California Commerce Club, Inc. (the “Company”, “us”, or “we”) has developed this privacy policy out of respect for the privacy of individuals consumers. This policy describes the Personal Information we collect, use, and disclose, both offline and online, about individual consumers who visit or interact with this website, visit any of our offices, stores, facilities, or locations, purchase or inquire about any of our products or services, or otherwise interact or do business with us. “Personal Information” means any information that identifies, relates to, describes, references, or can reasonably identify an individual.

Whenever you visit our website, we will collect some information from you automatically simply by you visiting and navigating through this site, and some directly from you when you voluntarily submit information using a form on the website, enroll in or subscribe to our newsletter or marketing communications, request information, or use any of the other interactive portions of our website. We may also collect some information about you from our vendors and/or third parties that provide services to us. For more information on the categories of sources from which we collect Personal Information, see the section titled “Sources of Personal Information” below.

Additionally, whenever you communicate, interact, or do business with us, we will collect Personal Information from you or about you in the course of our interaction or dealings with you, whether online or at any of our physical locations or facilities.

This policy does not apply to information collected from or about job applicants regarding their application for employment or candidacy. If you are a job applicant, click HERE for our Job Applicant Notice and Privacy Policy.

This policy does not apply to our current and former employees and their family members, dependents, and beneficiaries. If you are a California resident (who is a current or former employee of the Company or a family member, dependent, or beneficiary of any of our current or former employees), you may request access to our Employee Privacy Policy by sending an email to dataprivacy@commercecasino.net.

Based on your specific transactions and interactions with us or our website, we will or may collect, and we have in the last 12 months collected, the following categories of Personal Information from or about you. For each category of information, we identify the categories of third parties, service providers, and contractors to whom we have disclosed, sold, and/or shared the information in the last 12 months. The examples provided in each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you a meaningful understanding of the types of information that may be collected within each category.

Category	Personal Identifiers
Examples	Name, alias, vehicle license plate number, date of birth.
Disclosed To in Last 12 Months	Financial institutions Marketing support vendors and vendors that support managing or hosting the website Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, or phone Data analytics vendors, including Google Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants Insurance carriers, administrators, and brokers Corporate customers (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services) Our affiliated entities, including parent entities, subsidiaries, and affiliated entities
Sold To or Shared With	For data collected through our website, we sell some of this data to Data Analytics Vendors (not for monetary consideration but for other valuable consideration), and we also share the data with Data Analytics Vendors for cross-context behavioral advertising. Our Data Analytics Vendors include Google. For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.

Category	Contact Information
Examples	Home, postal or mailing address, email address, home phone number, cell phone number.
Disclosed To in Last 12 Months	Financial institutions Marketing support vendors and vendors that support managing or hosting the website Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, or phone Data analytics vendors, including Google Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants Insurance carriers, administrators, and brokers Corporate customers (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services) Our affiliated entities, including parent entities, subsidiaries, and affiliated entities
Sold To or Shared With	For data collected through our website, we sell some of this data to Data Analytics Vendors (not for monetary consideration but for other valuable consideration), and we also share the data with Data Analytics Vendors for cross-context behavioral advertising. Our Data Analytics Vendors include Google. For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.

Category	Commercial Transactional Data
Examples	Information regarding products or services provided, purchasing history.
Disclosed To in Last 12 Months	Financial institutions Marketing support vendors and vendors that support managing or hosting the website Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, or phone Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants Insurance carriers, administrators, and brokers Corporate customers (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services)
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.

Category	Internet Network and Computer Activity
Examples	Date and time of your visit to this website; webpages visited; links clicked on the website; session identifiers; browser ID; browser type and characteristics; device ID and characteristics or attributes; referring URLs; mobile phone make, model and serial number; mobile service provider; operating system; form information downloaded; domain name from which our site was accessed; search history; interaction-level telemetry; cookies; and internet or other electronic network activity information related to usage of Company networks, servers, intranet, or shared drives, as well as Company-owned computers and electronic devices, including system and file access logs, security clearance level, browsing history, search history, and usage history.
Disclosed To in Last 12 Months	Marketing support vendors and vendors that support managing or hosting the website Data analytics vendors, including Google Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants
Sold To or Shared With	For data collected through our website, we sell some of this data to Data Analytics Vendors (not for monetary consideration but for other valuable consideration), and we also share the data with Data Analytics Vendors for cross-context behavioral advertising. Our Data Analytics Vendors include Google. For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.

