California Privacy Policy

This policy was last modified November 6, 2024

• About this California Privacy Policy

This California Privacy Policy (this “California Privacy Policy”) supplements the information contained in the Privacy Policy of VaynerX with additional disclosures required by the California Consumer Privacy Act, as amended from time to time (“CCPA”) and any other applicable California privacy laws that apply only to residents of California. Any terms defined in the Privacy Policy or in the CCPA have the same meaning when used in this California Privacy Policy. In instances where the information contained in the Privacy Policy and this California Policy differs, then this California Policy takes precedence.

By using the Site, you agree to the practices described in this California Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this California Privacy Policy periodically. Updates will be referenced by the “Last Modified” date shown above.

• Definition of Personal Information for Purposes of this California Privacy Policy

As defined in the CCPA, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

• Notice of Collection of Personal Information

We may collect and may have collected in the last 12 months the following categories of Personal Information:

Category	Examples
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.
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.
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).
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Online activity; Internet or other electronic network activity information.	Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
Professional or employment-related information.	Current or past job history or performance evaluations.
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.
Inferences drawn from any of the information.	Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Please note that the categories and examples listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact collected about every Site visitor, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if you provided such Personal Information when applying for a job via the Site, but not if you submitted a general inquiry or just visited the Site.

We collect the categories of Personal Information listed above from the following categories of sources:

• Directly from you when you provide it to us.
• Indirectly and automatically from your devices. For example, when you visit or interact with the Site.
• Directly from our parents, affiliates, subsidiaries, and other companies under common control and ownership.
• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• From vendors who provide services to us.
• From other third parties.  For example, sponsors or event partners in connection with certain ticketed events, social networking providers, and advertising companies. If you do not want us to collect information from social networks, you should review and adjust your privacy settings on those networks as desired before linking or connecting them to the Site.

• Use and Disclosure of Personal Information

We may use and disclose the Personal Information as described in our Privacy Policy, in Sections 2 and 4, respectively, for business and commercial purposes.

• Sale of Personal Information

We do not and will not sell your Personal Information.

• Your California Consumer Privacy Rights

The CCPA provides residents of California with the following rights regarding their Personal Information:

• Right to Know About Personal Information Collected or Disclosed: You have the right to request, twice in a 12-month period, that we disclose certain information to you about our collection, use, and disclosure of your Personal Information over the last 12 months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you within the time required by the CCPA, the relevant information.
• Right to Request Deletion of Personal Information: You have the right to request that we delete any of your Personal Information that we collected from you and retain, subject to certain exceptions. Once we receive and confirm a verifiable consumer request from you, we will delete (and direct our service providers to delete) your Personal Information from our records within the time required by the CCPA, unless an exception applies.
• Right to Opt-Out of the Sale of Personal Information: You have the right to opt-out of the sale of your Personal Information. We do not and will not sell your Personal Information.
• Right to Correct: You have the right to correct any of the personal data we have collected from you.
• Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights: You have the right not to receive discriminatory treatment by us for the exercise of any your CCPA rights. We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your California Privacy Rights

To exercise any of the above rights, please submit a request by completing the following form, or contact us by email at privacy@vaynerx.com.

Please note that requests submitted through the form may be processed more efficiently than requests submitted by other methods. Please note that in order to process your request, we may need to request additional information from you to verify your identity or assess the scope of your request.

Verification of Requests

When you submit your request, we will reasonably verify your identity prior to processing your request to access or delete any Personal Information we may hold about you. You must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person.

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

Making a Request through an Authorized Agent

You may submit a request through an authorized agent. The agent will need to state that they are acting on your behalf when making the request, have proof of the authority to act on your behalf, and be prepared to provide sufficient Personal Information to enable us to identify you in our records.

• Contact Us

If you have any questions about this California Privacy Policy, please email us at privacy@vaynerx.com or write to us at the following address:

VaynerX, LLC

Attention: Legal Department; California Privacy Policy Inquiry

10 Hudson Yards, 25th Floor

New York, NY 10001