PRIVACY POLICY

This privacy policy (“Privacy Policy”) describes how CodeFuel Ltd. D/B/A a subsidiary of Perion Network Ltd. (“Perion Group” and “CodeFuel”, “we”, “us”, or “our” respectively) collects, uses and discloses certain information, including Personal Data (as defined below); and the choices you can make about our use of that information.

CodeFuel is a technology and media company that provides a range of services. We display advertisements, sponsored content or search results provided to us by our search feed partners or advertisers (“Services”). The Services may be offered to by other companies including through apps, sites or products that display to you search results and ads by linking to our Services, or by our own developed extensions, software or apps that display the ads and search results through the Services (“CodeFuel Apps” or “Apps”).

This Privacy Policy applies when you browse our website: https://www.codefuel.com/ (“Visitor”, “you” or “your”). This Privacy Policy is meant to help you understand what information we collect, why we collect it, how we safeguard it and how you can control it by exercising your rights.

This Privacy Policy forms an integral part of our website Terms of Use, therefore, capitalized terms used herein but not defined, shall have their respective meaning under the Terms of Use.

Note you are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.

This Privacy Policy governs the use, processing and sharing of Personal Data that applies to all individuals world-wide, however, certain jurisdictions require that applicable disclosures will be provided in a certain way and format, and therefore additional notices will apply as follows:

Additional Information to California Residents: In the event you are a California resident– please also review our CCPA Privacy Notice to learn more about our privacy practices with respect to the California Consumer Privacy Act.

Additional Information to Colorado Residents: In the event you are a Colorado resident – please also review our CPA Notice to learn more about our privacy practices and your rights under the Colorado Privacy Act.

Additional Information to Connecticut Residents: In the event you are a Connecticut resident– please also review our CDPA Notice to learn more about your rights under the Connecticut Data Privacy Act.

Additional Information to Utah Residents: In the event you are a Utah resident – please also review our UCPA Notice to learn more about your rights under the Utah Consumer Privacy Act.

Additional Information to Virginia Residents: In the event you are a Virginia resident– please also review our VCDPA Notice to learn more about our privacy practices and your rights under the Virginia Consumer Data Protection Act.

 

1) POLICY AMENDMENTS

We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice if these changes are material and, where required by applicable law; we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

 

2) CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

CodeFuel Ltd. D/B/A, a subsidiary of Perion Network Ltd., incorporated under the laws of the state of Israel, is the Controller (as such term is defined under the General Data Protection Regulation [(Regulation 2016/679) (“GDPR”) or equivalent privacy legislation]. For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact our privacy team as follows:

CodeFuel Ltd.,

26 HaRokmim Street, Azrieli Center, Building A, 4th Floor

Holon 5885849, Israel

  • Data Protection Representative for Data Subjects in the EU, UK and Swiss:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/11106546394.

Attn: Andreas Mätzler

Email: rep_perion@prighter.com.

 

3) DATA SETS WE COLLECT AND FOR WHAT PURPOSE 

We may collect two types of information from you, depending on your interaction with us.

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the website or Services (such as session duration).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data” or “Personal Information” as applicable under law).

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:

DATA SET
Online Identifiers and Marketing Data: When you access and interact with our website, we collect certain online identifiers such as Cookie ID, IP address or similar unique online identifiers generated, advertising ID, tags (“Online Identifiers”). Further, we will collect your behavioral information, which is collected indirectly by our external marketing tools, or analytic tools. This information includes the referring URL (that is, the webpage directing you to our website, and other websites you visited in the session), your interests in our competitors, the web page you visited when you tapped/clicked on our ad, how you interact with our webpage, time, duration of use, pages you have viewed on our website (“Marketing Data”).
Contact Information: If you voluntarily contact us for support or other inquiries, or if you register to receive our newsletter, you will be required to provide us with certain information such as your name, email address, organization name, etc. In addition, you can choose to provide us with additional information as part of your correspondence with us (“Contact Information”).
Additional Features: In the event you choose to provide feedback, post on our website or social media pages, you may be required to provide us with certain additional information such as your role, country, company name, etc.
Recruitment: In the event you apply for a job via our website, we will process your CV (and the information included therein), as well as additional information such as your contact information (name, email address and phone number), information regarding your education and skills, employment history, and your photo (to the extent provided by you). Also, where allowed or required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data. In addition, we may collect other information from public and online sources, referees, background checks where applicable, and former employers and combine such data with the data you provided us (collectively, “Recruitment Data”).
PURPOSE AND OPERATIONS
Online Identifiers and cookies are used, in particular to operate the website and enable its proper functionality, for security and fraud prevention purposes, debugging purposes and to resolve technical problems. For example, in order to automatically recognize you by the next time you enter the website or to confirm you are a real person. Online Identifiers and Marketing Data are indirectly processed by third-parties marketing and analytic tools, for analytic and marketing purposes. We process this data to understand how Visitors use our website and to measure effectiveness of some marketing campaigns we run in order to track conversions, build targeted audience, and market our Services to people who have taken some action on the website.
Provide the required support: We collect your Contact Information to provide you with the support you requested or to respond to your inquiry.
Newsletter: If you registered to receive our newsletter, we will use you Contact Information in order to provide you with the requested communications.
Improve the Services: The correspondence with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).
Direct Marketing: To the extent available through the website, when you contact us and register to a free trial or similar forum, we will use your email address in order to send you service communications and marketing promotions, such as new features, additional offerings, special opportunities or any other information we think you will find valuable (“Direct Marketing”).
Keep a suppression list:
We will further use your email address, if applicable, under our suppression list, when you request to opt-out to ensure we comply with such preference and choice.
We will use this information for the purpose of providing you with the services that you requested.
We will use your Recruitment Data to process your job application and for recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements. Following the completion of the recruitment process, we may further retain and store the Recruitment Data (including other interactions with us under such process) as part of our internal records keeping, including for legal defense from any future claim, as well as, and subject to applicable law requirements, to contact you in the future for other position we believe you qualify for. If you are hired, your Recruitment Information will be kept on our HR systems as part of your employment and our corporate management. We currently use JazzHR as our third party service provider to manage the recruitment process on our behalf and process your Recruitment Data based on their Privacy Notice available here.
LAWFUL BASIS UNDER THE GDPR
Online Identifiers which are collected through cookies we implement, which are strictly necessary for the proper and basic operation of the website or fraud prevention will be processed in our legitimate interest. Your Marketing Data which are collected through third-party tracking technologies, including any targeting and marketing cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management. You may withdraw consent at any time by using the cookie preference settings as available in the footer of the website, or by managing opt-out through your browser or device.
We process the Contact Information in order to provide you the requested support, subject to our legitimate interest.
When we process your Contact Information in order to send you our Newsletter, we do so based on your consent which can be withdrawn at any time using the “unsubscribe” link within the communications we sent you.
When we process your Contact Information on order to improve our customer services, we do so based on our legitimate interest.
When we process your email address in order to send you Direct Marketing, we do so based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.
We will keep you email address for purpose of maintaining a suppression list based on our legitimate interest.
We process this information subject to our legitimate interest.
We process your Recruitment Data (including use, store and retain it) for the described purposes, based on our legitimate interest. In some cases, for example, where we will ask you to provide health related information or diversity and inclusion data, we will process such data based on our obligations in employment and the safeguarding of your fundamental rights. Where you provided your consent, we will process your Recruitment Data in order to contact you with further job offers which we believe you might be interested in.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in Section 10 “INTENATIONAL DATA TRANSFER” below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the website and Services and to enforce our policies and agreements, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

 

4) HOW WE COLLECT YOUR INFORMATION

We may collect information either automatically or voluntarily provided by you. Automatic collection of information is usually made through the use of cookies, pixel tags, local storage, databases, and server logs, all as detailed below.

 

5)  COOKIES AND SIMILAR TRACKING TECHNOLOGIES

When you browse our website, we, or our third party vendors, place “cookies”, “pixels” or “web beacons”, that collect certain information about your usage and interaction with the website and use this information for marketing CodeFuel and the Services CodeFuel offers, to find leads and prospects, as detailed in the table above. We also use these tools for analytic purposes as detailed above.

You can find more information about cookies at www.allaboutcookies.org.

Please see our cookie list, as well instruction on how to change your cookies settings and preferences at any time, available through our website footer.

Also note that, most browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings.

 

6) DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your Personal Data with third parties, including with business partners or service providers that help us provide our Services. You can find below information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT
Service Providers
Affiliated companies
Any acquirer of our business
Governmental agencies, or authorized third parties
DATA THAT WILL BE SHARED
All types of Personal Data
All types of Personal Data
All types of Personal Data
Subject to law enforcement authority request.
PURPOSE OF SHARING
We may disclose Personal Data to our trusted agents and service providers (including, but not limited to, our Cloud service provider, our analytics service provider, our CRM provider, etc.) so that they can perform requested services on our behalf. Thus, we share your data with third party entities, for the purpose of storing such information on our behalf, or for other processing needs. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.
We may share certain information with our affiliated companies within the Perion Group, which will provide us with certain required services and, for internal compliance and measurement, etc.
We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or security of the Perion Group, our customers, partners, or others. We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.

Where we share information with services provider and agents, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

 

7) USER RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

For detailed information on your rights and how to exercise your rights, please see the Data Subject Request Form (“DSR”) available here.