Category	Form and other Electronic Submission Information
Examples	Information submitted through the website, including any webforms and search bar queries.
Disclosed To in Last 12 Months	Marketing, tracking, and retargeting vendors and vendors that support managing or hosting the website Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, or text/SMS, phone Social media platforms Consulting and investigation firms, including HR consultants, safety consultants, and workplace investigators Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants
Sold To or Shared With	For data collected through our website, we sell some of this data (not for monetary consideration but for other valuable consideration) to Data Analytics Vendors, and we also share the data with these third parties for cross-context behavioral advertising. Our Data Analytics Vendors include Google. For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.

Category	Geolocation Data
Examples	IP address, GPS location, and latitude and longitude.
Disclosed To in Last 12 Months	Data analytics vendors, including Google Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants
Sold To or Shared With	For data collected through our website, we sell some of this data to Data Analytics Vendors (not for monetary consideration but for other valuable consideration), and we also share the data with Data Analytics Vendors for cross-context behavioral advertising. Our Data Analytics Vendors include Google. For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.

Category	Online Portal and Usage Information
Examples	Username and password, account history, usage history, file access logs, security clearance level, and any information submitted through the account.
Disclosed To in Last 12 Months	Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.

Category	Audio, Electronic, Visual, or Similar Information
Examples	Your image when recorded or captured in surveillance camera footage or in pictures taken on our premises, at our events, or that you share with us; video and audio recordings of calls and virtual meetings as disclosed to you at the time of the call.
Disclosed in the Last 12 Months To	Consulting and investigation firms, including human resources consultants, safety consultants, and workplace investigators Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants
Sold To or Shared With	Not sold for monetary or other valuable consideration. Not shared for cross-context behavioral advertising.

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company may collect from or about consumers:

1. Account Information (your account log-in, in combination with any required security or access code, password, or credentials allowing access to the account)
2. Protected Classifications (citizenship or immigration status)
3. Geolocation Data (IP address and/or GPS location, latitude & longitude)
4. Data of consumers under 16 years of age

Personal Information does not include:

• Publicly available information from government records.
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media.
• Information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
• Deidentified or aggregated information.

We may collect your Personal Information from the following sources:

• You the consumer when you visit the website and voluntarily submit information through forms on the website or social media, when you visit any of our stores or physical locations, when you purchase or inquire about any of our products or services. Our employees, contractors, vendors, suppliers, guests, visitors, other consumers, and customers based on your interactions with them (if any)
• We utilize cookies to automatically collect information about our website visitors
• Lead generators and referral sources
• Social media platforms
• Third party customer databases
• Automated License Plate Recognition (ALPR) systems
• Our affiliated entities, including parent entities, subsidiaries, and affiliated entities

We may disclose, sell, or share your Personal Information to/with the following categories of service providers, contractors, or third parties:

• Financial institutions
• Marketing support vendors and vendors that support managing or hosting the website
• Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, phone, or that record, transcribe, summarize, or process phone calls and meetings
• Data analytics vendors, including Google
• Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants
• Insurance carriers, administrators, and brokers
• Corporate customers (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services)
• Automated License Plate Recognition (ALPR) vendors
• Our affiliates, including parent entities, subsidiaries, and affiliated entities

We may collect, use, and disclose your Personal Information for any of the following business or commercial purposes:

1. To fulfill or meet the purpose for which you provided the information, or a purpose reasonably associated with the context in which you provided the information and consistent with reasonable consumer expectations.
2. To provide you or our customers with the requested products or services.
3. To process, complete, and maintain records on transactions.
4. To retain your selection for Text opt in/opt out to ensure customers who opted out are not sent any text messages.
5. To schedule, manage and keep track of customer appointments.
6. To maintain records of when customers decline a service or sale.
7. To respond to consumer inquiries, including requests for information, customer support online, phone calls, and in-store inquiries.
8. To provide interest-based and targeted advertising.
9. To comply with our contractual obligations to our marketing partners and vendors.
10. To engage in corporate transactions, including mergers, acquisitions, and joint ventures, as well as due diligence in proposed or pending corporate transactions.
11. To contact you by email, telephone calls, mail, SMS, or other equivalent forms of communication regarding updates or informative communications related to the functionalities, services, or other information you requested or asked the Company to provide to you.
12. To improve user experience on our website.
13. To understand the demographics of our website visitors.
14. To detect security incidents.
15. To debug, identify, and repair errors that impair existing intended functionality of our website.
16. To protect against malicious or illegal activity and prosecute those responsible.
17. To verify and respond to consumer requests.
18. To prevent identity theft.
19. To conduct risk assessments under applicable consumer privacy laws.
20. To conduct cybersecurity audits under applicable consumer privacy laws.
21. To conduct internal audits, compliance assessments, data analytics, and quality assurance activities.
22. To engage in strategic planning and operational efficiency.

