Privacy Policy

At Cigars International, your privacy is important to us. We have created this Privacy Policy to describe how we collect, use and share the information that we collect from and about you and the choices you have regarding your information. As more fully described below, we collect, use and share your information to better serve you and to improve our own business processes.

By accessing, browsing or using our websites, facilities, services, mobile, telephonic, and other electronic and online applications (collectively, the “CI Services”), or by your use of any of our programs, content, materials, functionality (collectively, the “Content”), by providing information to us in other ways, or by accepting or entering into any contracts with us, you agree that you have read and understand this Privacy Policy and that you consent to our collection, use, and disclosure of your personal information and other collected information pursuant to the terms of this Privacy Policy. If you do not agree with this Privacy Policy, do not access, browse or use the CI Services.

This Privacy Policy is incorporated into and made a part of any other agreement that references this Privacy Policy or governs access to or use of the CI Services.

Cigars International is a brand owned by BPA Sales, LP. BPA Sales, LP may receive information about you from our affiliated brands and companies, meaning companies that we own, that own us, or that are under common ownership with us (our “affiliates”). We also may provide information about you to our affiliates, and when we do, this Privacy Policy also describes how our affiliates collect, use and share your information. For purposes of this Privacy Policy, when we use the terms “CI,” “we,” “us” and “our,” or similar terms, we are referring to BPA Sales, LP and our affiliates.

This Privacy Policy does not describe the collection, use and disclosure practices of any third parties. For information on the collection, use and disclosure practices of any other companies with which you are doing business, please review their privacy policies.

Changes to this Privacy Policy

We will review this Privacy Policy periodically (at least annually). We reserve the right, in our sole discretion, to revise, update, or change this Privacy Policy at any time. You should check this web page periodically to see if any recent changes to this Privacy Policy have occurred. If we make changes, we will revise the date at the bottom of this Privacy Policy. All changes will be effective immediately upon posting of the updated Privacy Policy. By accessing, browsing or using the Services after any changes are made, you agree to those changes.

Children’s Privacy

The CI Services are not directed to individuals under the age of twenty-one (21). If you are under twenty-one (21), you should not access, browse or use the CI Services. Likewise, you should not provide any personal information to us. We do not knowingly collect or use information from children under 13 through the CI Services. If a parent or legal guardian becomes aware that a child under the age of 13 has provided information to us through the CI Services, the parent or legal guardian should contact us using the information below under “Contact Us” and we will use commercially reasonable efforts to delete that information. Visit the Federal Trade Commission website (www.ftc.gov ) for more information about the Children’s Online Privacy Protection Act (COPPA).

Information is gathered from your use of the CI Services by us, our service providers, advertisers, sponsors and partners.

Information You Provide. We may collect information that you choose to provide during use of the CI Services in a variety of ways, such as when you:

• purchase products or services from us. This information may include your name, address, telephone number,
• email address, and payment or credit card information;
• register for one of our services;
• make information available to us or interact with us via social media website and applications;
• express an interest in receiving marketing or promotional materials regarding cigars, pipe tobacco, or related products or services;
• participate in chats, web forums or other interactive sessions;
• subscribe to newsletters or provide feedback; and
• participate in surveys, sweepstakes, contests or other promotions.

Automated Information. Information regarding your use of the CI Services may be collected and/or aggregated by automated means. This automatically collected information may include information such as:

• User Activity. We or service providers collect information on how the Services are used, for example, the features you use, the links that you click on, your search parameters, data reflecting transactions that have taken place using the Services, how you interact with other users, performance statistics, and other usage data. We collect information that your browser sends whenever you visit our Services (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics.
• IP Addresses and Related Data. The servers used to operate and provide the Services may collect data pertaining to you and the equipment, software, and communication methods you use to access the Services, including, but not limited to, IP addresses assigned to the computers and other devices from which you access the Internet, your Internet service provider (ISP), device ID numbers and unique identifiers, your media access control (MAC) address, your operating system, your device’s screen resolution, your web browser type, the pages you access on the Services, the websites you access before and after visiting the Services, the length of time you spend on the Services, date and time stamps, clickstream data, your approximate geographic location, performance statistics, and other usage data.
• Email. We or our service providers collect information regarding emails you open and the links on which you click within an email.

