Privacy Notice for California Residents

Effective Date: April 29, 2026

Last Updated: April 29, 2026

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This Privacy Notice for California Residents (this “Privacy Notice”) is intended to supplement our Privacy Policy and applies only to California residents. Any terms used in this Privacy Notice have the same meaning as defined in our Privacy Policy.

Application

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, (collectively, the “CCPA”), California residents have the right to be informed about the data we collect about them. This Privacy Notice applies solely to natural persons who are California residents, as defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

 

Categories of Personal Information We Collect

The CCPA defines “Personal Information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident. Personal Information does not include:

  • Publicly available information from government records;
  • Deidentified or aggregate information;
  • Personal Information covered by certain sector-specific privacy laws, such as the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) (“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act (“HITECH”), the Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (“FIPA”).

Notably, this Privacy Notice does not apply to any health information we may collect in the context of our provision of our services to you and Providers. Please see our HIPAA Notice for more information on the collection, use and disclosure of such information.

Below are the categories of Personal Information that we may have collected, used, and disclosed for a business purpose, as permitted by law, in the last twelve (12) months, depending on your interactions with us:

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Category Examples May Include Collected
1. Identifiers Your name, postal address, unique personal identifier, account information, online identifier, Internet Protocol address, email address, telephone number Yes
2. Customer Records Personal Information Categories Name, signature, address, telephone number, financial account information Yes
3. Protected Classification Characteristics Race, color, gender, age, military or veteran status No
4. Commercial Information Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Yes
5. Biometric information Fingerprint, retina scan No
6. Internet or other electronic network activity information Browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement Yes
7. Geolocation data City and state location of your device Yes
8. Sensory Data Audio, electronic, visual, thermal, olfactory, or similar information No
9. Professional or Employment-related Information Employer, job title, occupation No
10. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts No
11. Inferences drawn from other personal information collected Inferences drawn from the information we collect when you visit our Website, reflecting your preferences, predispositions, etc. Yes
12. Sensitive Personal Information Account log-in information and account credentials Yes; for account access only and we do not use sensitive PI for purposes requiring a right to limit

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Sources from which We Collect Personal Information

The following are categories of sources from which we may receive your Personal Information:

  1. directly from you when you inquire about our Services via our Website, or otherwise voluntarily submit information to Polly;
  2. from information collected through the use of cookies, web beacons, and other tracking technologies within our Services, third party advertisements on our Website, and emails; and
  3. from third parties that assist us in providing relevant services (e.g., data analytics vendors, marketing support vendors).

A more detailed description of these categories of sources from which Personal Information is collected is available in our Privacy Policy.

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Business or Commercial Purposes for which We Collect Personal Information

We may collect the Personal Information listed above for the following business or commercial purposes:

  1. i. To respond to your questions;
  2. ii. To confirm or fulfill purchase and/or registration requests;
  3. iii. To provide to you the Services you requested;
  4. iv. To send you information about third party services through pop-ups, banners and emails;
  5. v. For marketing and promotional purposes by various means, including email, mail, and telephone;
  6. vi.To contact you regarding events, news, or other resources and to advise you of products or services that may be available;
  7. vii. To display content we think may be of interest to you and customize your visit to and use of the Services and our communications;
  8. viii. To notify you about maintenance, updates, and new features;
  9. ix. To contact you as needed to inform you of updates to or to address a suspected violation of our Terms and Conditions of Use, Privacy Policy, or any other rules or policies applicable to the Services; 
  10. x. To get your feedback to assess user-satisfaction or other needs and interests;
  11. xi. To perform information analysis, compliance audits, and data metrics;
  12. xii. To evaluate the use and the effectiveness of the Services that we offer, which can include the effectiveness of content, advertising, or programs;
  13. xiii. To help us create new tools, features, and services and improve the Services, content, and products;
  14. xiv. To perform security and integrity tasks, including detecting security incidents and protecting against malicious or illegal activity;
  15. xv. To comply with applicable laws, rules, or regulations in operating our business; and
  16. xvi. Otherwise in rendering, administering, and improving, our products and services, and our business.
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Disclosure of Personal Information for Our Business or Commercial Purposes

We have disclosed the following categories of Personal Information for business or commercial purposes in the preceding twelve (12) months to the following categories of third parties:

