Privacy Policy

Last Updated: February 14, 2025
PLEASE READ THIS NOTICE CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR RIGHTS AND CHOICES.

Introduction

Vortex Companies, LLC and its subsidiaries (collectively, “Vortex”, “we,” “us,” and “our”) prioritize the safeguarding of your personal information. We are committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat the personal information that we collect and process.

When does this Policy apply? This privacy policy (“Policy”) governs the collection of personal data by Vortex through its websites, mobile apps, or any other online platforms that it operates and manages and that link to this Policy (each referred to as a “Site,” and collectively, the “Sites”). For more information about how we process personal information in connection with job applications, please see our Job Applicant Privacy Notice.

By accessing or using any of our Sites, you agree to the policies, terms, and conditions outlined in this Policy and consent to the collection and use of your information by Vortex. You also authorize us to take any actions regarding your information in accordance with the provisions of this Policy.

Our Role and Contact Information. We act as the “data controller” with respect to the information described in this Policy. Our contact information is provided at the end of this Policy.

How We Process Personal Information

What Personal Information Do We Collect? We collect the following types of personal data for the purposes listed below.

Category	Description
Contact Information	If you contact us, we will receive your name, title, company/organization name and type, mailing address, country, email address, phone number, fax number, and other information that you share with us. If you visit one of our facilities, we may require you to sign-in. We process Contact Information to operate our Sites and business; to provide our products and services; to provide customer support; to ensure the privacy and security of our Sites and operations; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to respond to your request; to complete transactions you request; and to keep records of our communications with you. The legal basis for this processing is our legitimate interest in the proper administration of our Sites and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information
Communications	If you contact us, in addition to your Contact Information, we will receive any comments, content, questions, complaints, customer service requests, or other information that you choose to provide. You can decide how much information you want to share with us in those communications. We process Communications to operate our Sites and business; to provide our products and services; to provide customer support; to ensure the privacy and security of our Sites and operations; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to respond to your request; to complete transactions you request; and to keep records of our communications with you. The legal basis for this processing is our legitimate interest in the proper administration of our Sites and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Professional or Employment-related Information
Account Information	When you create an account with us, in addition to your Contact Information, we collect your username or account ID and the password that you choose to create. You may be required to create an account to access certain features of the Sites. We process Account Information to operate our Sites and business; to provide our products and services; to provide customer support; to ensure the privacy and security of our Sites and operations; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes. The legal basis for this processing is our legitimate interest in the proper administration of our Sites and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Sensitive Personal Information
Order and Payment Information	If you purchase products from us, our payment processor will receive your credit/debit card number, security code, and expiration date; other applicable financial information; and your billing information and address. We will also receive your order and shipping details. We keep records of the products purchased along with your Contact Information and Account Information. We process Order and Payment Information to operate our Sites and business; to provide our products and services; to provide customer support; to ensure the privacy and security of our Sites and operations; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to determine user interests; to develop new products and services; for usage analytics purposes; to process and complete payments and other transactions; and to detect fraud and prevent loss. The legal basis for this processing is our legitimate interest in the proper administration of our Sites and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Sensitive Personal Information
Job Applicant Information	In addition to Contact Information, we collect and receive information about vendors’ and potential vendors’ services, information needed to facilitate payment and tax reporting, and other information necessary to facilitate the business relationship. We process Vendor Information to operate our Sites and business; to provide our products and services; to ensure the privacy and security of our Sites and operations; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to respond to your request; to complete transactions you request; and to keep records of our communications with you. The legal basis for this processing is our legitimate interest in the proper administration of our Sites and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Professional or Employment-related Information
Cookies and Similar Technologies	The Sites use cookies and similar technologies. Please see the “Our Use of Cookies and Web Beacons” section of this Policy for more information. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly. We process Cookies and Similar Technologies to operate our Sites and business; to provide our products and services; to provide customer support; to ensure the privacy and security of our Sites and operations; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to respond to your request; to keep records of our communications with you; to determine user interests; to develop new products and services; for usage analytics purposes; to process and complete payments and other transactions; and to detect fraud and prevent loss. Where required by law, we rely on your express opt-in consent for the use of marketing, performance, and analytic cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Sites and business. CCPA Categories: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data
Usage Data	When you visit the Sites, we automatically collect information from your browser and your device, including: the date and time of your visit, data about which pages you visit, data about which links you click, and your Internet Protocol (IP) address, device identifier, device type, operating system, language preferences, and browser type. On Sites where you log in, we may link this data to your Account Information to better understand your interest in our products and services. We process Usage Data to operate the Sites, to serve you the content and functionality you request, to ensure the privacy and security of our Sites and operations, to develop new products and services, to enhance your experience and provide you with a more personal and interactive experience, and for usage analytics purposes. The legal basis for this processing is our legitimate interests in monitoring and improving our Sites. CCPA Categories: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data

Is Personal Information Required? You can visit the Sites without providing any personal data. However, on some Sites, we may ask you for personal data so that we may provide a service or carry out a transaction you request. Providing this information is voluntary. However, if you choose not to, we may be unable to fulfill your request or complete your transaction.