When you use the CI sites, various technologies such as cookies, local shared objects, and web beacons (generally referred to as "Data Technologies"), are used to automatically collect information. "Cookies" are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. "Local shared objects," or “LSOs,” sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit. A "web beacon" (e.g. Internet tag, pixel tag or clear pixel GIF), links web pages to web servers and their cookies, and may be used to identify you and monitor your activity on the CI sites. Anonymous advertising identifiers are increasingly being used on mobile devices in a manner similar to cookies. When we refer to Data Technologies, we are including all current and similar future technologies.

One or more Data Technologies may be used on the CI sites and other websites and mobile applications (that may not be the CI sites) used by us, by another party on our behalf, or by third parties in accordance with their privacy policies. Data Technologies may be used by us and others, on our behalf and on their own behalf, to collect information about you that may be added to your user profile and used to connect information about you from different sources, websites, devices, and mobile applications. This information may be used to more effectively market our products and services, and those of our affiliates and third parties, that may be of interest to you.

We may use a trackable toll-free telephone number in advertisements. If you call one of these uniquely generated toll-free numbers, we (or a service provider acting on our behalf) may collect non-personally identifiable information about the call (e.g. date, time, duration), as well as personally identifiable information (e.g. your name, and the telephone number from which your call originated).

Videos. We may target and track the videos you view on the CI sites. You consent to our tracking of your video viewing through the CI sites or third-party social media for up to two years or as permitted by applicable law.

Location Information. We may use location information to provide location-based services and content, as well as to understand traffic patterns in and around our retail locations. You can adjust the setting on your device(s) to limit tracking or to decline cookies, but as a result you may not be able to use certain features of the CI sites or Content or take full advantage of all of our offerings.

Publicly Posted Information. Information that you make available to us and others via social media networks, forums, blogs, list serves, chat rooms or similar functionality is public information that we or others may share or use in accordance with the law.

Combined Information and Information from Other Sources. We may combine or cross-reference information that you provide to us, directly or indirectly, with information collected from or by other sources, including affiliates, service providers and third parties.

With Your Consent. With your consent, we may use and share your personal information and other collected information in ways not specifically described in this Privacy Policy. Where processing relies on such consent, you may withdraw consent at any time without affecting prior processing.

We may use information we collect for various business purposes including:

1. for everyday business purposes, such as establishing and managing your user account, for accounting and financial purposes such as processing and collecting payments, providing the products and services you request, responding to your queries, and providing customer support;
2. to offer you our products or services and/or the products or services of others;
3. to communicate about, and administer your participation in, special events, programs, surveys, sweepstakes, contests, and other offers or promotions;
4. to enable you to interact with CI and other users through various means, such as through message boards, blogs and social media;
5. to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications, and websites;
6. to diagnose and address technical and service problems;
7. to perform data analyses, including market and consumer research, trend analysis, demographic analysis, and financial analysis;
8. to deliver content (including advertising) correlating to your interests and browsing and usage history, both within the CI Sites and on other websites and applications;
9. to comply with applicable legal requirements and our policies; and
10. to contact you via telephone, email, mail, text, or chat. We will obtain your consent to contact you in the manner required by law.

We cannot change your personal information over the phone. You can change your personal information by logging into your password-protected account. If you would like assistance updating information we have about you or your preferences, please contact us by email

We may include applications or widgets from social media providers that allow interaction or content sharing by their users. These widgets, such as a Facebook "Share" or "Like" button, are visible to you on the web page you visit. Integration between the CI sites and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, and additionally to potentially share any or all of your information with us. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and the choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network. Any information we receive by these means will be treated and/or processed according to this Privacy Policy.

We may partner with advertising networks to deliver targeted advertising that is more relevant to you and your interests. Such targeted advertising is customized based on predictions generated over time from your online activity and visits across different websites, devices and mobile applications. Regardless of the different terms used for such advertisements (e.g., “online behavioral”, "interest-based" or “contextual” advertising), we will refer to these collectively as “targeted advertising” or “targeted advertisements” throughout this Privacy Policy.