Certain rights can be easily executed independently by you without the need to fill out the DSR Form:

  • You can you can opt-out from receiving our marketing emails by clicking “unsubscribe” link.
  • you can withdraw consent for processing Personal Data for analytics or marketing purposes, by using the cookie settings on the website, or using your device setting.

 

8) DATA RETENTION

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable.

The retention periods are determined according to the following criteria:

I. For as long as it remains necessary in order to achieve the purpose for which the Personal Data was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.

II. Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirement.

III. Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges.

IV. If we reasonably believe there is a prospect of litigation relating to your Personal Information.

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

 

9) SECURITY MEASURES

We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry such as: encryption using SSL, we minimize the amount of data that we store on our servers, restrict access to Personal Data to CodeFuel employees, contractors and agents, etc. Note that, we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: privacy@codefuel.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

 

10)  INTERNATIONAL DATA TRANSFER

the Perion Group of companies are based in Israel, and therefore your Personal Data may be accessed from territories which are not your country of residence. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receive an adequate level of protection as required under applicable law. Furthermore, when Personal Data that are collected within the European Economic Area (“EEA“), the UK or Swiss are transferred outside of the EEA, the UK or Swiss (respectively) to a country that has not received an adequacy decision from the European Commission or an equivalent competent authorities, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union (SCCs) or the UK standard contractual clauses (UK SCCs) as approved by the UK Information Commissioner Office (ICO), as applicable.

 

11) ELIGIBILITY AND CHILDREN PRIVACY

The website is not intended for use by children under the age of 16,  and we do not knowingly process children’s information. We will discard any information that we receive from a Visitor that is considered a “child” immediately upon our discovery that such a user shared information with us. Please contact us at: privacy@codefuel.com if you have reason to believe that a child has shared any information with us.

 

12) JURISDICTION-SPECIFIC NOTICES

A. ADDITIONAL NOTICE TO COLORADO RESIDENTS

This section applies to Colorado residents, acting only as an individual or household context. Pursuant to the Colorado Privacy Act (“CPA”) please see below the disclosure of the categories of Personal Data that are collected or processed, the purposes, how consumers can exercise their rights, and appeal such decision, categories of third-parties the controller shares or sells the personal data, or sells the personal data for advertising and how to opt-out.

 

Under the CPA, CodeFuel is required to provide a privacy notice that identifies the categories of Personal Data that are collected or processed, the purposes, how consumers can exercise their rights, and appeal such decision, categories of third-parties the controller shares or sells the personal data, or sells the personal data for advertising and how to opt-out.

In Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Our DSR details and discloses your rights and Personal Data shared or sold for targeted advertising.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. If the request is submitted by someone other than the consumer about whom information is being requested, proof of authorization (such as power of attorney or probate documents) will be required.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@codefuel.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/.

 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

 

B. ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS

The below disclosures apply to Connecticut residents acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), in compliance with the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”).

Under the CDPA, CodeFuel is required to provide you with a clear and accessible privacy notice that includes: the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.

In Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Our DSR details and discloses your rights and Personal Data shared or sold for targeted advertising. Note, under the CDPA consent can be withdrawn within 15-days of notice at any time.

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests, provided we inform you of such extension within the initial 45 days response period, together with the reason for the extension.

If we decline to take action on your request, we shall so inform you without undue delay, however no longer than within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

C. ADDITIONAL NOTICE TO UTAH RESIDENTS

Under the Utah Consumer Privacy Act (“UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your Personal Data are described below.

The UCPA requires CodeFuel to disclose the categories of Personal Data processed, purpose of processing, how you can exercise your rights, including your opt-out rights from the sale of Personal Data or processing for targeted advertising, the categories of Personal Data shared with third parties and with whom, and if CodeFuel sells Personal Data to third parties or processes Personal Data for targeted advertising. Note, under the UCPA, CodeFuel does not “sell” your Personal Data.

In Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. The DSR details and discloses your rights if and to the extent applicable under the UCPA.

We will respond to your request within 45 days after receipt of your request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, we will provide with the reasoning for our refusal.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

D. ADDITIONAL NOTICE TO VIRGINIA RESIDENTS

Under the amended Virginia Consumer Data Protection Act (“VCDPA”), if you are a resident of Virginia acting solely in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.

The VCDPA requires CodeFuel to disclose the categories of Personal Data processed, purpose of processing, how you can exercise your rights, including how a you may appeal our decision with regard to the consumer request, the categories of Personal Data shared with third parties and with whom, and if CodeFuel sells Personal Data to third parties or processes Personal Data for targeted advertising.

In Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. The DSR details and discloses your rights and Personal Data shared or sold for targeted advertising.

We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@codefuel.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you or your request, we will not be able to grant your request.