1. LINK TO OTHER SITES

This Privacy Policy only applies to Services provided by Company. The Services may contain links to third party websites or resources, which may or may not be obvious (“Third Party Sites”) as well as advertisements, software, text, graphics, articles, photographs, pictures, designs, sound, video, music, information, and other content originating from third parties (collectively, “Third Party Content”). Our provision of links to Third Party Sites is not an endorsement of any information, products or services that are offered on or through any Third Party Site or Third Party Content. Such Third Party Sites and Third Party Content are not monitored or checked for accuracy, appropriateness, or completeness by us, and we are not responsible for the content or performance of any Third Party Sites accessed through the Services or any Third Party Content posted on, available through, or installed from the Services, including the content, accuracy, offensiveness, opinions, reliability, privacy practices or other policies of or contained in the Third Party Sites or the Third Party Content. If you leave the Services and access any Third Party Site, or if you use or install any Third Party Content, you do so at your own risk and you should be aware that our Privacy Policy no longer governs. You hereby expressly agree to comply with any and all terms and conditions, user guides, and privacy policies of any Third Party Sites.  

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2. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.
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In Short: We collect personal information that you provide to us such as name, address, email, and contact information.
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We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services or otherwise contacting us.
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The personal information that we collect depends on the context of your interactions with us, the choices you make, and the products and features you use. The personal information we collect can include the following:
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Publicly Available Personal Information. We collect first name, maiden name, last name, nickname, email addresses, and other similar data.
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All personal information that you provide to us must be true, complete and accurate
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Online Identifiers. We collect cookie identifiers, or others such as the ones used for analytics and marketing, and other similar data.

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3. FINANCIAL INFORMATION

We may collect data necessary to process cash back rewards, loyalty rewards, and brand ambassador payments, such as phone number related to Venmo account information and other financial information (“Financial Data”). Financial Data shall only be used as is necessary to issue cash back rewards and brand ambassador payments and comply with loyalty programs.

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4. MOBILE TERMS AND CONDITIONS

By texting us with your receipt to opt into cash back rewards, or by opting into our loyalty rewards or brand ambassador payments or any of our services or to receive messages or offers from us, you consent to receive mobile text alerts using an automatic telephone dialing system and our PICADELI US MOBILE MESSAGING TERMS AND CONDITIONS.

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5. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
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We use personal information collected for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
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We use the information we collect or receive:
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To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” Section below).
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Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
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Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
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To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
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To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contracts.
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To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
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To deliver services to the user. We may use your information to provide you with the requested service.
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To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
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For other Business Purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

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6. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
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We may process or share data based on the following legal bases:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:
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• Vendors, Consultants and Other Third Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
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• Third Parties that Help Provide Text-Messaging Services. We will not share your opt-in to an SMS campaign with a third party for purposes unrelated to supporting you in connection with such SMS campaign. We may share your personal information with third parties that help us provide text-messaging services, including but not limited to platform providers, phone companies, and other vendors who assist us in the delivery of text messages.
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• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of the Company to another company.
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• Third Party Advertisers. We may use third party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Services and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
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• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
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• Additional Disclosures; Affiliates. We may disclose your personal information to our affiliates or subsidiaries; however, if we do so, the affiliates or subsidiaries’ use and disclosure of your personal information will be subject to this Privacy Policy.  
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• Exclusions. All of the above categories of personal information exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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7. HOW TO PROHIBIT SHARING TO THIRD PARTIES

You may prohibit sharing of your personal information to Company’s third party service providers and business partners by emailing perks@picadeli.com or by using the means provided in our marketing communications to unsubscribe.

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8. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.
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When you visit our Services, we may automatically collect certain information such as IP Addresses, browser types and versions, service providers, pages visited, unique device identifiers, operating systems, and more. This information does not reveal specific information about your identity, such as contact information, but may inform us about device and usage information that will help us maintain the security of our Services or for internal analytics and reporting. This information is solely collected to improve our Services and cater to your needs.  
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Our Services use cookies and other tracking technology (such as web beacons and pixels) to track activity on our Services and retain certain information. Cookies are files that contain information to identify your devices that help customize and improve your web browsing experience. You have the option to refuse all cookies or change the settings on your browser to automatically refuse cookies. However, refusing cookies may impact the use and enjoyment of certain parts of our Services.  
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We may collect data that contains information about your device’s location. The extent of this information is dependent upon the settings you use to access our Services. If you do not wish to provide us with location data, you can opt out by refusing access to the information via your browser or disabling location tracking settings on your device. If you opt out of location sharing, certain aspects and functions of the Services may be impacted.

