This section provides additional information for California residents under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered "personal information," such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.

To the extent we process deidentified personal information, we will make no attempt to reidentify such data.

Information we collect from you

Personal Identifiers, including name, email address, postal address, telephone number, and online Identifiers
Internet Activity
Commercial Information, including purchases
Financial Information, including credit or debit card number
Biometric Information, including sleep, health, or exercise data
Location Information, including general location data and precise geolocation
Physical and Audio Data, including physical characteristics or descriptions
Protected Classifications and Other Personal Characteristics, including age and sex, gender, or gender identity
Health Data, including data related to physical or mental health
Inferences from Other Data, including inferences created from other personal information collected and inferences based on sensitive information

To the extent we process deidentified personal information, we will make no attempt to reidentify such data.

Information from other sources

We may collect personal information about you from third-party sources, including Ad Networks.

How long we keep your data

We do not retain data for any longer than is necessary for the purposes described in this Policy.

We generally retain data according to the guidelines below.

Data Retention
Type of Data	Retention Period
Cookies and online data we collect while you use our website, including Online Identifiers, Internet Activity, General location data, Precise geolocation	We delete or anonymize data concerning your use of our website within 7 years of collecting it.
Data we collect in order to process and ship orders you place with us, including Name, Email address, Postal address, Telephone number, Purchases, Credit or debit card number, General location data	We keep personal information related to products and services you purchase for as long as the personal data is required for us to fulfill our contract with you, and for 7 years from your last purchase with us. We may keep data beyond this period in anonymized form.
Data we collect when you contact us for customer support and other inquiries, including Name, Email address, Postal address, Telephone number, Purchases	We keep customer feedback and correspondence with our customer service for up to 7 years to help us respond to any questions or complaints. We may keep data beyond this period in anonymized form.
Data we collect when you sign up for promotional and marketing communications, including Name, Email address, Postal address, Telephone number, Online Identifiers, Internet Activity, Purchases, General location data, Inferences created from other personal information collected	Where you have signed up to receive promotional and marketing communications from us, we will retain any data collected until you opt out or request its deletion. We may keep data beyond this period in anonymized form. We will further retain a record of any opt-outs in order to prevent sending you future communications.
Data we collect when you review our products, answer surveys, or send feedback, including Name, Email address, Online Identifiers, Purchases	We retain review, survey, and feedback data for up to 7 years following your last contact with us. We may keep data beyond this period in anonymized form to help improve our products and services.
Data we collect in connection with privacy requests, including Name, Email address, Online Identifiers	We retain records related to privacy requests as long as necessary to comply with our legal obligations.
Data we collect for security purposes, including Name, Email address, Online Identifiers, General location data	We retain security-related data as long as necessary to comply with our legal obligations and to maintain and improve our information security measures.
Data we collect for Fitness Programming, including Name, Email address, Postal address, Telephone number, Online Identifiers, Purchases, Credit or debit card number, Sleep, health, or exercise data, General location data, Physical characteristics or descriptions, Age, Sex, gender, or gender identity, Data related to physical or mental health	We keep personal information related to your Fitness Programming for as long as the personal data is required for us to fulfill our contract with you, and for 7 years from your last purchase with us. We may keep data beyond this period in anonymized form.

Why we process your information

We process personal information for the following business and commercial purposes:

Analyzing Data
Conducting Surveys
Creating Customer Profiles
Delivering Targeted Ads
Fulfilling Customer Orders
Improving our Products & Services
Internal Business Operations
Managing Event & Guest Data
Marketing Our Products & Services
Meeting Compliance & Legal Requirements
Operating Our Website or Mobile Apps
Preventing Fraud
Processing Payments
Providing Customer Support
Providing Cybersecurity
Sending Promotional Communications
Storing and Managing Data
Tracking Purchases & Customer Data

How we disclose your information

We may disclose personal information about you for business and commercial purposes when you Consumers:

Data Disclosure
Personal Information Category	Categories of Service Providers	Categories of Third Parties
Personal Identifiers	Ad Networks, Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Contractors, Customer Support Tools, Data Analytics Providers, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, Sales & Marketing Tools, and Shipping Services	Ad Networks, Payment Processors, and Shipping Services
Internet Activity	Ad Networks, Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Contractors, Customer Support Tools, Data Analytics Providers, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, and Sales & Marketing Tools	Ad Networks
Commercial Information	Ad Networks, Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Contractors, Data Analytics Providers, Governance, Risk & Compliance Software, Payment Processors, Sales & Marketing Tools, and Shipping Services	Ad Networks, Commerce Software Tools, and Payment Processors
Financial Information	Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Contractors, Data Analytics Providers, Governance, Risk & Compliance Software, Payment Processors, Sales & Marketing Tools, and Shipping Services	Commerce Software Tools and Payment Processors
Biometric Information	Data Analytics Providers and IT Infrastructure Services	None
Location Information	Business Operations Tool, Contractors, Governance, Risk & Compliance Software, and IT Infrastructure Services	None
Physical and Audio Data	Data Analytics Providers	None
Protected Classifications and Other Personal Characteristics	Data Analytics Providers and IT Infrastructure Services	None

Information “sharing” and “selling”

We “share” certain personal information with third party ad networks for purposes of behavioral advertising, including: Personal Identifiers, Internet Activity, and Commercial Information. This allows us to show you ads that are more relevant to you.

You may opt-out of these data practices here.

We do not receive monetary or other valuable consideration in exchange for your data and therefore do not "sell" your data as defined in CCPA.

We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age.

Opt-out preference signals

Your browser settings may allow you to automatically transmit an opt-out preference signal, such as the Global Privacy Control (GPC) signal, to online services you visit. When we detect such signal, we place a U.S. Privacy String setting in your browser so that any third party who respects that signal will not track your activity on our website. Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. GPC is supported by certain internet browsers or as a browser extension. Find out how to enable GPC.

Your CCPA rights

Your privacy rights under the CCPA are described below. Make a Privacy Request by clicking here or by emailing us at hq@soflete.com.

Right to Access

You have the right to access the specific pieces of personal information we have collected about you.

If you make an Access Request more than twice in a 12-month period, or we determine the request is manifestly unfounded or excessive, we may require you to pay a small fee for this service.

Right to Delete

You have the right to request that we delete any personal information about you that you have provided to us. Subject to certain limitations, we will delete your personal information from our records and notify our service providers, contractors, and third parties that you have requested deletion of your personal information.

Right to Non-Discrimination

If you exercise your CCPA privacy rights, we will not discriminate against you by, for example, charging a different price or offering a different level or quality of products or services.

We will not retaliate against you, as an employee, applicant for employment, or independent contractor, for exercising your privacy rights.

Right to Opt-Out

You have the right to opt-out of any selling and sharing of your personal information.

You may exercise your right to opt-out here.

Right to Correct

You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.

Right to Limit the Use of Sensitive Personal Information

The Right to Limit does not apply because we do not use your sensitive personal information to infer characteristics about you.

Request Verification

Before we can respond to a privacy request, we will verify that you are the consumer who is the subject of the CCPA request. Requests to Opt-Out or Limit the Use of Sensitive Data (if applicable) do not require verification.

Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request.

Authorized Agent

A California resident's authorized agent may submit a rights request under the CCPA by emailing us at hq@soflete.com. Requests submitted by an authorized agent will still require verification of the consumer who is the subject of the request in accordance with the process described above. We will also ask for proof that the consumer who is the subject of the request authorized an agent to submit a privacy request on their behalf by either verifying their own identity with us directly or directly confirming with us that they provided the authorized agent permission to submit the request. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 may also submit proof of statutory power of attorney, which does not require separate consumer verification.

If you have trouble accessing this notice, please contact us at hq@soflete.com.

Contact Us

If you have any privacy-related questions or have trouble accessing this notice, please email hq@soflete.com.

Notice of Financial Incentive

Consumers who sign up for our marketing emails/SMS texts receive a 10% discount on their first purchase. To opt in, a consumer must enter their email address/phone number into the form and consent to receive emails in exchange for a discount provided via coupon code. A consumer may unsubscribe from our marketing emails by using the unsubscribe link in the email footer/replying STOP via text at any time. We calculate the value of the offer and financial incentive by using the expense related to the offer.

Your Privacy Choices

Request to Opt-Out