California Privacy Statement

Pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights and Enforcement Act ("CPRA") (CCPA and CPRA collectively, the "CCPA"), Mark Anderson Companies, Inc., its subsidiaries and affiliates ("MAC") are providing the following Privacy Statement to explain how MAC collects, uses and discloses Personal Data that we collect from individuals who are residents of California, including but not limited to users who visit our websites or consumers who receive goods or services directly from MAC.

For purposes of this California Privacy Statement, Personal Data is information that identifies, relates to, or could reasonably be linked with a particular California resident or household that has the same meaning under the CPRA Section 1798.140(v): 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 Data does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern or information that has been de-identified or aggregated. "Sensitive personal information" has the same meaning as under the CPRA Section 1798.140(ae). Sensitive personal information does not include information that is publicly available.

MAC respects your right to privacy and recognizes our responsibility for protecting the privacy and security of the personal information we receive from you. We are committed to securing the confidentiality and integrity of your personal information.

Collection, Disclosure, and Sharing of Personal Data

The following details which categories of Personal Data we collect and process, which categories of third parties may have access to your Personal Data for operational business purposes, as well as which categories of Personal Data we "share" for purposes of cross-context behavioral advertising, including within the 12 months preceding the date this Privacy Statement was last updated.

Sources of Personal Data

We collect this Personal Data actively (e.g. direct input from individuals) or passively (e.g. website cookies) from you. Additionally, we may also collect Personal Data from third-party sources, such as our affiliates, business partners, and services providers, listed above where applicable.

Purposes for the Collection, Use and Sharing of Personal Data

MAC uses your Personal Data for the following Business Purposes and objectives:

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes (see below for a more detailed description of these categories)	Shared with Which Categories of Third Parties for Cross-Context Behavioral Advertising
Identifiers, such as name, contact information, unique personal identifiers, email address, IP address, online identifiers, government-issued identifiers.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	Ad networks.
Personal information as defined in the California customer records law, such as name, contact information, financial, education, employment information.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.
Characteristics of protected classifications under California or federal law, such as race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, marital status, sex, gender expression, gender identity, age, sexual orientation, military or veteran status.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.
Commercial Information, such as transaction information and purchase history, including purchases considered, consuming histories or tendencies.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.
Biometric Information, such as fingerprints, voiceprints and faceprints.	Not applicable.	Not applicable.
Internet or network activity information, such as IP address, mobile device ids, MAC address, browsing history, search history.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	Ad Networks.
Geolocation Data, such as precise location/tracking data and coarse location/tracking data.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.
Audio/Video Data, such as photographs.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.
Education Information subject to the federal Family Educational Rights and Privacy Act such as education and training history, education degrees, qualifications/certifications.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.
Employment Information. Professional or employment-related information, such as work history and prior employer, background checks, performance rating or feedback, employer occupation title/job role.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.
Inferences such as any assumptions drawn from any of the Personal Data listed above to create a profile about, for example, an individual's preferences or characteristics. This is only applicable to consumers that purchase our TMBC product due to the nature of the product.	Service Providers/Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, with your consent.	None.

Detailed Description of Categories of Third Parties

Third Parties that MAC may disclose your Personal Data are as follows:

(a)	Service Providers/Subcontractors MAC may share your Personal Data with our subcontractors for certain business purposes. This information is provided for them to provide us with services such as payment processing, advertising services, marketing partners, web analytics, data processing, IT services, customer support and other services such as for the purpose of auditing and fraud investigations.
(b)	Related Entities MAC may share Personal Data between and among MAC, its parent company, and other affiliated companies for purposes of management and analysis, and other business purposes. For instances, MAC may share your Personal Data with our parent company and affiliated companies to expand and promote our product and service offerings.
(c)	Law Enforcement/Legal authorities MAC may be required to disclose your Personal Data to third parties including law enforcement agencies when required to protect and defend our legal rights, protect the safety and security of users of our Services, prevent fraud, respond to legal process, or a request for cooperation by a government entity, as required by law.
(d)	Corporate Transactions In the event of a sale, transfer, merger, reorganization, or similar event, MAC may transfer your Personal Data to one or more third parties as part of that transaction with the business entities or people involved in the deal negotiation or transfer.
(e)	With Your Consent MAC may share Personal Data about you with other third-party companies if you give us permission or direct us to share the information. MAC will share Personal Data with authorized agents that you authorize MAC to communicate to.

We do not sell and have not sold Personal Data, including your Sensitive Personal Data, in the preceding 12 months. Without limiting the foregoing, we do not sell Personal Data, including the Sensitive Personal Data, of minors under 16 years of age. We do not knowingly "share" the Personal Data, including the Sensitive Personal Data, of minors under 16 years of age.

