California Privacy Notice

This California Privacy Notice (the “CA Disclosures”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you“).

These CA Disclosures describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018, as amended (“CCPA”).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined the CCPA.

For the purposes of these CA Disclosures, “personal information” has the meaning provided by the CCPA and does not include:

• Information that is publicly available.

• Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

• Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

• Information relating to our employees, contractors and other personnel.

1. COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information from and about you for a variety of purposes. For example, we use personal information:

• To fulfill your requests, process your transactions and provide our Services to you

• To communicate with you

• For marketing and advertising purposes

• To monitor, improve, and develop our products and Services

• To protect the security and integrity of our business, comply with legal requirements and obligations, and as otherwise permitted or required by law.

To learn more about the types of personal information we collect and the purposes for which we use this information, please refer to the What Information Do We Collect and For What Purpose section of our Privacy Notice.

In the last 12 months, we have collected the following categories of personal information:

In the last 12 months, the “sensitive personal information” (as defined by the CCPA) we have collected may include: your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, information about your racial or ethnic origin, information about your citizenship or immigration status, and health information. Fairfield does not use or disclose sensitive personal information for any purpose other than for performing services you have requested, for detecting security incidents, fraud and other illegal actions, to ensure the physical safety of natural persons, to perform services on behalf of the business (where the sensitive information is reasonably necessary and proportionate for this purpose), or for short term transient use. Fairfield only collects and processes sensitive personal information without the purpose of inferring characteristics about a consumer.

We collect the information described above from a variety of sources, including: directly from you, from your employer or organization, from our customers and other users, from our business partners and affiliates, from your browser or device when you use our Services, or from third parties that you permit to share information with us. Please see the What Information Do We Collect and For What Purpose section of the Privacy Notice for more information about the sources of personal information we collect.

2. DISCLOSURE OF PERSONAL INFORMATION

As described in the How Do We Share Your Information section of our Privacy Notice, we share each of the categories of personal information described above with third parties and service providers for our business purposes.

3. YOUR CALIFORNIA CONSUMER RIGHTS

As a California resident, you may be able to exercise the following rights (“California Consumer Rights”):

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;

  • The categories of personal information we have collected about you;

  • The categories of sources of the personal information;

  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

  • The categories of personal information we have sold or shared about you (if any) and the categories of third parties to whom the information was sold; and

  • The business or commercial purposes for collecting or selling the personal information.

• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.

• The Right to Correction of any inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

• The Right to Opt Out of Sales of Personal or Sharing of Personal Information for Targeted Advertising. You have the right to direct us not to sell personal information or share personal information for targeted advertising. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales or sharing.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

To Submit Your California Consumer Rights Requests

You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To exercise your California Consumer Rights, please submit a request by:

• Filling out our Consumer Rights Request Form, or

• Calling (833)-437-3254

To Exercise Your Right to Opt Out of Personal Information Sales or Sharing for Targeted Advertising

As is common practice among companies that operate online, we do allow certain third party advertising networks, social media companies and other third party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services. These third parties use this personal information to serve relevant ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks. To learn more, please see Third-Party Tracking and Online Advertising section of our Privacy Notice.

By visiting here, you can opt out from sales of this type of personal information by businesses that participate in the opt-out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at https://www.privacyrights.info/.

To exercise the Right to Opt-Out of personal information sharing or selling for targeted advertising purposes, you may also submit a request by clicking on the following link:

DO NOT SELL OR SHARE MY PERSONAL INFORMATION

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these CA Disclosures where we can verify the authorized agent’s authority to act on your behalf.

For requests to know, delete, or correct personal information, we require the following for verification purposes:

• (a) a power of attorney valid under the laws of California from you or your authorized agent; or

• (b) sufficient evidence to show that you have:

  1. provided the authorized agent signed permission to act on your behalf; and

  2. verified your own identity directly with us pursuant to the instructions set forth in these CA Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of personal information “sales” or “sharing”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Minors. We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

California’s “Shine the Light” Law. California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please fill out our Consumer Rights Request Form.

Updates to These CA Disclosures. We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the bottom of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Last Updated: January 1, 2023