PRIVACY STATEMENT-CALIFORNIA

Revised: 3.16.2022

This CALIFORNIA PRIVACY STATEMENT supplements the information contained in the Privacy Statement of Web-Est, LLC ("Web-Est") (collectively, "we," "us," or "our") and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

The law requires us to tell you about the personal information we collect about you in a certain way – specifically, we need to tie it back to "legal categories" of personal information that are listed in the law. To do this, we bundled up the information we gave you above in this Privacy Notice and matched the different types of personal information we collect about you with the legal category. To make things easier to understand, we've put this information in a chart that shows you four things about the personal information we have collected in the past 12 months:

1. The legal category of personal information,
2. Examples of the types of personal information included in each legal category,
3. The purpose for why we collect and use your personal information for each legal category; and
4. The business purposes for which we share your personal information and with whom. We've included these things in the California Privacy Chart. For a more detailed description of the purposes of use and sharing with third parties included in the California Privacy Chart, please see the "Sharing Personal Information" section below.

California Privacy Chart

Category	Examples	Collected	Purpose	Source	Sharing with Third Parties for a Business Purpose+
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES	Provide content Respond to Requests Website development Account Purchases Customer support Personalize experience Website security Debugging Services Analysis Auditing Quality Control Short-Term Legal Requests	Directly from you From your devices From third parties	Affiliates Behavioral Advertising Service Providers Other Third Parties
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES	Provide content Respond to Requests Website development Account Purchases Customer support Personalize experience Website security Debugging Services Analysis Auditing Quality Control Short-Term Legal Requests	Directly from you From third parties	Affiliates Behavioral Advertising Service Providers Other Third Parties
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES	Provide content Respond to Requests Website development Account Purchases Customer support Personalize experience Services Analysis Auditing Quality Control Short-Term Legal Requests	Directly from you	Affiliates Behavioral Advertising Service Providers Other Third Parties
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	Provide content Respond to Requests Account Purchases Customer support Personalize experience Services Analysis Auditing Quality Control Short-Term Legal Requests	From your devices From third parties	Affiliates Behavioral Advertising Service Providers Other Third Parties
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	Not collected	Not collected	Not collected
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES	Provide content Website development Personalize experience Website security Debugging Services Analysis Auditing Quality Control Short-Term	From your devices From third parties Online advertising agencies and providers	Affiliates Behavioral Advertising Service Providers Other Third Parties
G. Geolocation data.	Physical location or movements.	NO	Not collected	Not collected	Not collected
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO	Not collected	Not collected	Not collected
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES	Respond to Requests Personalize experience Services Analysis Auditing Legal Requests	Directly from you From third parties	Affiliates Behavioral Advertising Service Providers Other Third Parties
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO	Not collected	Not collected	Not collected
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO	Not collected	Not collected	Not collected

 

Personal information does not include:

• Publicly available information from government records
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • 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;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• From your devices/indirectly from you. For example, from observing your actions on our Website.
• From third parties, such as online advertising agencies and providers. For example, when our ad network partners use cookies and web beacons to collect information about your internet activities.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To provide you with content, including our Website and services.
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to contract for our products or services, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to 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).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business. This includes detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• To provide you with services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, and providing analytic services.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. This includes undertaking internal research for technological development and demonstration.
• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Undertaking activities to verify or maintain the quality or safety of the services we provide, and to improve, upgrade, or enhance the services.
• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer's experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
• To 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.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Affiliates:We may share your personal information with our affiliates, subsidiaries, and related entities if we need to, in order to maintain our business and provide products and services to you. If we share your information, we will share only the information that is necessary and we will take reasonable steps to make sure that third parties take prudent steps to protect your information.

Service Providers: We may provide your personal information to companies that provide services to help us with our business activities, such as customer service. These companies are authorized to use your personal information only as necessary to provide these services to us. These service providers may include internet service providers and operating systems and platforms, and may also include companies providing you behavioral advertising on our behalf.

Other Third Parties: We will disclose your personal information to other third parties upon your request.

In addition to the third parties identified above, during the 12-month period prior to the effective date of this notice, the Company may have shared personal information for the following reasons:

Compliance with Legal Obligations: In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Changes in Business Structure or Ownership: We reserve the right to transfer your personal information in the event Web-Est is involved in a merger, acquisition, or sale of all or a portion of its business or assets.

In the preceding twelve (12) months, we have not sold any personal information to anyone or shared your personal information with third parties for those parties' commercial use. We do not knowingly collect, sell, or share for commercial purposes any personal information of minors under 18.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

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 and confirm your verifiable consumer request, we will disclose to you:

• 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 or selling 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 (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list of disclosures made for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

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 (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to 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 providers to:

1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Opt Out of Sale: You may have the right to ask us not to sell your personal information. We do not sell your personal information, but if you wish to make a request, we are happy to confirm that we do not sell your personal information.

Exercising Access, Data Portability, Deletion Rights

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

• Calling us at 800-698-6246
• Emailing us at info@web-est.com

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. We are only required to honor your verifiable request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information to allow us to evaluate and honor your request, including your name, business name, and business city and state.
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, including your name, business name, and customer ID or account number.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent's identity and contact information to us.

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. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

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

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will 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 the verifiable consumer request's receipt. 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (888) 932-3780
Website: www.web-est.com
Email: info@web-est.com
Postal Address: 12884 S Frontrunner Blvd, Ste 220 Draper, UT 84020