Targeted advertising is customized by advertising networks based on information collected over time from your online activity not only here, but also across third-party websites, devices and mobile applications. For example, advertising networks might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the CI Services and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website. Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the CI Services and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet. We may also enable and implement Google Analytics advertising features on the CI Services.

We do not provide information that is directly associated with a specific person (such as name and address) to an advertising network. When you view or interact with a targeted advertisement, however, the advertising network may assume that you are interested in the advertisement and the information collected from that viewing or interaction may be associated with your personal information.

To change your preferences with respect to advertising networks and targeted advertising, you may set a Do Not Track preference in your Web browser. Your mobile device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for targeted advertising. For further information, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. o opt out of targeted advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out of targeted advertising will not affect your use of the CI Services.

As a reminder, changing your settings with individual web browsers or advertising networks may not necessarily carry over to other browsers or advertising networks. Even if you reject such technology, you may continue to receive advertisements, but they will not be tailored to your specific interests. As a result, depending on the opt-outs you request, you may still see our ads from time to time.

When you visit websites, they may store or retrieve data about you using cookies and similar technologies ("cookies"). Cookies may be necessary for the basic functionality of the website, as well as other purposes. You can set your device or browser to accept or reject most cookies, or at least notify you in most situations where the technology is offered. In addition, you may set a Do Not Track preference in your Web browser. Please note that if you reject cookies, it may impact your experience on the website, and you may continue to receive advertisements (but they will not be tailored to your specific interests).

The security of your personal information is important to us. We use commercially reasonable administrative, technical, personnel, and physical security measures designed to safeguard information about you in our possession against loss, theft and unauthorized use, disclosure, or modification. Of course, despite these measures, we cannot guarantee perfect security of networks, servers, and databases we operate or that are operated on our behalf. Please note that we will never email you asking for account information like your username, date of birth, credit card information, or other personal information. Finally, we will never email you with attachments that can be opened. If you received a suspicious email that appears to be from us, please contact us

Most personal information is stored in the United States. By providing us with any personal information, you understand, however, that your information may be transferred, processed, or stored outside the United States, in a country that has a different data protection regime. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.

We will retain your personal information for only as long as reasonably necessary and proportionate to provide services, fulfill purposes described in this notice, comply with legal obligations (such as preventing fraud, meeting regulatory requirements, or maintaining security), resolve disputes, enforce agreements and, in each case, as consistent with applicable law. Typical retention periods:

• Account and transactional records: up to 7 years after account closure or final transaction.
• Customer service records and warranty claims: up to 7 years after resolution.
• Marketing consent and preferences: until consent is withdrawn.
• Usage and analytics data: aggregated or pseudonymized where possible; retention periods vary by purpose.

We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.

We do not sell or otherwise share information about you that we collect or receive, except as described below:

1. Affiliates, Subsidiaries and Business Partners. We may share your information with our affiliates, subsidiaries and business partners in the U.S. and worldwide for the purposes described above and for other general business administration purposes. By visiting or using our Services or otherwise providing us with your information, you consent to this transfer of your information throughout our network of entities. To opt-out of such sharing, please see the “Contact for More Information” section below.
2. Our Service Providers. We may engage certain vendors to provide services, on our behalf, in connection with the CI Services (e.g., payment processing companies, data analytics, marketing and advertising providers, fraud prevention providers, cloud storage providers, IT service providers, and delivery partners). By written contract, we require such providers to maintain personal information about you as confidential and to use that information only for the specific business purpose of performing the services specified by us, and in a matter consistent with this Privacy Policy, and not to retain, use or disclose the information for any other purpose.
3. Cooperative Databases. We may share your personal information with cooperative databases. Such data cooperatives may combine or match the information we provide with information in their database. We and other cooperative members may then use this matched data to perform consumer research, analyze and improve our services, and send marketing communications to newly identified prospects. To opt-out of such sharing, please see the “Contact for More Information” section below or, if applicable in your state, please follow this hyperlink: online request form
4. Third Party Promotions or Co-Sponsored Promotions. In the event that you choose to participate in a survey, sweepstakes, contest or other promotion conducted by a third party, or that is co-sponsored by CI and a third party, you may be asked to disclose personal information to that third party. Once personal information is voluntarily disclosed by you in conjunction with such a third party or co-sponsored promotion, the subsequent use or disclosure of such information will be subject to a third party’s privacy policies and practices. Please note that any such third party or co-sponsored promotion will be conspicuously identified and, as such, your participation and disclosure of personal information is strictly voluntary.
5. Corporate and Asset Transactions. If we sell all or substantially all of our business or sell or transfer all or a material part of our assets, or are otherwise involved in a merger or transfer of all or a substantial part of our business, we may transfer all information we have collected and stored, including personal information, to the party or parties involved in the transaction as part of that transaction.
6. Other. We may access or disclose information, including personal information, to:
   1. protect or defend our interests and the legal rights or property of CI and our affiliates;
   2. protect the rights, interests, safety and security of users of the CI Services or members of the public;
   3. protect against fraud or for risk management purposes; or
   4. comply with applicable law or legal process, as well as prudent legal practice as we may determine.