Sources of Personal Data

Purposes for the Collection, Use and Sharing of Personal Data

MAC uses your Personal Data for the following Business Purposes and objectives:

(a) Business Purposes for processing Personal Data pertaining to consumers. Personal Data pertaining to consumers with whom MAC has a business relationship may be processed as needed:

(1)	To provide the information, product, or service requested by the individual, and as would be reasonably expected by the individual given the context in which the Personal Data was collected, and the information provided in the applicable privacy statement given to the individual (such as for personalization, remembering preferences, or respecting individual rights);
(2)	For due diligence, including verifying the identity of the individual, as well as the eligibility of the individual to receive information, products, or services (such as verifying age, employment, or account status);
(3)	To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training materials, and service updates);
(4)	To manage the individual's account, such as for customer service, finance, and dispute resolution purposes;
(5)	For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets;
(6)	For security management, including monitoring individuals with access to the website; applications, systems, or facilities, investigation of threats, and as needed for any data security breach notification; and
(7)	To anonymize or de-identify Personal Data. Where we maintain or use de-identified information, we will continue to maintain and use such information only in a de-identified fashion and will not attempt to re-identify such information.

(b) Business-necessary processing activities. MAC may process Personal Data as needed (i) to protect the privacy and security of the Personal Data it maintains, such as in connection with advanced security initiatives and threat detection; (ii) for treasury operations and money movement activities; (iii) for compliance functions, including screening individuals against sanction lists in connection with anti-money laundering programs; (iv) for business structuring activities, including mergers, acquisitions, and divestitures; and (v) for business activities, management reporting, and analysis.

(c) Development and improvement of products and/or services. MAC may process Personal Data to develop and improve its products and/or services, and for research, development, analytics, and business intelligence.

(d) Relationship management and marketing. MAC may process Personal Data for relationship management and marketing. This purpose includes sending marketing and promotional communications to individuals who have not objected to receiving such messages, such as product and service marketing communications, investor communications, Client communications (e.g., product updates and training opportunities and invitations to MAC events), customer satisfaction surveys, supplier communications (e.g., requests for proposals), corporate communications, and MAC news.

(e) Operational purposes. Additionally, MAC uses your Personal Data for purposes such as: (i) disaster recovery and business continuity, (ii) internal audits or investigations; (iii) implementation or verification of business controls; (iv) statistical, historical, or scientific research; (v) dispute resolution; (vi) legal or business counseling; (vii) compliance with laws and company policies; and/or (viii) insurance purposes.

Purposes for the Collection and Use of Sensitive Personal Data

Subject to your consent where required by applicable law, we may use Sensitive Personal Data for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, servicing accounts, providing customer service, verifying customer information, process payments, and activities relating to quality or product improvement.

Retention Period

We retain Personal Data for as long as needed or permitted considering the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

(a) The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Data to address issues that may arise;

(b) Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them); or

(c) Whether retention is advisable considering our legal position (such as regarding applicable statues of limitations, litigation or regulatory investigations).

California Consumer Rights

If you are a California resident you may make the following requests, subject to applicable law:

(a) Right to Access and Know -- You may request that we disclose to you the following information covering the 12 months preceding your request:

(1)	The categories of Personal Data we collected about you and the categories of sources from which we collected such Personal Data;
(2)	The specific pieces of Personal Data we collected about you;
(3)	The business or commercial purpose for collecting or sharing Personal Data about you;
(4)	The categories of Personal Data about you that we shared (as defined under the applicable privacy law) and the categories of third parties with whom we shared such Personal Data; and
(5)	The categories of Personal Data about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Data (if applicable).

(b) Right to Request Correction of your Personal Data -- You may request to correct inaccuracies in your Personal Data;

(c) Right to Request Deletion of your Personal Data -- You may request to have your Personal Data deleted; and

(d) Right to Opt-out of Sharing for Cross-Context Behavioral Advertising -- You may request to opt out of the "sharing" of your Personal Data for purposes of cross-context behavioral advertising.

We will not unlawfully discriminate against you for exercising your rights under the CCPA.

How to submit a California Rights Request

To make a privacy request, please contact us by emailing us at privacy@maianimalhealth.com.. We will verify and respond to your request consistent with applicable law, considering the type and sensitivity of the Personal Data subject to the request. We may need to request additional Personal Data from you, such as your name and email address, to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Data. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Data.

Authorized Agents Submitting a Request on Behalf of a Consumer

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent's authority has been reviewed and verified. Agents may be asked to provide proof of their status as an authorized agent. Once a request has ben submitted by an authorized agent, we may require additional information from you to verify your identity as described in the section entitled "How to Submit a California Rights Request" or confirm that you provided the agent permission to submit the request. Authorized agents emailed privacy@maianimalhealth.com. to submit a request.

Changes to this California Consumer Privacy Statement

We may change or update this Privacy Statement from time to time. When we do, we will communicate updates to this Privacy Statement by posting the updated Statement on this page with a new "Last Updated" date.

Contact Us

If you have any questions regarding this California Consumer Privacy Statement, please contact us at privacy@maianimalhealth.com.

Last Updated: October 1, 2024