personal data for targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. You may exercise your right to opt-out without fear of discrimination. To exercise your right to opt out of the sale of your personal data, the use of your personal data for targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, you can do any of the following:

• Call us at the following toll-free number: (800) 976-8305, or
• Send us an email at privacy@drivecaramel.com ; or mail your questions or comments to Caramel, Inc., Attn: General Counsel, 16350 Ventura Blvd, Suite D513, Encino, CA 91436.

A request to opt-out must be a verifiable request. We may deny a request to opt-out if we are unable to authenticate the request through commercially reasonable efforts, or we may ask for additional information that is reasonably necessary to authenticate the request. This request to opt-out does not apply to Virginia, Colorado, Connecticut, or Utah job applicants or independent contractors.

Retention of Personal Information

We will retain each category of personal information in accordance with our established data retention schedule as indicated above. In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to, the business purposes for which the Personal Information was collected; relevant federal, state, and local record keeping laws; applicable statutes of limitations for claims to which the information may be relevant;legal preservation of evidence obligations; and administrative considerations.

Children's Privacy

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under the age of 18. If you believe that we have personal information about a child, please notify us immediately, and we will delete the information as quickly as possible.

Contact

If you have any questions, please contact us at privacy@drivecaramel.com.

Changes to Our Privacy Policy

Caramel reserves the right to amend this privacy policy at our discretion and at anytime. It is our policy to post any changes we make to our privacy policy on this page.  If we make material changes to how we treat our users’ identifying and/or personal information, we will notify you through a notice on the www.drivecaramel.com website home page.  The date the privacy policy was last revised is identified at the bottom of the privacy policy.  You are responsible for ensuring we have an up-to-date,active, and deliverable email address for you and for periodically visiting our website and this privacy policy to check for any changes.  Your continued use of our website following the posting of changes constitutes your acceptance of such changes.