You are entitled to make certain choices about how we communicate with you.

1. You may choose not to provide personal information, even though that may impact your ability to register or receive a particular product or service.
2. We use your email address to send order confirmations and invoices.
3. If you have elected to receive our weekly email specials by providing us with your email address, we will send you exclusive specials. You can opt out of receiving promotional emails from us, either by clicking on the “unsubscribe” link at the bottom of any email, or contacting by our customer service department.
4. If you do not want to receive interest-based advertisements, you can opt out as discussed in the "Advertising Networks" section above.
5. To exercise choices regarding cookies set through the use of our Services, as well as other types of online tracking and interest-based advertising, see our “Advertising Networks” section above.

This PRIVACY NOTICE supplements the information contained in the above Privacy Policy and applies solely to California residents who have business relationships with us ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"), the California Privacy Rights Act of 2020 (“CPRA”), the California “Shine the Light” law, and other California privacy laws. Any terms defined under California law shall have the same meaning when used in this PRIVACY NOTICE under “Your California Privacy Rights.” Please note, this section applies solely to California residents.

Under California’s “Shine the Light” law, if you are a California resident who provides personal information in obtaining products or services for personal use, you may choose to opt out of any sharing of that personal information with third parties by one of our brands or affiliates with whom you have provided that personal information. If you are a California resident and (1) you wish to opt out; or (2) you wish to request information concerning whether one of our brands or affiliates has disclosed any of your personal information to any third parties for direct marketing purposes, you may contact us as specified in the “Contact For More Information” section below.

We collect and retain the following categories of personal information and in some cases, sensitive personal information from consumers for the business purpose of complying with federal, state and local laws, and regulations governing our business, and to help us determine what products and services might be of greatest interest to you.

CI collects at least one item from each of the below categories of personal information identified in the California Consumer Privacy Act

1. Identifiers. Your real name, alias, date of birth, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, or other similar identifiers.
   
   
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, address, telephone number, driver's license or state identification card number, or other financial information. Some personal information included in this category may overlap with other categories.
   
   
3. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
   
   
4. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
   
   We obtain the categories of personal information listed above from the following categories of sources:
   
   
   • Directly from our customers or their agents. For example, from documents that our customers provide to us related to the products or services for which they engage us.
   • Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing products or services to them
   • Directly and indirectly from activity on the CI sites. For example, from submissions through our website portal or website usage details collected automatically.
   • From third parties that interact with us in connection with the services we or they perform.

We may disclose your personal information to our corporate affiliates and to third parties with whom we have joint marketing agreements for the purpose of offering complementary products and services. When we disclose personal information to our affiliates, service providers, and/or third parties, we do so under a contract that describes the business purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the services provided under the contract.
We may have disclosed or sold the following categories of personal information:

• Category A: Identifiers
  
  
• Category B: California Customer Records personal information categories
  
  
• Category C: Commercial Information
  
  
• Category D: Internet or other similar network activity
  
  

Accessing, Correcting, or Deleting Personal Information

If you are a California resident, upon our receipt of a verifiable request from you, you can obtain access to the personal information about you which we have in our files, or which we have used or shared with third parties. This section describes your CCPA and CPRA rights and explains how to exercise those rights.

