Supplemental California Law Disclosure

In these Supplemental California Law Disclosures (“California Disclosures”), we, TheStudio C, LLC (The Studio C), disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws, and supplement the disclosures in our privacy statement. These California Disclosures are effective January 1, 2020. Individuals who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this document.

I. California Consumer Privacy Act (CCPA) Privacy Policy

A. Who and what information is subject to this CCPA Privacy Policy?

California residents are protected as “consumers” by the CCPA with respect to personal information. A number of statutory exceptions apply under the CCPA. As a result, this CCPA Privacy Policy does not apply to the following:

1. personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transactions with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency;

2. personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business;

3. personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; and

4. personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.

B. Supplemental CCPA Disclosures

We provide additional disclosures about consumer rights and our personal information handling practices in the preceding twelve months.

1. Right to Know About Personal Information Collected, Disclosed, or Sold

We describe here the personal information we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to admin@thestudioc.org and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access. We will ask that you provide certain information to verify your identity. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

2. Our Personal Information Handling Practices in 2019

Category of personal information	We collected such personal information for the following purposes:	We collected such personal information from the following categories of sources:	We shared such personal information with the following categories of third parties:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	To enable you to access and use our services To respond to your inquiries and requests To send you information regarding our services and administrative information To manage, evaluate, improve and administer our online service To develop new products and services To perform contractual obligations To comply with legal obligations To defend our legal interests	Directly from our client	Service providers including companies we retain to provide hosting, marketing, data enhancement, billing and collections, analytics, support, technical, operational, security or other services to us Government entities as required by applicable law Other recipients at your direction or with your consent
Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number, or, in the case of HIPAA, medical information.	Same as above	Same as above	Same as above
Characteristics of protected classifications under California or federal law, including 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	Same as above	Same as above	Same as above

3. Disclosures of Personal Information; No Sale We have not disclosed any categories of California residents’ personal information.

4. Right to Request Deletion of Personal Information You have a right to request the deletion of personal information that we collect or maintain about you as an independent controller. To submit a request to delete personal information, please submit an email request to admin@thestudioc.org and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA. We will ask that you provide certain information to verify your identity. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

5. Right to Opt-Out of the Sale of Personal Information You have the right to opt-out of the sale of your personal information by a business. We do not, and will not, sell your personal information.

6. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights You may not be discriminated against because you exercise any of your rights under the CCPA.

7. Authorized Agent You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 1 and 4 above:

• Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to The Studio C, LLC, Attention: Privacy Department, 6635 W. Happy Valley Rd, Glendale, AZ 85310; and Characteristics of protected classifications under California or federal law, including 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. Same as above Same as above Same as above
• Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

II. Shine the Light Law
The California law known as the “Shine the Light” law permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not share any of your personal information with third parties for their direct marketing purposes.

III. California Children’s Privacy Rights
A user under the age of 18, or the parent of a user under the age of 18, residing in California, is entitled to request removal of content or information the user posted on our services. If you would like to request removal of your or your child’s content or information, please email us at admin@thestudioc.org for assistance, or you can delete specific information (or delete your or your child’s account) directly. Please note that removal of your content or information does not ensure complete or comprehensive removal, as there may be de-identified or recoverable elements of your content or information on our servers in some form. Additionally, we will not remove content or information that we may be required to retain under applicable federal and state laws.

IV. Contact for More Information
If you have questions or concerns regarding our privacy policy or practices, you may contact us at: privacy@thestudioc.org, The Studio C, LLC, 6635 W. Happy Valley Rd, Glendale, AZ 85310.

Last Revised: January 22, 2021