We do NOT and will not sell or share your Personal Information in exchange for monetary consideration. However, we may sell or share some of your information to third parties for other valuable consideration, as noted in the table above.

We may sell or share your Personal Information for the following business or commercial purposes:

1. For marketing activities, including targeting and retargeting our ads based on your activity on our website.
2. To understand the demographics of our website users and receive reports on website traffic.
3. To improve user experiences when using our website.

Other than these exceptions, we do not and will not disclose your Personal Information to any third party in exchange for monetary or other valuable consideration or share your Personal Information for cross-context behavioral advertising.

You have the right to tell us NOT to sell or share your Personal Information. You have the full and free right to opt-out of our disclosure of your Personal Information to any third parties where the disclosure constitutes “selling” or “sharing” as defined by the California Privacy Rights Act. You may exercise your right to opt-out without fear of discrimination for doing so. To opt-out of our selling or sharing of your information, meaning, we will not disclose your information to third parties for any monetary or other valuable consideration, you can do any of the following: Click HERE to be taken to an online opt-out submission form. Visit California Commerce Club, Inc.’s website at: https://commercecasino.com/. Click on “Do Not Sell or Share My Personal Information” to be taken to an online submission form. Visit any California Commerce Club, Inc. location in California to request a paper opt-out submission form. You can use a Global Privacy Controls (GPC) signal. California Commerce Club, Inc. will process opt-out preferences from GPC signals, which are in formats commonly used and recognized by businesses, such as an HTTP field header, as requests to opt-out of sale or sharing. The GPC signal opt-out will only apply to the browser you are using on your device; it will not apply to other browsers and/or devices to which GPCs are not activated or to offline sales. We will display your opt-out preference signal under the “Consent Preferences” located in the bottom left-hand corner at: https://commercecasino.com/ If you are unable to submit an opt-out through any of the above methods, please call our toll-free privacy line at 877-927-2150 for assistance and a representative will assist in meeting your needs. You can have an authorized agent submit a request on your behalf. To submit an opt-out through use of an authorized agent, you must provide that agent with written permission signed by you to submit an opt-out on your behalf, except when using an opt-out preference signal. The authorized agent may call our toll-free privacy line at 877-927-2150 to make the opt-out request and for directions for submitting the proof of authorization and the authorized agent’s proof of identification to the Company. We maintain the right to deny any request from an authorized agent that does not submit sufficient proof that they have been authorized by you to act on your behalf. A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt-out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

Opt-out preference signals provide consumers with a simple and easy-to-use method by which to exercise the right to opt-out of the selling and sharing of their information. Global Privacy Controls (GPC) is a user-enabled opt-out preference signal which can communicate a user’s “Do Not Sell or Share” request on behalf of the person or device. We will process opt-out preferences from GPC signals which are in formats commonly used and recognized by businesses, such as an HTTP field header. We will treat a consumer’s use of GPCs as a valid request to opt-out of the selling and sharing of information for that browser. We currently do not connect browser use to particular consumers and, as such, you will need to use GPCs on all browsers in which you access our website and use our opt-out form to opt-out of offline sales.

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals or other mechanisms (with the exception of GPCs) that provide a choice regarding the collection of personal information about activities over time and across different websites or online services. We encourage users who have DNTs to use GPCs.

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

We do NOT and will not use or disclose your sensitive personal information for any purpose that gives rise to a right to limit the use or disclosure of your Sensitive Personal Information under the CCPA.

We will retain each category of Personal Information for as long as we continue to have a legal or business need to retain it consistent with the purposes for which the information was collected. Your Personal Information may be stored or maintained in a variety of different records, files, databases, and information systems some of which are controlled or managed by vendors. As a result, we are unable to predict at the point of collection of your information how long the information will be retained, as it depends on many factors. In deciding how long to retain each category of Personal Information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statute of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.

Because the law prescribes minimum periods for retention of certain records, some records will be retained for at least the duration of the required period plus a certain number of years. Retention is often measured from occurrence of a triggering event but we may also measure the retention period from either (1) the date the record or data was collected, created, or last modified, (2) the date of the particular transaction to which the record or data pertains, or (3) another triggering event that is determined to be reasonable and appropriate based on the nature of the data and the legal/business needs for its continued use.

