Keenwawa’s Privacy Policy

Right to Know and Data Portability

You have the right to request that We disclose certain information to You about Our collection and use of Your Personal Information over the past 12 months. Once We receive Your request and confirm Your identity, We will disclose to You, as applicable:

• 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;

• If We sold or disclosed Your Personal Information for a business purpose, two separate 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; and/or

• The specific pieces of Personal Information We collected about You (also called a data portability request).

We do not provide a right to know or data portability disclosure for business-to-business Personal Information.

Right to Delete

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 Your request and confirm Your identity, We will review Your request to see if an exception allowing Us to retain the information 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, 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; and/or

• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

We will delete or de-identify Personal Information not subject to one of these exceptions from Our records and will direct Our service providers to take similar action.

We do not provide these deletion rights for business-to-business Personal Information.

Exercising Your Rights to Know or Delete

To exercise Your rights to know or delete described above, please submit a request by emailing Us at legal@brightloom.com. Only You, or someone legally authorized to act on Your behalf, may make a request to know or delete related to Your Personal Information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete 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.

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

Response Timing and Format

We will confirm receipt of Your request within ten (10) business days. If You do not receive confirmation within the 10-day timeframe, please contact marketing@brightloom.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to another 45 days), We will inform You of the reason and extension period in writing.

If You have an account with Us, We may deliver Our written response to that 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 Our receipt of Your request. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your Personal Information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

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

We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, We 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; or

• Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, We may offer You certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to Your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires Your prior opt-in consent, which You may revoke at any time.