Requests to Know and/or Correct

You have the right to request that we disclose certain information to you about our collection and use of your personal information, including: the categories and specific pieces of personal information we have collected about you. You also have a right to correct any such personal information you believe to be inaccurate.

Requests to Delete

You have the right to request that we delete any of your personal information that we have collected and retained, subject to certain exceptions in the CCPA/CPRA. Once we receive and confirm your verifiable consumer request, we will delete your requested personal information from our records, unless an exception applies, and we will direct our service providers to similarly delete your personal information from their records.

Exercising Your Request to Know, Correct or Delete Rights

In order to submit a verifiable consumer request to know what personal information we may have collected or shared, or to correct or request the deletion of any of your personal information, you may use one of these two Communication Methods:

• Use our online request form
• Call our toll-free number at 1-800-642-7191

Upon receipt of a request by one of the above methods concerning your personal information, we will attempt to verify your identity (or authority to make the request) by:

• requesting that you provide personally identifying information, including your first name, middle name, last name, email address, shipping address and telephone number
• requesting that you provide additional evidence proving your identity such as your unique customer identification number or details of a recent transaction.

You may make a verifiable consumer request up to two times within any 12-month period. We will not be able to respond to requests made more frequently than that.

Right to Non-Discrimination for the Exercise of Consumer’s Privacy Rights

You have a right not to receive discriminatory treatment from us for the exercise of any of your privacy rights conferred by the CCPA/CPRA.

Your Right to Opt-Out

As a California resident, you have the right to limit the personal information that we share with or sell to our affiliates or third parties. Please know that the CPRA definition of “sale” includes disclosure of personal information in exchange for anything of value, whereas the CPRA definition of “share” means disclosure of personal information for targeted advertising. You also have a right to limit the sensitive personal information that we may collect to that necessary to perform the service or to provide the goods that we offer for sale. To request that your personal information not be shared or sold, or to limit the sensitive personal information that we may collect, please follow this hyperlink: online request form. In addition, customers who are California residents may request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us at either our toll-free number or residents may request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us or call our toll-free number, 1-800-642-7191. Even if you opt out of the disclosures described in this section, we may still disclose information to affiliates and non-affiliated third parties as permitted by law.

Correcting Your Information

If you are a registered user of the CI sites, you may make changes or updates to certain information by logging into your password-protected account within the CI sites. Additionally, if you believe that information we maintain about you is inaccurate, subject to applicable law, you may request that we correct or amend the information by contacting us as indicated in the "Contact For More Information" section below.

Online Tracking Policy for California Residents

As of the effective date of this Privacy Policy, there is no commonly accepted response for Do Not Track signals initiated by browsers and, therefore, we do not respond to them.

Authorized Agent

As a California consumer, you can designate an authorized agent to make a request under the CCPA on your behalf. To do so, please write to us at the address provided below, providing your full name and address, the name and address of your authorized agent, the agent’s contact information, specify your relationship with the authorized agent, and the purpose for which you are designating the authorized agent. You may revoke the authority of that agent at any time by contacting us in writing at the address below.

Sensitive Personal Information

The CPRA provides the right to limit the collection of sensitive personal information. Please note, however, we do not collect “sensitive personal information” as defined under California law.

This section supplements this Privacy Policy and provides information about the privacy rights of Maryland residents under the Maryland Online Data Privacy Act ("MODPA"). Please note, this section applies solely to Maryland residents.