If the business purposes for collecting the Personal Information, and legal reasons for retaining the Personal Information, have both expired, we will purge the information in a secure manner.

From time to time, we may enter an arrangement with another company that is not owned by or affiliated with us to provide additional products or services. These arrangements may include business partners, sponsors, and co-branded online services (referred to here as “co-branded services”). Any information, including Personal Information, that you provide on one of these co-branded services may be shared with these partners. By participating in activities or providing your information for these co-branded services, you consent to our providing your information to those partners. Separate privacy policies may apply to these partners’ uses of your Personal Information.

We may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose.

In the event we sell or transfer a particular portion of our business assets, information of consumers may be one of the business assets transferred as part of the transaction. If substantially all of our assets are acquired, information of consumers may be transferred as part of the acquisition.

By subscribing to our SMS program, you agree to receive recurring texts from the Company for purposes that may include two-factor authentication, customer service, account notifications, marketing communications, and/or security alerts. You provide your phone number to us voluntarily and solely so we can send you these communications. Your phone number is disclosed only with our SMS service provider Active Campaign and not with third parties or affiliates for marketing purposes.

We may disclose specific Personal and/or Sensitive Personal Information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.

Our website may store or retrieve information on your browser, mostly in the form of cookies. A cookie is a small piece of data (text file) that a website – when visited by a user – places on the user’s device to remember information about the user.

This type of cookie is set by us and is referred to as a “first-party cookies.” Our website uses first-party cookies primarily to make the website work as you expect it to. For example, we use the information we collect through first-party cookies to allow you to navigate between pages efficiently, analyze how well our website is performing, and understand the content that you spent the most time reviewing. In some cases, we use first-party cookies to store information that we use for targeted advertising.

We also incorporate cookies and similar technologies, such as pixels, tags, and web beacons, from outside our website’s domain (“third-party cookies”). Third-party cookies gather information to enable our vendors to provide a range of services to us, including targeted advertising and measuring the success of our advertising campaigns.

Below is a detailed list of the categories of first- and third-party cookies we use on our website. You can prevent the collection of data by non-essential performance, functional, and/or marketing cookies by clicking on the “Consent Preferences” icon located in the bottom left-hand corner in our website footer and toggling off the related functionality.

How we use cookies

We make use of cookies under the following circumstances and for the following reasons:

• Provide you with services available through the website and to enable you to use some of its features
• For security related purposes
• Authenticate users and prevent fraudulent use of user accounts
• Identify if users have accepted the use of cookies on the website
• Compile data about website traffic and how users use the website to offer a better website experience
• Understand and save visitor preferences for future visits, such as remembering your login details or language preference, to provide you with a more personal experience, or to avoid you having to re-enter your preferences every time you use the website
• Track your browsing habits to enable us to show advertising which is more likely to be of interest to you, including advertising by third parties on our website

Essential Cookies

Essential cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but blocking these cookies will prevent the website from working correctly or might prevent the Website from working at all.

Non-Essential Cookies

Non-Essential cookies are not essential to the website functionality but serve some other unique purpose in three subcategories:

1. “Performance” cookies (sometimes referred to as static cookies) collect information about the user’s behavior on the website without collecting personal information, for example:
   • Pages the user visits.
   • Ads the user views.
   • Ads or site features that the user clicks.
2. “Functional” cookies (sometimes called preference cookies) track and remember the user’s preferences and past choices on the website to provide a personalized user experience. For example, functional cookies can collect:
   • Usernames
   • Passwords
   • Regions
3. “Targeting” cookies (sometimes called preference cookies) can track:
   • Content the user views
   • Links the user follows
   • The user’s browser and device information and IP address

Please note: Organizations can use targeting cookies to track and influence users by building user profiles or displaying advertisements.

Information on Some of the Cookies in Use on our Site

For information on some of the cookies we use on our site and apps, please review the policies from some of our vendors:

• Google Analytics

Cookie Management

You can control and manage cookies associated with your browser. If you are interested in controlling and managing cookies from your browser including any set by our Website, please refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on different ways to configure your browser’s cookie settings.

If you want to clear all cookies left behind by the websites you have visited, here are links where you can download three third party programs that clean out tracking cookies.

