Beginning January 1, 2025, we may be subject to the Delaware Personal Data Privacy Act based on our interactions with Delaware residents and our use of their Personal Data.  This law provides Delaware residents enhanced rights with respect to their Personal Data when they are not acting solely in a commercial or employment context (such as a B2B communication) when interacting with us.  If you are an employee or job applicant or are interacting with us in a commercial or employment capacity, these disclosures are unlikely to apply to you.

In this section, “DPDPA Personal Data” refers to Personal Data that is linked or reasonably linkable to an identified or identifiable Delaware resident.  DPDPA Personal Data does not include de-identified or publicly available information, as defined in the Delaware Personal Data Privacy Act, protected health information regulated by HIPAA, and certain other exceptions spelled out in the law.  We do not collect DPDPA Personal Data about individuals we know to be under the age of 13.

First, a Delaware resident may have the right to confirm whether we are processing DPDPA Personal Data concerning them and to access their DPDPA Personal Data.

Second, a Delaware resident may have the right to correct inaccuracies in their DPDPA Personal Data we hold.

Third, a Delaware resident may have the right to request we delete DPDPA Personal Data concerning them.

Fourth, a Delaware resident may also request to receive their DPDPA Personal Data in a portable and, if technically feasible, readily usable format.

Fifth, a Delaware resident may have the right to request a list of the categories of third parties to which we have disclosed their DPDPA Personal Data.

Sixth, a Delaware resident may opt out of processing their DPDPA Personal Data for purposes of targeted advertising, the sale of their DPDPA Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Delaware resident. 

To exercise your rights, please email us using the information in the Contact Us section.  If you email us, please put in the subject line of your email the right you are seeking to invoke:  “Delaware Right to Access,” “Delaware Right to Correct,” “Delaware Right to Delete,” “Delaware Right to Portability,” “Delaware Right to Third-Party Categories,” and “Delaware Right to Opt Out.”

You may submit multiple requests at once through an email.  Subject to certain exceptions, ordinarily there is no cost for submitting your first request; if you submit multiple requests in a twelve-month period, we may charge you a reasonable fee to cover the administrative costs of complying with your requests or decline to act on your requests.  For requests other than a Right to Opt Out, we are permitted to use commercially reasonable efforts to authenticate you are who you say you are and if you are making a request on behalf of another, that you have the authority to do so.  If we are unable to do so, we may request that you provide additional information reasonably necessary to authenticate you.  If we cannot authenticate you or your authority, we will deny the request.  If you submit a Right to Opt Out request, we are permitted to deny the request if we have a good faith, reasonable, and documented belief that the request is fraudulent, and we will tell you that and why.

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your DPDPA Personal Data) without undue delay and within 45 days after we receive your request.  We may extend that deadline by 45 days, to 90 days in total, in some cases.  If we extend the deadline, we will tell you that and why.

Delaware’s law includes exceptions for Personal Data regulated under other laws or maintained for certain reasons or in certain contexts.  For example, it does not apply to publicly available information, including information that we reasonably believe Delaware residents have lawfully made available to the general public, or protected health information regulated by HIPAA.  As another example, we will not delete DPDPA Personal Data when it is necessary to maintain it to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not.  You may appeal our decision by emailing us using the information in the Contact Us section with the subject line “Appeal of Request” and including our response to your request.  We will also include this information in our response to your request.  If you appeal our decision, we have 60 days to respond.

In addition, when you visit our website, we may use the information we collect automatically through online interactions, as described above in the Cookie and Pixel Policy section for targeted advertising, which we may disclose or make available to advertising and social media networks.