Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in EFE, Inc.'s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We have adopted this notice to comply with the California Consumer Privacy Act of 2018, as may be amended from time to time ("CCPA"), including the California Privacy Rights Act ("CPRA"), and any terms defined in the CCPA or CPRA have the same meaning when used in the Privacy Notice. Further, as used in the Privacy Notice, except as may be otherwise provided herein, all capitalized terms which are defined in the Privacy Policy shall have the same meaning herein as therein, all of such terms and their definitions being incorporated herein by reference.

Information We Collect

We collect 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"). 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, or other qualifying research 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;
  • protection of trade secrets;
  • protection of free speech and press rights for noncommercial activities protected by California's Constitution;
  • exemption of certain commercial credit reporting agency actions from the deletion and opt-out rights;
  • exemption of household data from the business's right to know, deletion, and correction response obligations;
  • exemption of student grades, educational scores, or educational test results held for a local educational agency from the deletion right;
  • exemption of educational standardized assessments, including specific responses, from the right to know's disclosure requirements when disclosure could jeopardize its validity or reliability; and
  • exemption of physical items containing personal information from the deletion and opt-out rights, such as the consumer's photograph, if the consumer previously consented to the item's creation and other circumstances apply.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

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

• Directly from you. For example, from forms you complete, such as the "Contact Us" form on the Site, or other communications with us.
• Indirectly from you. For example, from observing your actions on our Site.

Use of Personal Information

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

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about the Site or our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, 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 Site, 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 Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, 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 Site, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
• 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/consumers 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.

Automated Decision-Making and Profiling

We do not use automated decision-making (where an electronic system uses personal information to make a decision about you without human intervention), but we do use Profiling. We do not consider that the use of profiling has any legal effect on you or significantly affects you.

You have the right to object to our use of profiling described in this section. You can do that by opting out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (such as the IP address assigned to you by your Internet Service Provider) when you visit our Site, you can use a virtual private network (VPN).

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyze or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Use of Profiling for Web Analytics

Our web analytics services, such as Google Analytics, collect information such as your location (based on your IP address) and your behavior (based on cookies) when you access our Site (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer.

By automatically analyzing and categorizing information such as the location (based on IP address) as well as the behavior and devices of visitors to our Site (using cookies), we are able to gain a better understanding of what our Site visitors require (in terms of the content of our Site and our products and services), how to improve our Site and how to advertise and market our products and services to them.

Cookies will be used to track and store information about your behavior and device on our Site (unless you have opted out from receiving such cookies by rejecting cookies) and your location will be analyzed based on your IP address. We have a legitimate interest in processing this information for the purpose of improving our Site for our Site users and getting to know our Site user's preferences so our Site can better meet their needs and desires.

Selling and/or Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose as defined under California Civil Code § 1798.140(e). We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, we have not sold personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Retention of Personal Information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention Periods

Correspondence and enquiries: when you make an enquiry, or correspond with us for any reason, whether by email, via mail or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and at such time we will delete your information.

E-Newsletter: we retain the personal information you provided to sign up for our e-newsletter (including your email address, name, and any other optional information you submitted) for as long as you remain subscribed (i.e., you do not unsubscribe), or until we discontinue our e-newsletter service, whichever occurs first. Upon unsubscription or service discontinuation, we will securely delete your personal information within a commercially reasonable time period, except where we are required to retain it to comply with legal obligations or legitimate business purposes.

Criteria for determining retention periods:

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long the information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how difficult it may be to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

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.

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 twelve (12) months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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.
• 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.
• The specific pieces of personal information we collected about you (also called a data portability request).

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 (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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:

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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. seq.).
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.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

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 [email protected].

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

While we do not permit users of the Site to be under the age of 18, you may also make a request to know or delete or correct on behalf of your child by sending an email to [email protected].

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, which may include the disclosure of identifying information.
• 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.

For instructions on exercising your sale opt-out or opt-in rights, see "Personal Information Sales Opt-Out and Opt-In Rights".

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 [email protected].

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 forty-five (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 twelve (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.

Personal Information Sales Opt-Out and Opt-In Rights

Under California law, consumers have the right to direct us to not sell or share their personal information at any time (the "right to opt-out"). We do not sell or share personal information of consumers whom we have actual knowledge are less than sixteen (16) years of age, and such consumers must affirmatively authorize ("opt-in") the sale or sharing of their personal information before any such sale or sharing occurs. Consumers who opt-in to personal information sales or sharing may opt-out of future sales or sharing at any time by visiting our "Do Not Sell or Share My Personal Information" webpage or by contacting us through the methods described in this policy.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing. We will process your opt-out request within fifteen (15) business days of receipt.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request. You can ask us or third-parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific third-party website to unsubscribe and/or opt-out in accordance with the terms and conditions of such third-party website.

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.

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.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Changes to Our Privacy Notice

We may amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice's effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

California consumers will also have the right to:

• Correct inaccurate personal information.
• Opt-out of sharing personal information for cross-context behavioral advertising purposes.
• Restrict sensitive personal information use and disclosure.

Contact Information

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

• Email: [email protected]
• Mail: 138 Professional Way, Wellington, Florida 33414

If you need to access this Policy in an alternative format due to having a disability, please contact [email protected].