Other Processing Activities. We may also process personal information when necessary for the following:

• The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
• Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
• Compliance with applicable laws (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
• Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate applicable law (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
• Collection, use, retention, or disclosure of information that is deidentified or aggregated. We will process such data only in a de-identified fashion and not attempt to re-identify such data.
• Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.

We may process your personal information in connection with any of the purposes and uses described in this Policy on one or more of the following legal grounds:

• Because it is necessary to perform the tasks you have requested or to comply with your instructions or other contractual obligations between you and us;
• To comply with our legal obligations as well as to keep records of our compliance processes;
• Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
• Because you have chosen to publish or display your personal information on a public area of a Site, such as a comment area;
• Because it is necessary to protect your vital interests;
• Because it is necessary in the public interest; or
• Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.

Our Use of Cookies and Web Beacons

What are First-Party and Third-Party Cookies? A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

What are Other “Similar Technologies”? What are Other “Similar Technologies”? In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels, (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

Other Third-Party Technologies. Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Website’s functionality. In addition, adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:

• Google Chrome
• Firefox
• Microsoft Edge
• Safari for Mac and iPhone

You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

How do we disclose the information described in this Policy? Where permitted by applicable law, we may share the information described above in the following contexts. We will only disclose your personal information where, when required by law, the recipient has provided written assurances that it will protect any personal information disclosed to it in accordance with applicable law. We will not share your phone number with third partiesor our affiliates for the purpose of such parties sending you SMS text messages.

Category	Disclosure Contexts
Affiliates	We share personal information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.
Corporate Transactions	We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our organization or assets.
Disclosures with Your Consent	We may ask if you would like us to share your information with third parties who are not described elsewhere in this Policy. We will only disclose your information in this context with your consent.
Legal Obligations	We will disclose your information in response to subpoenas, warrants, court orders, and other legal process and/or to comply with relevant laws. We may also share information in order to establish or exercise our legal rights; to pursue claims; to defend against claims; and to investigate, prevent, or take action regarding possible illegal activities, fraud, safety of person or property, or a violation of contract.
Service Providers and Advisors	We share personal information with our and our affiliates’ contractors, service providers, insurers, and professional advisors (including attorneys, accountants, consultants, and auditors) that need access to the information to provide services on our behalf or perform functions for us. Among other things, the recipients help us administer the Website; support our provision of services; process payments; send communications; provide technical support; support our provision of promotions, sweepstakes, or contests; and assist with other legitimate purposes permitted by law.
Deidentified or Aggregated Data	We share aggregated information and information that does not identify any specific individual, such as groupings of demographic data and preferences (1) for compliance with reporting obligations; (2) for business or marketing purposes; and (3) to assist us and others in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, marketing, and/or functionality.

Data Security

Vortex is dedicated to safeguarding the security of personal data. While no security measure can fully eliminate the risk of a breach, we employ various security technologies and procedures to protect data from unauthorized access, use, or disclosure and to detect fraudulent identify-verification activity, including when transmitting personal information in response to data subject requests.

For example, we store the personal data you provide on systems with restricted access, located in secure facilities. When you navigate between pages or across sites using the same login credentials, we authenticate your identity using an encrypted cookie placed on your device. Additionally, when you place an order, view account details, or submit financial information, we ensure the protection of such data during transmission through Secure Socket Layer (SSL) encryption and other secure protocols.

For sites where you log in, it is your responsibility to keep your password secure and not share it with others. If you are using a shared computer, you should always log out before leaving the site to prevent others from accessing your information.

Although we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Sites. Your use of the Sites is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

Personal Data Retention

As permitted by applicable law, we retain the personal information we collect about you as long as (1) it is necessary to fulfill the purposes for which it was collected, in line with this Policy, or (2) we have another lawful reason, outlined in this Policy or at the time of collection, to retain the information beyond the period required for the original purpose.

We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it. We may retain and use anonymous, de-identified, or aggregated information for as long as is permitted under applicable law.

We are required by law to maintain records of consumer requests submitted under the CCPA and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes. For more information, please contact Human Resources via the contact information provided below.

Your Rights And Choices

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor requests when we are required to do so under applicable law.

Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of your information changes, please let us know via any of the “Contact Us” details at the end of this Policy.

Email Preferences. If you do not want to continue receiving emails from us, you may opt-out by clicking the “unsubscribe” button at the bottom of our emails or by contacting us via any of the “Contact Us” details at the end of this Policy. Please provide your name and contact information in your request, and we will respond to your request in accordance with applicable law.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

Individual Rights. You may have certain rights relating to your personal data under local data protection laws. We honor individuals’ rights where required under applicable law, and, depending on the applicable laws, these rights may include the right to:

• Access your personal information;
• Know more about how we process your personal information;
• Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;
• Erase or delete your personal information;
• Restrict our processing of your personal information;
• Transfer your personal information to another controller, to the extent possible;
• Object to certain processing of your personal information;
• Opt-out of certain disclosures of your personal information to third parties;
• If you’re under the age of 16, or such other applicable age of consent, opt-in to certain disclosures of your personal information to third parties;
• Not be discriminated against for exercising your rights described above;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

All requests should be sent to the contact details noted in the “Contact Us” section of this Policy. Your personal information may be processed in responding to these rights.

European Union, European Economic Area, Switzerland, and the United Kingdom

Right of Access. You have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.

Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact Human Resources if you believe your information is not accurate or if it changes.

Right to Erasure. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected; (2) consent has been withdrawn in certain instances; (3) you have objected to the processing in certain instances; (4) the personal information has been unlawfully processed; (5) the personal information has to be erased for compliance with a legal obligation; and (6) the personal information was collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Restrict Processing. You have the right to restrict the processing of your data when (1) the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.

Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Right to Complain. If you believe we have not processed your personal information in accordance with applicable law, we encourage you to contact us using the contact information provided below. You may also have the right to make a complaint to an applicable Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities for residents of the EU or EEA is available at: https://edpb.europa.eu/about-edpb/board/members_en. UK residents may contact the UK Supervisory Authority here: https://ico.org.uk/make-a-complaint/data-protection-complaints/. Residents of Switzerland may contact the Federal Data Protection and Information Commissioner at https://www.edoeb.admin.ch/en/report-form-data-subjects. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

United States

Depending on where you live in the United States, you may have certain rights relating to your personal information. We honor these rights where required under applicable law. These may include the following:

Right to Confirmation and Access. Residents of certain states have the right to confirm whether we process their personal information and to access such personal information.

Right to a Copy. Residents of certain states have the right to access their personal information, including a right to obtain a copy of the consumer’s personal information in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance. Residents of certain states also have the right to receive a list of specific third parties to which we have disclosed the consumer’s personal data.

Right to Know. Residents of certain states have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing personal information; and (7) the categories of third parties to whom we disclose personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.

Right to Delete. Residents of certain states have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and, as applicable, notify any service providers and contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Right to Correct. Residents of certain states have a right to correct inaccuracies in their personal information, taking into account the nature of the personal information and the purposes for which we process the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.

Rights Regarding Sensitive Data. We only process sensitive data with your consent or where otherwise permitted by applicable law. Where you have provided consent to this processing, you may revoke your consent or opt out of the processing of your sensitive data at any time. For residents of California, this includes your CCPA right to limit the processing of sensitive personal information to that processing permitted by the CCPA. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.

Right to Opt-Out. Residents of certain states have the right to direct us to stop selling, and for residents of California, sharing, your personal information to third parties and to refrain from doing so in the future. Residents of certain states also have the right to opt of targeted advertising and profiling based on your personal information. In addition to the Submission Process below, you can opt-out of targeted advertising by adjusting your preferences in the cookies banner. For purposes of the CCPA, we do not sell or share personal information as defined under applicable law.

Submission Process. You may submit a request to exercise one of the above rights via a toll-free telephone call to 1-855-943-3441, by email to info@vortexcompanies.com, or via our online submission form. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.

Verification Process. We are required to verify the identities of those who submit requests to exercise certain of the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, mailing address, and/or telephone number. We will inform you if we cannot verify your identity.

• If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
• If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
• If we cannot verify the identity of the person making a request to delete, we may deny the request.
• If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. In such cases we may not be required to comply with the request or may request additional information reasonably necessary to verify the request.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we may not require these actions with respect to confirmed guardianship, conservatorship, power of attorney, or other protective arrangement in accordance with applicable law.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the above rights. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers, employees, applicants, or independent contractors for exercising their rights under applicable law.

