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IMPORTANT PRIVACY NOTICE FOR CALIFORNIA CONSUMERS

LAST REVISED: August 5, 2021

This Privacy Notice for California Consumers (“Notice”), provided by adQuadrant, Inc. (“adQuadrant,” “Company,” “we,” or “our”), supplements, and is expressly made part of, the information contained in Topgiveaways.com’s Online Privacy Policy and applies solely to those who are consumers (“you” or “your”) as defined in Section 1798.140(g) of the California Consumer Privacy Act of 2018 (“CCPA”). We adopt this Notice in compliance with the CCPA and any terms defined in the CCPA have the same meaning when used in this Notice.

adQuadrant collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). As a consumer, you have certain rights regarding your personal information as defined in the CCPA. This Notice provides you with information on how adQuadrant collects, uses, and shares personal information. It also outlines the rights you have regarding personal information that we collect from you and describes how you can exercise those rights.

Collection and Use of Personal Information

adQuadrant recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, adQuadrant has collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include publicly available information from government records, information relating to our job applicants, employees, contractors or other personal, de-identified or aggregated consumer information, or information otherwise excluded from the CCPA’s scope, such as information collected pursuant to the GLBA.

We have obtained the categories of personal information listed above from the following categories of sources:

- Directly from you. For example, from forms you complete or products and services you purchase
- Indirectly from you. For example, from information we obtain in the course of providing our services to you, or from observing your actions on our website.
- From third-party business partners such as social media sites, ad networks, and analytics providers.

adQuadrant may use this information to:

- Provide you with the information, products, or services you request from us.
- Fulfill the reason you provided the information, such as to respond to customer service requests or other inquiries.
- Create, maintain, customize, and secure your account with us.
- Personalize your website experience and deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent where required by law)
- Help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- Process your requests, purchases, transactions, and payments
- Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
- Prevent transactional fraud.
- Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.

adQuadrant will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing notice to you. Such notice may be delivered, for example, by posting an updated California Privacy Notice.

Sharing Personal Information

adQuadrant may disclose your personal information to a third party for business purposes. When we do so, adQuadrant enters into a contractual arrangement that describes the business purpose and requires the recipient to both: (A) keep that personal information confidential; and (B) not use it for any purpose except performing the obligations under the contract.

We share your personal information with the following categories of third parties for a business purpose:

- Service providers.

- Data aggregators and analytic providers

- Internet cookie data recipients (e.g., Google analytics)

In the preceding twelve (12) months, adQuadrant has disclosed the following categories of personal information to the third parties listed above for a business purpose:

- Category A: Identifiers.

- Category B: California Customer Records personal information categories.

- Category F: Internet or other similar network activity.

- Category G: Geolocation data.

If we have collected or received your data in connection with a financial product or service, you may have additional rights regarding this sharing which are described below.

Sale of Personal Information.

The CCPA similarly requires adQuadrant to provide you with a statement on the sale of personal information. In the preceding twelve (12) months, adQuadrant has not sold personal information.

Notice Regarding Your Rights

Access & Data Portability Rights

You have the right to request that adQuadrant disclose what personal information we collect, use, and disclose. If we receive and confirm your consumer request as verifiable and no exception applies, we will provide you with:

- The categories of personal information we collected about you.

- The categories of sources for the personal information we collected about you.

- Our business or commercial purpose for collecting that personal information.

- The categories of third parties with whom we share that personal information.

- The specific pieces of personal information we collected about you.

- If we sold or disclosed your personal information for a business purpose, two lists disclosing:

- Sales, identifying the personal information categories that each category of recipient purchased; and

- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable, unless an exception applies we will delete (and direct our service providers to delete) your personal information from our records.

The CCPA provides a number a reasons why a deletion request may be denied. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Opt-Out Rights

Financial Information

If we have collected financial information from you, then you have the right to restrict the sharing of personal financial information with our affiliates (companies we own or control, or that own or control us) and outside companies that we do business with. Such rights do not prohibit the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.

You can choose to:

Restrict Information Sharing With Companies We Own or Control, or That Own or Control Us (Affiliates): Unless you direct us not to, we may share personal and financial information about you with our affiliates (and those affiliates may use the information to market to you).
Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products and Services: Unless you direct us not to, we may share personal and financial information about you with outside companies we contract with to provide financial products and services to you.

Please email us at privacy@topgiveaways.com if you wish to exercise either one of the options above.

If we collect information from you that is not related to a financial product or service, you have the right to request that adQuadrant does not sell that personal information as defined by the CCPA. To exercise that right, please click here: Do Not Sell My Personal Information (www.topgiveaways.com/CCPA-do-not-sell-request) or writing to us at 120 Tustin Ave., Suite C1056, Newport Beach, CA 92663.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to adQuadrant by:

Writing to us at 120 Tustin Ave., Suite C1056, Newport Beach, CA 92663.
Via email at privacy@topgiveaways.com (please include “California Privacy Request” in the subject line).

Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must:

Provide sufficient information that allows adQuadrant to verify, to a reasonable degree of certainty, that you are the person about whom adQuadrant collected personal information (or your authorized representative), which may include multi-factor authentication of identifying information provided by you. Such authentication may be conducted and verified independently or in combination with a comparison of personal information already maintained by adQuadrant, if any; and
Describe your request with sufficient detail that allows adQuadrant to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.t must:

Making a verifiable consumer request does not require you to create an account with us, but we must also be able to confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

adQuadrant endeavors to respond to a verifiable consumer request within forty-five (45) days of receiving it. If adQuadrant requires additional time to process your request, up to a maximum total of ninety (90) days from the date the request is received, we will notify you of this and inform you of the reason for requiring the additional time.

If you have an online account with us, we will deliver our written response to your online account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request or have denied a request, if applicable.

We do not charge a fee 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.

Non-Discrimination

adQuadrant will not discriminate against you for exercising any of your CCPA rights as described above. Unless permitted by the CCPA, adQuadrant will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Do Not Track Disclosures

How do we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services?

We currently do not respond to DNT signals in browsers.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit www.Topgiveaways.com?

No.

Other California Privacy Rights

California’s "Shine the Light" law (Civil Code Section § 1798.83) permits certain individuals that are California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at privacy@topgiveaways.com or write to us at:

adQuadrant

120 Tustin Ave.

Suite C1056

Newport Beach, CA 92663

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

adQuadrant is committed to responding promptly to any questions or concerns you may have about this Notice. If you have questions concerning the methods by which adQuadrant collects or uses your personal information as explained in this Notice and our Online Privacy Policy, the rights granted to you under the law, or how to exercise your rights; or if you are a consumer with a disability and you wish to receive a copy of this Notice, we can be reached by postal mail at 120 Tustin Ave., Suite C1056, Newport Beach, CA 92663, or by phone at 469-485-7814. You can email us at privacy@topgiveaways.com with questions, comments or suggestions.

Please print and retain a copy of this California Privacy Notice for your records.