Subject to certain limitations, the MODPA affords you the following rights:

• To access and obtain a copy of your personal information.
• To request correction of your personal information.
• To request deletion of your personal information.
• To opt out of the sale of your personal information.
• To request restriction of or opt out of the processing of your personal information for specific purposes, including targeted advertising.
• To opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Exercising Certain Rights

To exercise these rights, please use our self-service online request form. To opt out of marketing communications, use the unsubscribe link in emails or contact us

Sale of Personal Information

Except as set forth in this Privacy Policy, we do not “sell” personal information as defined by the MODPA. “Sale of personal data” means the exchange of personal data to a third party for monetary or other valuable consideration. MODPA’s definition of “sale” contains several exceptions. Accordingly, we may share personal information to: service providers that process data on our behalf (e.g., cloud hosts, payment processors) pursuant to the terms of any agreement; an affiliate; partners and other third parties for the purpose of providing a product or service requested by the customer; and buyers or successors in a merger or sale (with notice). All such recipients are contractually required to protect data and limit use. Further, we may disclose personal information: the consumer intentionally made available to the general public via a channel of mass media; when required by law; and to protect rights/safety.

We may share your personal information with Cooperative Databases. Such sharing with Cooperative Databases arguably constitutes a sale under the MODPA. To opt-out, please use our self-service online request form.

Automated Decision-Making and Profiling

We do not make decisions about individuals solely by automated means that produce legal or similarly significant effects.

Where we use automated processing for personalization or recommendations, we allow you to opt out of targeted advertising. To opt out of targeted advertising, you may modify your cookie preferences at any time by accessing the "Cookie Settings" link available in the footer of the website.

Sensitive Personal Information

The MODPA provides a right to limit the collection of sensitive personal information. Please note, however, that we do not collect sensitive personal information as defined under the MODPA.

This section supplements this Privacy Policy and provides information about the privacy rights of Nebraska residents under the Nebraska Data Privacy Act ("NEDPA"). Please note, this section applies solely to Nebraska residents.

Subject to certain limitations, the NEDPA affords you the following rights:

• To confirm whether your personal data is being processed.
• To correct your personal data. 
• To delete your personal data.
• To access (obtain a copy of) your personal data.
• To opt out of the sale of your personal data.
• To opt out of the processing of your personal data for targeted advertising.
• To opt out of profiling in furtherance of a decision that produces a legal or similarly significant effect concerning the consumer. 

Exercising Certain Rights

To exercise your rights to correct, delete, access, or opt out of the sale of your personal data, use our self-service online request form or call our toll-free number, 1-800-642-7191.

Targeted Advertising

To opt out of targeted advertising, you may modify your cookie preferences at any time by accessing the "Cookie Settings" link available in the footer of the website.

Profiling

We do not engage in “profiling in furtherance of a decision that produces a legal or similarly significant effect concerning the consumer” as defined under the NEDPA. The NEDPA defines “profiling” to mean “any form of solely automated processing performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.” Further, the NEDPA defines a “Decision that produces legal or similarly significant effect concerning a consumer” to mean “a decision made by the controller that results in the provision or denial by the controller of financial and lending services, housing, insurance or health care services, education enrollment, employment opportunities, criminal justice, or access to basic necessities, such as food and water. “

Sensitive Data

The NEDPA requires a consumer’s consent to process sensitive data. Please note, however, that we do not process sensitive data as defined under the NEDPA.

This section supplements this Privacy Policy and provides information about the privacy rights of New Jersey residents under the NJ Data Privacy Act ("NJDPA"). Please note, this section applies solely to New Jersey residents.

Subject to certain limitations, the NJDPA affords you the following rights:

• To confirm whether your personal data is being processed and accessed.
• To correct your personal data.
• To delete your personal data.
• To access (obtain a copy of) your personal data.
• To opt out of the sale of your personal data.
• To opt out of the processing of your personal data for targeted advertising.
• To opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. 

Exercising Certain Rights

To exercise your rights to correct, delete, access, or opt out of the sale of your personal data, please use our self-service online request form.

Targeted Advertising

To opt out of targeted advertising, you may modify your cookie preferences at any time by accessing the "Cookie Settings" link available in the footer of the website.

Profiling

We do not engage in “profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer” as defined under the NJDPA. The NJDPA defines “profiling” to mean “any form of automated processing performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.” Further, the NJDPA defines “decisions that produce legal or similarly significant effects concerning the consumer” to mean “decisions that result in the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health care services, or access to essential goods and services.”

Sensitive Data

The NJDPA provides a right to limit the processing of sensitive data. Please note, however, that we do not process sensitive data as defined under the NJDPA.