theSkimm, Inc.

California Privacy Rights Act Notice

Last Updated: January 1, 2023 

The California Privacy Rights Act (“CPRA”) grants residents of the State of California (“consumers”) and households located in California, certain rights regarding their Personal Information. This Notice (the “CPRA Notice”) supplements the theSkimm Privacy Policy and applies to the Personal Information of consumers and/or households that is collected and/or processed (online and/or off-line) by or on behalf of theSkimm, Inc. (“theSkimm” “we” “us” or “our”). All capitalized terms herein have the meanings given in the CPRA or the Privacy Policy. We address Personal information associated with theSkimm personnel and job applicants separately. 

In the event of any conflict between this CPRA Notice and terms in the Privacy Policy, the provision that is more protective of your Personal Information shall control to the extent of such conflict. If you have any questions about this CPRA Notice or whether any of the following rights apply to you, please contact us at   privacy@theskimm.com with the subject line “California Privacy Request.”

1.     Your Rights and Choices

The CPRA provides consumers and households with specific rights regarding their personal information. theSkimm will usually be a business processing your Personal Information. If theSkimm is acting as a service provider or contractor on behalf of another business, please contact the business that collected your Personal Information in the first instance regarding your rights under the CPRA. 

·      Right to Know About Your Personal Information 

You have the right to request that we disclose the following kinds of information to you about our collection, disclosure, sale, and use of your Personal Information: 

o   Categories of Personal Information: We have or might have collected or otherwise obtained the categories of Personal Information from or about consumers and their devices that are referenced in the Privacy Policy.

o   Categories of Sources: We have or might have collected the categories of Personal Information listed above from the following categories of sources referenced in the Privacy Policy.

o   Categories of Business or Commercial Purposes: We collect the categories of Personal Information listed above for the business or commercial purposes referenced in the Privacy Policy.

o   Categories of Third-Party Recipients: We have or might have disclosed the categories of Personal Information listed above to the third-party recipients referenced in the Privacy Policy.

o   Categories of Personal Information Sold or Shared: We have or might have sold or shared the following categories of Personal Information with the following third parties:

o   Unique personal identifiers (e.g., device identifiers; internet protocol address; mobile ad identifiers, and similar technology); 

o   Other forms of persistent or probabilistic online identifiers; and

o   Internet and other electronic network activity information (e.g., information regarding your interaction with our website).

You have the right to opt out of the Sale or Sharing of your Personal Information. For information on how to do so, see Section 2 below. 

o   Categories of Personal Information Disclosed for a Business Purpose: We have or might have disclosed the following categories of Personal Information to the third-party recipients referenced in the Privacy Policy for the following business purposes:

o   Specific Pieces of Personal Information

If you would like to know the specific pieces of Personal Information that we have collected about you, please contact us as described in Section 2 below. You may exercise this right up to two times in any 12-month period. We will provide you with the information collected about you since January 1, 2022.

·      Right to Request Deletion

You may have the right to request deletion of your personal information. We will honor such request but might not be able to fulfill your request if we (or our service providers) are required to retain your personal information. Examples of such exceptions are:

o   Completing a transaction or performing a contract we have with you; 

o   Detecting and addressing data security incidents, and repairing or upkeep of our IT systems;

o   Protecting against fraud or other illegal activity; 

o   Complying with applicable law or a legal obligation, or to exercise rights under the law (e.g., the right to free speech); or

o   Using your Personal Information internally to improve our Services.

·      Right to Request Correction

You may have the right to request that we correct inaccurate Personal Information that we maintain about you. We will honor such request but might not be able to fulfill your request if it is impossible to do so or would involve disproportionate effort, or if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive.

·      Right to Opt-Out of the Sale and/or Sharing of Personal Information

You may have the right to opt out of the sale and/or sharing of personal information. 

·      Right to Limit the Use and Disclosure of Sensitive Personal Information

You may have the right to limit the use and disclosure of sensitive personal information. 

2.         Exercising Your Privacy Rights

To exercise the rights described in Section 1 above, please submit a verifiable consumer request to us entitled “California Privacy Request,” by using the following methods:

·      Call us at: (332) 201 – 3296

·      Email us at: privacy@theskimm.com   

·      Click  request form and follow instructions

·      Submit to this address: 53 W. 23^rd Street, 8^th Floor, New York, NY 10010

·      What we need to know to fulfill your request

The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) 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 related to you. Typically, accounts associated with an email address will require verification of the email address, as well as a description of the requested user rights or regulations invoked. Making a verifiable consumer request does not require you to create an account with us. 

If you submit a request to know or delete your Personal Information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.

o   How you will hear back from us

We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. 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. 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 may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

3.         Right to Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties (except for financial incentives permitted by the CPRA, see below), (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services. 

4.         Other California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of Personal Information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. In order to submit such a request, please contact us at privacy@theskimm.com . 

5.         Changes to this CPRA Notice

This CPRA Notice is effective as of the date of the Last Update stated at the top of this CPRA Notice. We may change this CPRA Notice from time to time with or without notice to you. By visiting or accessing the Websites or the Services, or otherwise engaging or interacting with us after we make any such changes to this CPRA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CPRA Notice in current effect. Please refer back to this CPRA Notice on a regular basis. 

6.         Contact Information

If you have any questions or comments about this CPRA Notice, the ways in which we collect and use your information, your choices, and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: 

• Phone: (332) 201 - 3296
• Email us at: privacy@theskimm.com  
• Submit to this address: 53 W. 23^rd Street, 8^th Floor, New York, NY 10010