CALIFORNIA & TEXAS PRIVACY NOTICE

This Privacy Notice applies to any California and Texas residents about whom we collect Personal Information (“Consumers”). The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act (“CCPA”) and the Texas Data Privacy and Security Act (“TDPSA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.

The CCPA and TDPSA provide residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access, delete, and restrict the sale of certain personal information we collect about them. Residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA and TDPSA. If you are a California or Texas resident, you may submit a request to exercise these rights by completing our online webform or by emailing us using the information provided in the "Your Privacy Rights" section below.

If you are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access this California Privacy Notice by emailing us using the contact information below.

Privacy Policy & Terms of Service for more information about our information collection, use, and sharing practices and other terms of service.

Personal Information We Collect

For the purposes of this Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information covered by certain sector-specific privacy laws.

ZFT collects personal information provided by consumers through the Sites. Over the last twelve (12) months, we have collected the following categories of personal information from consumers:

• Identifiers, including your first and last name; billing and shipping address; email address; phone number; account information and password; online identifiers as detailed below including IP address or device IDs; and/or other similar identifiers.
• Payment and financial information, including your credit or debit card number and related payment card information; bank account and routing number; and/or other financial information.
• Commercial information, which includes our Services that you have purchased, obtained, or considered; and/or other purchasing or consumer histories, tendencies, and preferences.
• Information relating to Internet activity or other electronic network activity, which includes the information disclosed in Section 1(b) of our Privacy Policy.
• Geolocation data, which includes Global Positioning System (“GPS”) data based on your IP address.
• Information not listed above and related to characteristics protected under California, Texas or federal law, which may include gender or gender identity; race or ethnicity; religion; sexual orientation; marital status; national origin; and/or disabilities.
• Inferences based on the above information.

b. What We Do With Your Personal Information

ZFT may collect, use, or disclose personal information about you for the purposes detailed in Section 2 of our Privacy Policy.

c. Sources of Collected Personal Information

We may collect personal information from the following categories of sources:

• From you, including via our Sites, in person, telephone, postal mail, and/or social media
• From our brands and affiliates
• Through our service providers, such as non-affiliated companies who help us provide Products and Services to you
• From our business partners and others, including those that may promote and/or offer products and services that may be of interest to you

We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers.

Who We Share Personal Information With

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes.

We do not sell your personal information to third parties, including personal information of minors under 16 years of age. However, as with nearly every e-commerce company, we do share a limited set of data that is gathered when you visit our Site, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. To the extent this activity is interpreted as included in California’s broad definition of “data sale,” we have provided you with opt-out rights as to that activity as described in subsections (e) and (f) below.

Your Privacy Rights

California and Texas residents have the following rights under applicable law in relation to your personal information, subject to certain exceptions:

• Right to Know. You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, as applicable.
• Right to Delete. You have the right to request under certain circumstances the deletion of your personal information that is collected by us.
• Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information by a business. However, as noted in subsection (d) above, we do not currently sell any personal information. We do participate in behavioral ad networks, and to the extent participation in such networks is deemed to be a data sale under the CCPA, we have provided instructions on how you can opt-out in subsection (f) below.
• Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

How to submit a request. You may exercise any of the rights described in this section by using the designated links at the end of this Notice, or by emailing us at sales@zerofoxtrot.com.

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA and TDPSA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. In order to verify you, you must provide us with your first and last name and email address. These rights are also subject to various exclusions and exceptions under applicable laws.

You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to sales@zerofoxtrot.com.

We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.

Direct marketing by third parties. We do not personal information to third parties for their own purposes, and we permit you to opt-out of any disclosures of non-identifiable personal information. However, because California residents have the right to request information regarding such practices under California’s “Shine the Light” Law, please contact us using the information provided at the end of this Policy. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond. “Personal information” under this California law means any information that identified, described, or was able to be associated with an individual at the time of disclosure.

We will continue to update our business practices as direct regulatory guidance becomes available. For more information on interest-based advertising, please visit our Privacy Policy and Cookie Policy.

Notice of Right to Opt-Out

As noted in Sections D and E above, we do not currently sell any personal information. We do, however, participate in behavioral advertising networks. To the extent participation in such networks is deemed to be a data sale under the CCPA, we encourage you to visit the Network Advertising Initiative and/or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements.

How to Contact Us

If you would have any questions or want more information, contact our Privacy Compliance Officer at sales@zerofoxtrot.com or by mail at

ZFT OPCO LLC
[Re: Privacy Compliance Officer]
2113 Wells Branch Parkway Suite 3100 Austin Texas US 78728

Data Portability

You can use the links below to download all the data we store and use for a better experience in our store.

• CCPA and TDPSA requests
• Personal information
• Orders

Access to Personal Data

You can use the link below to request a report which will contain all personal information that we store for you.

• Request a report

Right to delete

Use this option if you want to remove your personal and other data from our store. Keep in mind that this process will delete your account, so you will no longer be able to access or use it anymore.

• Request personal data deletion