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Privacy Notice

Privacy Notice for California Residents

Effective Date: June 5, 2020

This Privacy Notice for California Residents supplements the information contained in WP
Super Host’s Privacy Policy and applies solely to all visitors, users, and others who reside in the
State of California (“consumers” or “you”). We adopt this notice to comply with the California
Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same
meaning when used in this notice.

Information We Collect

The wpsuperhost.com website (collectively, the “Site”) collects information that identifies,
relates to, describes, references, is capable of being associated with, or could reasonably be
linked, directly or indirectly, with a particular consumer or device (“personal information”). In
particular, the Site has collected the following categories of personal information from its
consumers within the last 12 months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address,
email address, account name, Social Security number,
driver’s license number, passport number, or other
similar identifiers.
YES
B. Personal
information
categories listed
in the California
Customer
Records statute
(Cal. Civ. Code §
1798.80(e)).
A name, signature, Social Security number, physical
characteristics or description, address, telephone number,
passport number, driver’s license or state identification
card number, insurance policy number, education,
employment, employment history, bank account number,
credit card number, debit card number, or any other
financial information, medical information, or health
insurance information.
Some personal information included in this category may
overlap with other categories.
YES
C. Protected
classification
characteristics
under California
or federal law.
Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status,
medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions),
sexual orientation, veteran or military status, genetic
information (including familial genetic information).
YES
D. Commercial
information.
Records of personal property, products or services
purchased, obtained, or considered, or other purchasing
or consuming histories or tendencies.
YES
E. Biometric
information.
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a
template or other identifier or identifying information,
such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns,
and sleep, health, or exercise data.
NO
F. Internet or
other similar
network activity.
Browsing history, search history, information on a
consumer’s interaction with a website, application, or
advertisement.
YES
G. Geolocation
data.
Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar

information.

NO
I. Professional or
employment-relat
ed information.
Current or past job history or performance evaluations. NO
J. Non-public
education
information (per
the Family
Educational
Rights and
Privacy Act (20
U.S.C. Section
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, transcripts, class lists,
student schedules, student identification codes, student
financial information, or student disciplinary records.
NO
K. Inferences
drawn from other
personal
information.
Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
NO

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and
    Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical
    Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the
    Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or
    California Financial Information Privacy Act (FIPA), and the Driver’s Privacy
    Protection Act of 1994.

WP Super Host obtains the categories of personal information listed above from the following
categories of sources:

  • Directly from you. For example, from forms you complete or products and services you
    purchase.
  • Indirectly from you. For example, from observing your actions on our Site.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following
business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share
    your name and contact information to ask a question about our products or services, we
    will use that personal information to respond to your inquiry. If you provide your
    personal information to purchase a product or service, we will use that information to
    process your payment and facilitate delivery. We may also save your information to
    facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Site, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent
    transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate
    and address your concerns and monitor and improve our responses.
  • To personalize your Site experience.
  • For testing, research, analysis, and product development, including to develop and
    improve our Site, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or
    governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth
    in the CCPA.

WP Super Host will not collect additional categories of personal information or use the personal
information we collected for materially different, unrelated, or incompatible purposes without
providing you notice.

Sharing Personal Information

WP Super Host may disclose your personal information to a third party for a business purpose.
When we disclose personal information for a business purpose, we enter a contract that describes
the purpose and requires the recipient to both keep that personal information confidential and not
use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Subsidiaries and affiliates.
  • Contractors and service providers.
  • Data aggregators.
  • Third parties with whom we partner to offer products and services to you.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, WP Super Host has disclosed the following categories of personal
information for a business purpose to the parties identified above:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.

Sales of Personal Information

In the preceding 12 months, WP Super Host has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their
personal information. This section describes your CCPA rights and explains how to exercise
those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that WP Super Host disclose certain information to you about our
collection and use of your personal information over the past 12 months. Once we receive and
confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion
Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data
    portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate
    lists disclosing:

    • sales, identifying the personal information categories that each category of recipient
      purchased; and
    • disclosures for a business purpose, identifying the personal information categories
      that each category of recipient obtained.

Deletion Request Rights

You have the right to request that WP Super Host delete any of your personal information that
we collected from you and retained, subject to certain exceptions. Once we receive and confirm
your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights),
we will delete (and direct our service providers to delete) your personal information from our
records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good
    or service that you requested, take actions reasonably anticipated within the context of
    our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
    activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech
    rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
    1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the
    public interest that adheres to all other applicable ethics and privacy laws, when the
    information’s deletion may likely render impossible or seriously impair the research’s
    achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based
    on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the
    context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a
verifiable consumer request to us by contacting us at:

Sprious LLC
d/b/a WP Super Host or support@wpsuperhost.com
440 N 8th Street, Suite 110
Lincoln, NE 68508

Only you, or a person registered with the California Secretary of State that you authorize to act
on your behalf, may make a verifiable consumer request related to your personal information.
You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person
    about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand,
    evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify
your identity or authority to make the request and confirm the personal information relates to
you.

Making a verifiable consumer request does not require you to create an account with us. We will
only use personal information provided in a verifiable consumer request to verify the requestor’s
identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its
receipt. If we require more time (up to 90 days), we will inform you of the reason and extension
period in writing.

If you have an account with us, we will deliver our written response to that account. If you do
not have an account with us, we will deliver our written response by mail or electronically, at
your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable
consumer request’s receipt. The response we provide will also explain the reasons we cannot
comply with a request, if applicable. For data portability requests, we will select a format to
provide your personal information that is readily useable and should allow you to transmit the
information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee,
we will tell you why we made that decision and provide you with a cost estimate before
completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal
information at any time (the “right to opt-out”). We do not sell the personal information of
consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of
age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers
who opt-in to personal information sales may opt-out of future sales at any time.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted
by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting
    discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different
    level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in
different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will
reasonably relate to your personal information’s value and contain written terms that describe the
program’s material aspects. Participation in a financial incentive program requires your prior
opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that
are California residents to request certain information regarding our disclosure of personal
information to third parties for their direct marketing purposes. To make such a request, please
write us at:

Sprious LLC
d/b/a WP Super Host or support@wpsuperhost.com
440 N 8th Street, Suite 110
Lincoln, NE 68508

Changes to Our Privacy Notice

WP Super Host reserves the right to amend this privacy notice at our discretion and at any time.
When we make changes to this privacy notice, we will post the updated notice on the Site and
update the notice’s effective date. Your continued use of our Site following the posting of
changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which WP Super Host
collects and uses your information described below and in the Privacy Policy, your choices and
rights regarding such use, or wish to exercise your rights under California law, please do not
hesitate to contact us at:

Sprious LLC
d/b/a WP Super Host or support@wpsuperhost.com
440 N 8th Street, Suite 110
Lincoln, NE 68508

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