California Consumer Privacy Act Supplement

This California Consumer Privacy Act Supplement (this "Supplement") covers the requirements of the California Consumer Privacy Act and its implementing regulations ("CCPA"). The CCPA only applies to information about residents of California. If you are not a resident of California, you may submit a request and we will process it, as described in this Supplement, even though the CCPA does not require us to do so. In accepting, processing, and responding to requests by individuals who are not California residents, we will apply all of the same limitations and exceptions under the CCPA to those requests as apply to requests made by California residents. We reserve the right to change or stop the practice of accepting requests from individuals who are not California residents at any time and without prior notice, unless you are otherwise entitled to submit such a request pursuant to another privacy law applicable to our relationship with you.

This Supplement describes how we collect, use and share Personal Information (PI) of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, "Personal Information" has the meaning given in the CCPA.

The categories of PI under the CCPA include (Ventures may not collect all categories of information):

• Identifiers
• Personal information as defined in the California Customer Records Statute
• Characteristics of protected classifications under California or federal law
• Commercial information
• Biometric information
• Internet or other electronic network activity information
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information
• Professional or employment-related information
• Education information
• Inferences drawn from personal information to create a profile about a consumer

This Supplement contains disclosures required by CCPA and applies only to “Personal Information” that is subject to the CCPA. Much of the Personal Information that Ventures collects is exempt from the CCPA because it is protected under other federal and/or state privacy laws. For example:

• Publicly available information from government records;
• Deidentified or aggregated consumer information;
• Health or medical information covered by the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; and
• personal 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.

YOUR CALIFORNIA PRIVACY RIGHTS.

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. Privacy and data protection laws, other than the CCPA, apply to much of the Personal Information that we collect, use, and disclose. When these laws apply, Personal Information may be exempt from, or outside the scope of, Access Requests and Deletion Requests. As a result, in some instances, we may decline all or part of an Access Request or Deletion Request related to this Personal Information. This means that we may not provide some or all of this Personal Information when you make an Access Request. Also, we may not delete some or all of this Personal Information when you make a Deletion Request. If we deny your request, we will provide you with the basis for such decision.

Your rights are:

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you. 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 your Personal Information from our records, unless an exception applies. 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, 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.
• Correction. You may request that we correct inaccurate or incomplete personal information about you;
• Opt-Out of Sale of Personal Information. Opt-Out of Sale of Personal Information. Under the CCPA, you have the right to opt-out of the sale of your Personal Information to third-parties. While Ventures does not sell Personal Information to third parties, Ventures does share data related to cookies and similar technologies with third parties for behavioral advertising. The CCPA excludes from the definition of “sale” the situation where a “consumer uses or directs the business to intentionally disclose Personal Information.” You may exercise your right to opt-out of the sale of your Personal Information by using the toggle switch in the Cookie Preference Manager. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your Personal Information covered by that law with third parties for their direct marketing purposes.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

HOW TO EXERCISE YOUR RIGHTS

You may exercise your California privacy rights described above as follows:

• Right to information, access, correction and deletion. You can request to exercise your information, access and deletion rights by emailing at info@vspventures.com.
• Right to opt-out of the sale of Personal Information. You may exercise your right to opt-out of the sale of your Personal Information by using the toggle switch in the Cookie Preference Manager.

VERIFIABLE REQUEST

We will need to confirm your identity to process your requests to exercise your information, access, correction or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us 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 the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For California residents only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

PERSONAL INFORMATION THAT WE COLLECT, USE AND SHARE

The chart below summarizes how we collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above.

As the term is defined by the CCPA, we may "sell" the following categories of Personal Information in the last 12 months: cookie and tracking technologies. We "sold" each category to advertising networks, data analytics providers, and social networks. The business or commercial purposes of "selling" Personal Information is for third-party companies to perform services on our behalf, such as marketing, advertising, and audience measurement.

We do not "sell" Personal Information of known minors under 16 years of age.