California Consumer Privacy Rights Notice

Effective: January 1, 2020

This California Consumer Privacy Rights Notice (“Notice”) sets forth Thanx, Inc.’s disclosure obligations under California law, including the California Consumer Privacy Act of 2018 (“CCPA”) and the California Civil Code section 1798.83. This Notice provides the additional details regarding the information defined as ‘personal information’ under applicable California law and related to a California resident or household (“Consumers” or “You”), further referred to as “Personal Information”.

1. Personal Information Collected and Disclosed:

Thanx collects, uses and/or discloses Personal Information for purpose of its Loyalty Reward Program (“Program”) as follows:

Personal Information Collected, Used and/or Disclosed for Business Purpose in Preceding 12 Months
CCPA Category	Collected?	Source of Collection	CCPA - Business Purpose	3rd Parties Disclosed	CCPA Purpose 3rd Party Disclosure
Category A Identifiers & B Personal Information
Name/Alias	YES	YOU	Performing Services	Your Selected Merchants	Performing Services
Email	YES	YOU	Performing Services	Your Selected Merchants	Performing Services
Address	YES	YOU	Online Ordering for Delivery	Your Selected Merchants	Performing Services
Cell or Telephone #	YES	YOU	Performing Services	Your Selected Merchants	Performing Services
Unique/Online ID (cookies)	YES	YOU/DEVICE	Performing Services Internal Analytics Auditing	Your Selected Merchants	Performing Services
IP Address	YES	DEVICE 3rd Party Services	Auditing Data Security Performing Services	Your Selected Merchants	Performing Services
Account Name	NO	N/A	N/A	N/A	N/A
Social Security #	NO	N/A	N/A	N/A	N/A
Driver’s License #	NO	N/A	N/A	N/A	N/A
Passport #	NO	N/A	N/A	N/A	N/A
Credit or Debit Card # / ACH	YES	YOU	Performing Services Processing Payments for Digital Purchases	N/A	N/A
Other: Medical/Financial/Health	NO	N/A	N/A	N/A	N/A
Category C: Protected Characteristics
	NO	N/A	N/A	N/A	N/A
Category D: Commercial Information
Personal Property Records	Yes	Program Partner Merchants	Performing Services Analytics	Your Selected Merchants	Performing Services
Products/Services Purchased-Obtained-Considered	Yes	Cookies Purchases Service Providers	Performing Services	Your Selected Merchants	Performing Services Analytics
Purchasing history/tendencies	Yes	Cookies Purchases	Performing Services	Payment Processors; Your Selected Merchants	Performing Services Analytics
Category E: Biometric Information
	No	N/A	N/A	N/A	N/A
Category F: Internet/Network Activity
Browsing/search history	No	N/A	N/A	N/A	N/A
Interaction with site/advertisement	No	N/A	N/A	N/A	N/A
Category G: Geolocation data
	Yes	Device	Performing Services	Your Selected Merchants	Performing Services Analytics
Category H:
Audio	NO	N/A	N/A	N/A	N/A
Electronic	NO	N/A	N/A	N/A	N/A
Visual	NO	N/A	N/A	N/A	N/A
Thermal	NO	N/A	N/A	N/A	N/A
Olfactory	NO	N/A	N/A	N/A	N/A
Other Similar	NO	N/A	N/A	N/A	N/A
Category L: Professional/Employment
	NO	N/A	N/A	N/A	N/A
Category J: Educational Information
	NO	N/A	N/A	N/A	N/A
Category K: Inferences from Data Collected
Preferences	Yes	Platform usage	Performing Services	Your Selected Merchants	Performing Services
Characteristics	N/A	N/A	N/A	N/A	N/A
Psychological Trends	N/A	N/A	N/A	N/A	N/A
Predispositions	N/A	N/A	N/A	N/A	N/A
Behavior	YES	Your Platform Usage	Performing Services Auditing Analytics	Your Selected Merchants	Performing Services
Attitudes	N/A	N/A	N/A	N/A	N/A
Intelligence/Abilities/Aptitudes	N/A	N/A	N/A	N/A	N/A

Other Potential Third Party Disclosures: Personal Information may also be disclosed to third parties to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) as part of a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of all or part of the business, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies as required by law; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations.

2. Sale of Personal Information

Thanx does not sell and will not sell your Personal Information.

3. Your Consumer Rights under CCPA.

California Consumers may contact Thanx through their account, by email at support@thanx.com with “Your California Privacy Rights” in the subject line.

A. Request Thanx Disclosure At No Charge:

categories of Personal Information collected, used, and/or disclosed about you;
categories of sources from which Personal Information is collected
business and/or commercial purposes for collecting and disclosing your Personal Information;
categories of third parties with whom your Personal Information has been disclosed/shared; and
the specific pieces of Personal Information collected about you.

B. Request Thanx to Delete At No Charge:

Except as exempted pursuant to CCPA 1798.105, to request Thanx delete Personal Information.

C. Consumer Request Limitations

Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA, including, but not limited to:

Thanx is obligated to disclose/delete only upon a verifiable Consumer request from the consumer or an authorized agent acting on behalf of Consumer.
Consumers may only make a personal information request twice in a 12-month period.
Deletion is not required because it is necessary for Thanx to maintain the Personal Information to fulfill the purposes enumerated in CCPA Section 1798.105

Thanx will confirm and respond to all requests within the timeframe required under the CCPA. In responding to any request to disclose/delete, Thanx shall maintain a record of the requests as required under the CCPA.

4. Non-Discrimination Policy

You have the right not to receive discriminatory treatment for exercising any rights conferred by the CCPA. Thanx shall not discriminate against a consumer for exercising any rights under the CCPA, including, but not limited to, (a) denying goods or services, (b) charging different prices or rates (including discounts/penalties) that is not directly related to the value provided to Thanx for the Personal Information, or (c) suggesting Consumer will receive a different rate/price or different level of quality of goods/services

5. Your California Privacy Rights under California Civil Code Section 1798.83 & Business and Professions Code Section 22581

Once a year, California law permits Consumers to request and obtain certain information about their Personally Identifiable Information (“PII”) (as defined by California law) disclosed to third parties for direct marketing purposes in the preceding calendar year (if any), free of charge. If applicable, this information would include a list of the categories of PII that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.

In addition, a business subject to California Business and Professions Code Section 22581 must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

6. Accessibility of this CCPA Policy.

You can print a copy of this Notice here.

7. Contact Us

Additional detail regarding our collection, use and disclosure of Personal Information, as well as general opt-out rights and other privacy disclosures, is set forth in our general Privacy Policy.

If you have any questions regarding your Personal Information or about our privacy practices, please contact us at: support@thanx.com

This Notice was last updated: January 1, 2020