OVERVIEW

The California Consumer Privacy Act of 2018 (the “CCPA”) became effective on January 1, 2020, and was amended to a certain extent by the California Consumer Privacy Rights Act (“CPRA”, and together with the CCPA, “California Privacy Regulations”), which came into effect on January 1, 2023, and created a variety of privacy rights for California residents. Tribexa shares the same information about our practices with everyone but use this notice to make relevant disclosures required by California Privacy Regulations.

This notice includes the following parts:

• Transparency. We are transparent about how your personal information is collected, used, shared, and sold.
• Control. We put you in control of your personal information, including accessing and deleting your personal information.
• Benefits to You. We use your personal information to benefit you and to make your experience better. Learn more about Tribexa’s Privacy Policy.

TRANSPARENCY

What Personal Information We Collect

You have the right to know what kinds of personal information Tribexa is collecting about you, how we collect and our business or commercial reasons for that collection. We make this information available to consumers in the “TYPES OF PERSONAL INFORMATION WE COLLECT AND USE” section of our Privacy Policy.

How We Use and Share Your Personal Information

You have the right to know how personal information is used and our business or commercial reasons for that use. You have the right to know if your personal information is shared by us with any third parties. We may share personal information with Service Providers, as defined by the CCPA, to perform services specified by written contract. In addition, we may share personal information with third parties for other notified purposes, as permitted by California Privacy Regulations.

We make this information available to consumers in the “DISCLOSURE OF PERSONAL INFORMATION” section of our Privacy Policy.

You have the right to know whether your personal information is being sold. Your personal information is “sold” when it is shared with a third party for monetary or other valuable consideration for something other than a “business purpose” as set forth in the CCPA.

Tribexa Does Not Sell Your Personal Information

CONTROL

Right to Receive, Obtain and Delete

You have the right to:

• Receive what specific pieces of personal information Tribexa has collected, retained, disclosed, or sold about you over the previous 12 months.  Obtain a copy of your personal information held by us.
• Request that we Delete your personal information.
• Request that we Correct any inaccurate personal information held by us. Limit the Use and Disclosure of Sensitive Personal Information (“SPI”) ¹

Tribexa makes it easy for you to exercise your rights. You can contact us by email at contact@tribexa.com. Before helping you with your inquiry, we may ask to verify your identity or the identity of your authorized agent.

Right to “Opt-out” of “Sale”

Tribexa does not sell your personal information, so we do not offer an opt-out.

BENEFITS TO YOU

Financial Incentives

California Privacy Regulations allow businesses to offer consumers financial incentives for sharing personal information.  For example, a business can offer a rewards program or provide a premium service to consumers as compensation for their personal information.  Tribexa does not offer any such programs; however, our clients may, and your participation in any such programs is optional.  If you choose to participate, your participation will be subject to each certain client’s program’s applicable terms and conditions, including how you may withdraw from such programs.

Non-Discrimination

California Privacy Regulations prohibit businesses from discriminating against you for exercising your rights under the law.  Such discrimination may include, but is in no way limited to, denying a good or service, providing a different level or quality of service, or charging different prices.  California Privacy Regulations permit businesses to provide differing levels or quality of service or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.

¹ This right is limited by our right to collect, use or disclose such SPI, which is necessary and proportionate:

• to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; to prevent, detect, and investigate security incidents that compromise PI;
• to resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions; to ensure the physical safety of natural persons;
  for short-term and transient use, provided that the personal information is not disclosed to another third party and is not used for target advertising outside the consumer’s current interaction with the business;
• to perform services on behalf of the business;
• to verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business; or
• to collect or process SPI where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Final Regulations Text, CALIFORNIA PRIVACY PROTECTION AGENCY, https://cppa.ca.gov/meetings/materials/20230203_item4_text.pdf Section 7027 (m).