Appeals Process. Residents of certain states have the right to appeal a refusal to take action on a request within a reasonable time after your receipt of the decision. You may submit an appeal to a decision on your request via a toll-free telephone call to 1-855-943-3441or by email to info@vortexcompanies.com. We will inform you of any action taken or not taken in response to the appeal, along with a written explanation of the reasons in support of the response.

Nevada

Nevada residents may submit a verified request to us at info@vortexcompanies.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

California

All terms used in this section shall have the meanings given in the CCPA, when applicable.

CCPA Notice at Collection. We collect and process personal information as described in the “How We Process Personal Information” section of this Notice. The relevant CCPA categories for this information are indicated above. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.

Data Practices During the Last 12 Months

• Personal Information Collected. We have collected the categories of personal information listed below during the preceding 12 months:
• Identifiers
• Categories Described in the Customer Records Statute
• Characteristics of Protected Classifications
• Commercial Information
• Internet or Other Electronic Network Activity Information
• Geolocation Data
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
• Professional or Employment-related Information
• Education Information
• Sensitive Personal Information
• Categories of Sources. We have collected personal information from you and through third parties, including public sources. If you are a job applicant or an employee, this also includes background check providers.
• Business and Commercial Purposes for Collecting. We have collected the categories of personal information listed above for the following purposes:
• Generally:
• Operate our Sites and business
• Provide our products and services
• Provide customer support
• Ensure the privacy and security of our Sites and operations
• Maintain our databases and back-ups
• Manage our relationships with you
• Serve you the content and functionality you request
• Enhance your experience and provide you with a more personal and interactive experience
• Communicate with you
• Respond to your request
• Complete transactions you request
• Keep records of our communications with you
• Determine user interests
• Develop new products and services
• Usage analytics purposes
• Process and complete payments and other transactions
• Detect fraud and prevent loss
• Establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings
• Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice
• Compliance with applicable laws
• Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate applicable law
• Collection, use, retention, or disclosure of information that is deidentified or aggregated
• Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us
• Job Applicants:
• Communicate with you
• Process your application with us
• Assess and document your qualifications for the requirements of the role for which you applied
• Background screening and vetting
• Confirm your identity and your entitlement to work in the applicable country
• Facilitate reimbursements
• Carry out our obligations under applicable law
• Personnel and human resources management
• Operations management
• Security management
• Legal and regulatory compliance
• Creation of anonymous/de-identified data
• Purposes that are consistent with, related to, and/or ancillary to the purposes and uses described
• Employees:
• Communicate with you
• Perform our relationship with you
• Assess and document your qualifications for the requirements of your role and promotions
• Background screening and vetting
• Confirm your identity and your entitlement to work in the applicable country
• Facilitate payments and reimbursements
• Provide your applicable benefits
• Take disciplinary, performance, or other related actions consistent with our internal policies and applicable law
• Facilitate investigations
• Monitor common workspaces
• Create ID badges
• Record meetings
• Account creation
• Workstation monitoring
• Protect our IT resources
• Carry out our obligations under applicable law
• Personnel and human resources management
• Operations management
• Security management
• Legal and regulatory compliance
• Creation of anonymous/de-identified data
• Purposes that are consistent with, related to, and/or ancillary to the purposes and uses described
• Personal Information Sold or Shared. We have not sold or shared categories of personal information during the preceding 12 months.
• Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months. We have disclosed each category of personal information to the following categories of third parties: (1) affiliates; (2) advisors (e.g., accountants, attorneys); and (3) service providers (e.g., data analytics, data storage, mailing, payment processing, administration, technical support).
• Identifiers
• Categories Described in the Customer Records Statute
• Characteristics of Protected Classifications
• Commercial Information
• Internet or Other Electronic Network Activity Information
• Geolocation Data
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
• Professional or Employment-related Information
• Education Information
• Sensitive Personal Information
• Business and Commercial Purposes for Disclosing. We have disclosed to the identified categories of third parties the categories of personal information listed above for the following purposes:
• Generally:
• Operate our Sites and business
• Provide our products and services
• Provide customer support
• Ensure the privacy and security of our Sites and operations
• Maintain our databases and back-ups
• Manage our relationships with you
• Serve you the content and functionality you request
• Enhance your experience and provide you with a more personal and interactive experience
• Communicate with you
• Respond to your request
• Complete transactions you request
• Keep records of our communications with you
• Determine user interests
• Develop new products and services
• Usage analytics purposes
• Process and complete payments and other transactions
• Detect fraud and prevent loss
• Establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings
• Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice
• Compliance with applicable laws
• Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate applicable law
• Collection, use, retention, or disclosure of information that is deidentified or aggregated
• Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us
• Job Applicants:
• Communicate with you
• Process your application with us
• Assess and document your qualifications for the requirements of the role for which you applied
• Background screening and vetting
• Confirm your identity and your entitlement to work in the applicable country
• Facilitate reimbursements
• Carry out our obligations under applicable law
• Personnel and human resources management
• Operations management
• Security management
• Legal and regulatory compliance
• Creation of anonymous/de-identified data
• Purposes that are consistent with, related to, and/or ancillary to the purposes and uses described
• Employees:
• Communicate with you
• Perform our relationship with you
• Assess and document your qualifications for the requirements of your role and promotions
• Background screening and vetting
• Confirm your identity and your entitlement to work in the applicable country
• Facilitate payments and reimbursements
• Provide your applicable benefits
• Take disciplinary, performance, or other related actions consistent with our internal policies and applicable law
• Facilitate investigations
• Monitor common workspaces
• Create ID badges
• Record meetings
• Account creation
• Workstation monitoring
• Protect our IT resources
• Carry out our obligations under applicable law
• Personnel and human resources management
• Operations management
• Security management
• Legal and regulatory compliance
• Creation of anonymous/de-identified data
• Purposes that are consistent with, related to, and/or ancillary to the purposes and uses described