• http://www.lavasoftusa.com/products/ad-aware_se_personal.php
• http://www.spybot.info/en/download/index.html
• http://www.webroot.com/consumer/products/spysweeper/

You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even block the website. You can prevent saving of cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our website when use of cookies is deactivated. Check the settings of your browser. Below you can find some guidance:

• Safari
• Opera
• Internet Explorer
• Google Chrome
• Mozilla

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals, with the exception of Global Privacy Controls as explained above in the section of this policy on “Opt-Out Preference Signals”.

You can adjust your advertising preferences on mobile devices through your device settings. Below you can find some guidance based on your type of mobile device:

• Apple
• Android

DAA

Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA), which maintains a self-regulatory program along with a website where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by this organization’s participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/.

• To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering found here: https://youradchoices.com/appchoices.

Non-Participant Opt-Out Options

• Some vendors do not participate in the DAA or other self-regulatory programs for online behavioral advertising or have developed their own processes for allowing consumers to opt-out: https://branch.app.link/optout
• Some devices and apps do not have access to web-based browser cookie opt-outs. To learn more about the advertising opt-outs provided by your mobile device’s operating system (like iOS and Android) or the device manufacture, click here.

Our website contains links to other sites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Privacy Policy of any site you visit via a link from our website.

The personal data record created through your registration with our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.

The protection of the information that we collect about visitors to our websites is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:

• We keep automatically collected data and voluntarily collected data separate at all times.
• We use internal encryption on all data stores that house voluntarily captured data.
• We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
• We restrict access to private information to those who need such access in the course of their duties for us.

We do not target, market to, or offer our products or services to consumers outside of the United States. You agree not to submit your personally identifiable information through the website if you reside outside the United States.

If you are a California resident, you have the following rights pursuant to the CCPA:

1. Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected about you, (2) the categories of sources from which the personal information was collected, (3) the business or commercial purpose for collecting, selling, or sharing this information, (4) the categories of third parties with whom we share or have shared your personal information, (5) the categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared, and (6) the categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose;
2. Right to Access. The right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected from or about you;
3. Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
4. Right to Correct. The right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you;
5. Right to Opt-Out. The right to opt-out of the selling or sharing of your personal information to third parties;
6. The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
7. The right to not be retaliated against for exercising any of the above rights.

You can submit any of the above types of consumer requests through any of the options below:

1. Submit an online request on our website at https://commercecasino.com/.
2. Call our privacy toll-free line at 877-927-2150.
3. Complete a paper form, which can be requested at the Guest Services Desk, located at California Commerce Club, Inc., 6131 Telegraph Road, Commerce, California 90040.

How We Will Verify That it is Really You Submitting the Request

If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us.

Responding to Your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests

Upon receiving a verifiable request from a California resident, we will confirm receipt of the request no later than 10 business days after receiving it. We endeavor to respond to a verifiable request within 45 calendar days of its receipt. If we require more time (up to an additional 45 calendar days, or 90 calendar days total from the date we receive your request), we will inform you of the reason and extension period in writing. 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.

We do not charge a fee to process or respond to your verifiable 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.

For a request to correct inaccurate Personal Information, we will accept, review, and consider any documentation that you provide, and we may require that you provide documentation to rebut our own documentation that the personal information is accurate. You should make a good-faith effort to provide us with all necessarily information at the time that you make the request to correct. We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we shall inform you of our decision not to comply and provide an explanation as to why we cannot comply with a request, if applicable.

Responding to Your Request to Opt-Out of the Selling or Sharing of Your Personal Information

We will act upon a consumer request to opt-out within 15 days of its receipt. We will notify all third parties to whom we have sold or shared Personal Information of your request and instruct them to comply with the request within the same time frame. We will notify you when this has been completed by mail or electronically, at your option.

A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt-out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

If You Have an Authorized Agent:

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either: (a) execute a valid, verifiable, and notarized power of attorney; or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.

Other California Privacy Rights

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide you with a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email dataprivacy@commercecasino.net, or write to us at the address listed below. Please mention that you are making a “California Shine the Light” inquiry.

By using this website, you consent to all terms and conditions expressed in this Privacy Policy.

As our services evolve and we perceive the need or desirability of using information collected in other ways, we may amend this Privacy Policy. We encourage you to check our website frequently to see the current Privacy Policy in effect and any changes that may have been made. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy and the revised effective date on this website. Please check back here periodically or contact us at the address listed at the end of this Privacy Policy.

This policy is in a form that is accessible to consumers with disabilities.

This website is owned and operated by California Commerce Club, Inc. If you have any questions about this Privacy Policy, please contact us at dataprivacy@commercecasino.net or call 877-927-2150.

This policy was last updated April 30, 2026.