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Categories of Third Parties to Whom Personal Information Was Disclosed for a Business or Commercial Purpose Categories of Personal Information Disclosed for a Commercial Purpose Business or Commercial Purpose for Disclosing Personal Information
Service providers or contractors A, B, D, F, G, K, L To help facilitate, manage, and/or analyze our Services (including web servers, cloud storage systems and service providers, support teams, web analysts, security and risk management vendors, and others)
Third parties authorized by law to receive Personal Information A, B, D, F, G, K, L To comply with applicable legal requirements
Subsidiaries, affiliates, business partners, and our Related Companies A, B, D, F, G, K, L To operate our business and provide our Services
Third parties involved in business transfers A, B, D, F, G, K, L For example, for a corporate merger, acquisition, consolidation, the sale of substantially all of our assets, or other fundamental corporate change, whatever form it may take
Current or prospective advertisers, sponsors, and other business partners A, B, D, F, G, K For marketing purposes
Third parties to whom you or your agents request or authorize us to disclose your Personal Information in connection with the Services we provide to you. A, B, D, F, G, K, L To operate our business and provide our Services

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Sale/Sharing of Personal Information

Subject to certain limited exceptions, the CCPA defines “sell,” “selling,” “sale,” or “sold,” as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration.” Subject to certain limited exceptions, the CCPA defines “share,” “shared,” or “sharing” as “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.”

We do not “sell” Personal Information for monetary or other valuable consideration, or “share” Personal Information for cross-context behavioral advertising.

 

Our Use and Disclosure of Sensitive Personal Information

As noted above in “The Information We Collect” section of this Privacy Notice, certain personal information we collect and process may be considered “sensitive personal information” under the CCPA. The CCPA requires that we provide you with the right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.

 

Consumers under 13 Years of Age

We do not intentionally collect, sell, or share the Personal Information of consumers under thirteen (13) years of age.

 

Data Retention

We retain Personal Information about you necessary to fulfill the purpose for which that information was collected, consistent with applicable laws. When we destroy your Personal Information, we do so in a secure manner in compliance with applicable laws, such that the Personal Information may not be reconstructed.

 

My Rights under the CCPA

If you are a California resident, you may exercise certain privacy rights related to the Personal Information we collect about you. You may exercise these rights free of charge, except as otherwise permitted under applicable law.

 

  1. Right to Know/Access Personal Information

You have the right to request that we disclose to you what Personal Information we collect, use, or disclose. This information includes (a) the categories of your Personal Information that we have collected for a business purpose; (b) the categories of sources from which we have collected your Personal Information; (c) the categories of third parties to whom we disclose your Personal Information; (d) the business or commercial purpose for your Personal Information; and (e) the specific pieces of Personal Information we have collected about you.

 

  1. Right to Deletion of Personal Information

You have the right to request that we delete your Personal Information, subject to certain limited exceptions. For example, we may deny your request to delete Personal Information that we are required to maintain to fulfill a legal obligation.

 

  1. Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate Personal Information that we maintain about you.

 

  1. Right to Non-Discrimination

We will not discriminate or retaliate against you for exercising your consumer rights under the CCPA, including by (a) denying you goods or services; (b) charging (or suggesting that we will charge) different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or (c) providing you a different level or quality of goods or services (or suggesting that we will do so). We may, however, offer a different price, rate, level, or quality of goods or services if that price or difference is reasonably related to the value provided to us by your data.

 

How to Submit a Request

You may submit your request to access, delete, or correct Personal Information collected about you by contacting us by email at legal@joinpolly.com, through our website at joinpolly.com/webform, or by calling us at 305-290-7440.


Verification of Identity and Processing of Requests

As required or permitted under applicable law, we may take steps to verify your identity before processing your request to access, delete, or correct Personal Information collected about you as set forth above. In order for your request to be processed, you must provide us with enough information to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person. We will confirm receipt of your request within 10 business days and provide information about how we will process your request. We will review each request for access, deletion, or correction carefully and respond to most requests within 45 calendar days if we are able to verify your identity based on the information you have provided; however, we may extend this time period once by an additional 45 calendar days when reasonably necessary, provided that we provide you with notice of this extension.

 

Agent Authorization

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as set forth in this Privacy Notice. Even if you choose to use an agent, as permitted by law, we may require you to confirm you have authorized the agent to act on your behalf or require you to verify your own identity.

 

Contact Us

Please let us know if you have any comments or questions about this Privacy Notice or our privacy practices. You may email us at legal@joinpolly.com.  

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