No Financial Incentives. We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.

Notice of Right to Opt-out of Sale/Sharing. As a California resident, you have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell or share personal information as defined under applicable law.

Limited Use of Sensitive Personal Information. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against individuals for exercising their rights under the CCPA.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of the Website may make any changes to their information at any time by contacting us at info@vortexcompanies.com.

Links To Other Websites

This Policy only applies to the Sites. It does not apply to any websites, applications, or services provided by third parties.

Our Sites may include links to other websites and content from third parties. These links are provided solely for the convenience of our visitors. These links are to external resources and third parties that have their own privacy policies and with which we may not have a relationship. It may not always be clear to you which links are to external third-party resources. If you click on a third-party link, you will be redirected away from the Site. You can check the URL to confirm whether you have left the Site.

If you choose to visit any linked websites, we encourage you to review their privacy policies. We are not responsible for the use of these external sites, their content, or any products or services that may be offered through them. We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services, applications or websites. Any information provided by you or collected from you by a third party will be governed by that party’s privacy policy and terms of use.

Children

Our Sites and services are not directed to children under the age of 13, and we do not knowingly collect information online from children under the age of 13. No one under the age of 13 may access, browse, or use the Sites or provide any information to us online. If we learn that we have collected or received personal information from a child under the age of 13 online without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it. If you believe we have received any information from a child under the age of 13 online, please contact us using the “Contact Us” details provided at the end of this Policy.

For information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website.

Inquiries, Concerns Or Complaints

We have appointed a data protection officer in the European Union to oversee compliance with this Policy. If you have questions regarding this Policy or our handling of personal data, please contact our data protection officer by email at quin.breland@vortexcompanies.com or by mail at the following address: SVP – Shared Services, Vortex Companies, Unterwanger Str. 3, 87439 Kempten (Allgäu), Germany. You may also contact Vortex’s Compliance department at info@vortexcompanies.com.

If you are unsatisfied with our response to any issues that you raise with the data protection officer or the compliance department, you may have the right to make a complaint with the data protection authority (“DPA”) in your jurisdiction.

You may have the right, under certain conditions, to invoke binding arbitration for complaints regarding Data Privacy Framework compliance not resolved by any of the other Data Privacy Framework mechanisms. For additional information, go to https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

Changes To This Policy

Vortex reserves the right to amend this Policy from time to time consistent with applicable law and DPF requirements. When we do, we will revise the effective date at the top of the Policy. Any changes, updates, and modifications will be effective immediately upon posting. If we make material changes, we may also notify you through a notice on the Site’s homepage, and/or we may send you an email regarding the updates.

You should read this Policy carefully before using the Sites, and you should revisit this page periodically to become aware of the most recent privacy terms. Your use of any of the Sites after such changes have been posted constitutes your agreement to such changes and to our collection, use, and sharing of your information according to the then-current Policy. If you do not agree with this Policy, you should not use the Sites.

Contact Information

For more information, if you have any questions or concerns, or if you wish to exercise your rights or lodge a complaint with us, you may contact us by using the information below:

• By Telephone: 1-855-943-3441
• By Email: info@vortexcompanies.com
• In Writing: Vortex Companies, Attn: DPO, 18150 Imperial Valley Drive, Houston, Texas 77060

You may also contact our data protection officer by email at quin.breland@vortexcompanies.com or by mail at the following address: SVP – Shared Services, Vortex Companies, 18150 Imperial Valley Drive, Houston, Texas 77060.