Privacy Notice — California-Specific Addendum

If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household [subject to the California Consumer Privacy Act] ("California Personal Information"). For such residents, the provisions of this California Addendum prevail over any conflicting provisions of the Privacy Notice.

Safeguard has collected the following categories of California Personal Information within the last 12 months¹

(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.

(B) Personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute). This means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, 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 any other financial information, medical information, or health insurance information.

(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

(E) Biometric information.

(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement.

(G) Geolocation data.

(H) Audio, electronic, visual, thermal, olfactory, or similar information.

(I) Professional or employment-related information.

(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.²

¹ Cal. Civ. Code § 1798.100(a)(5)(B).

Within the last 12 months, within the meaning of the California Consumer Privacy Act, we have sold California Personal Information identified in the above categories A-K.³

Within the last 12 months, we have disclosed California Personal Information identified in the above categories (A)-(K) for our business purposes. To learn more about the categories of third parties with whom we share such information, please see Privacy Policy.

We obtain California Personal Information from a variety of sources.⁴ [These sources include: yourself, with respect to both online and offline interactions you may have with us or our service providers; other entities with whom you transact; others with whom you maintain relationships who may deal with us on your behalf; the devices you use to access our websites, mobile applications, and online services; credit bureaus; identify verification and fraud prevention services; marketing and analytics providers; public databases; social media platforms; and others consistent with this Privacy Notice.] Please see Privacy Policy.

We use the California Personal Information we collect for the business purposes disclosed within this Privacy Notice. Please see Privacy Policy. Please note that the business purposes for which we may use your information include:⁵

Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;

Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;

Debugging to identify and repair errors in our systems;

Short-term, transient use including contextual customization of ads;

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; and

Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide.

Conducting internal research to develop and demonstrate technology; and

Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide.

² Cal. Civ. Code § 1798.130(c).

³ Cal. Civ. Code § 1798.130(a)(5)(C)(i).

⁴ Cal. Civ. Code § 1798.110(c)(2).

⁵ "Business purpose"; is a defined term under the CCPA. Cal. Civ. Code § 1798.140(d). This notice takes the position that ";business purpose" includes any reasonable operational purpose, but we note that the definition is unclear. Possibly, ";business purpose"; may mean only the specific listed items within the definition (audits, detecting security incidents, etc.).

We may also use the information we collect for our own or our service providers' other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.

Your California Rights

If you are a California resident, you have certain rights related to your California Personal Information. [You may exercise these rights free of charge except as otherwise permitted under applicable law.]

Section 100 Rights. You have the right to request that we disclose to you the specific species of personal information we have collected.

Section 105 Rights. You have the right to request that we delete California Personal Information about you which we have collected from you.

Section 110 Rights. You may request that we disclose to you:

the categories of California Personal Information we have collected about you;

the categories of sources from which the California Personal Information is collected;

our business or commercial purpose for collecting or selling California Personal Information;

the categories of third parties with whom we share California Personal Information; and

the specific pieces of information we have collected about you.

Section 115 Rights. To the extent that we sell your California Personal Information within the meaning of the California Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:

the categories of California Personal Information that we have collected about you;

the categories of California Personal Information about you that we have sold within the meaning of the California Consumer Privacy Act and the categories of third parties to whom the California Personal Information was sold, by category or categories of personal information for each third party to whom the California personal information was sold; and

the categories of California Personal Information about you that we disclosed for a business purpose.

Right to Opt Out. In addition, we may sell your information within the meaning of the California Consumer Privacy Act. You have the right to opt out of such sales here. Submit an opt-out request.

You may request to exercise these rights by:⁶

By completing our rights request form available here privacy@gosafeguard.com

Calling us toll-free at 877-861-8985.

[As required or permitted under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted under applicable law.] Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:

Denying you goods or services;

Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

Providing you a different level or quality of goods or services; or

Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.⁷

Do Not Sell My Personal Information

If you are a California resident, you have the right to opt out of our sales of certain information relating to individuals and households subject to the California Consumer Privacy Act. To exercise this opt-out right, whether you have an account or not, please submit a request via privacy@gosafeguard.com. If you do not have an account, include your name and email address or mailing address.

⁶ Pending legislation provides for alternative means of exercising rights. AB 1564. This draft reflects the law as currently in effect.

⁷ Cal. Civ. Code § 1798.130(a)(5).