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9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.
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We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us keeping your personal information for longer than 2 years.
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When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.
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We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from us is at your own risk. You should only access the services within a secure environment.

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11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.
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We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at PO Box 69, Pacific Palisades, CA, 90272, United States, email us at perks@picadeli.com, or call us at (213) 468-6700.

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12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.
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You may have certain rights in relation to your personal information including a right to access or to correct your personal information. These rights will only apply in certain circumstances. These rights will generally not be available if there are outstanding contracts between us, if certain laws or regulations require us to keep your personal information or if your personal information is relevant to a legal dispute. We’ve listed the rights you have over your personal information and how you can use them below.
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• You can remove consent, where you have provided it, at any time;
• You can ask us to confirm if we are processing your personal information;
• You can ask for access to your personal information;
• You can ask to correct your personal information if it’s wrong;
• You can ask us to delete your personal information;
• You can ask us to restrict how we use your personal information;
• You can ask us to help you move your personal information to other companies. To help with that, you have a right to ask that we provide your personal information in an easily readable format to another company;
• You can ask us to stop using your personal information, but only in certain cases; and,
• You have the right to complain to the relevant supervisory authority.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or aspects of our Services. To opt-out of interest-based advertising by advertisers on our Services visit https://www.aboutads.info/choices/.

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13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

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14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
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California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
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If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.

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15. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this Privacy Policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

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16. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Privacy Policy, you may contact us by post at Picadeli US Inc, PO Box 69, Pacific Palisades, CA 90272, United States, by email at perks@picadeli.com, and by phone at (213) 468-6700.

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PRIVATE NOTICE FOR CALIFORNIA RESIDENTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (the “Privacy Notice”) supplements the information contained in the Privacy Policy of Picadeli US Inc. (“Company”, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2023 (“CPRA”) and other California privacy laws.  Any terms defined in the CCPA and CPRA have the same meaning when used in this Privacy Notice. Any terms defined in the Privacy Policy have the same meaning when used in this Privacy Notice unless otherwise defined in the Privacy Notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). Please review the following categories of Personal Information and whether we collect this information from consumers:

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Personal Information does not include:

• Publicly available information including but not limited to information from government records;
• De-identified or aggregated consumer information;
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA) or similar laws or clinical trial data; and,
• Personal Information covered by sector-specific privacy laws, including but not limited to the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from consumers or their agents ;
• Indirectly from consumers or their agents through the course of providing Services;
• Directly and indirectly from activity on our Services including, but not limited to, submissions through our Services or Services usage details collected automatically; and,
• From third parties that interact with us in connection with the Services.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To provide information, products or services;
• To provide email alerts, event registrations and other notices concerning our products or services, or events or news;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
• To improve our Services;
• Testing, research, analysis and product development;
• As necessary or appropriate to protect the rights, property or safety of Company, our clients or others;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA, and CPRA; and,
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without first providing you notice.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

Any disclosure of your Personal Information for a business purpose may be to the following categories of third parties:

• Our affiliates;
• Service providers; or
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

We do not sell any Personal Information.

Your Rights

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information collected;
• The categories of sources for the Personal Information collected;
• Our business or commercial purpose for collecting that Personal Information;
• The categories of third parties with whom we shared that Personal Information;
• The specific pieces of Personal Information collected about you (a data portability request);
• The right to correct inaccuracies in your Personal Information; and,
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:some text
  • sales, identifying the Personal Information categories that each category of recipient purchased; and,
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
    
    

Deletion Request Rights
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You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request to delete, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
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We may deny your deletion request if retaining the Personal Information is necessary for us or our service providers to:
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1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Identify and repair errors that impair existing functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Personal Information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation; or,
9. Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
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To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
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• Calling us at (213) 468-6700; or,
• Email: perks@picadeli.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
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You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
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• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and,
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  

We can only respond to requests if we can verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
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Response Timing and Format
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We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, up to ninety (90) days, we will inform you of the reason and extension period in writing. 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. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If applicable, the response we provide will explain the reasons we cannot comply with a request. For data portability requests, we will select a format to provide your Personal Information that is readily useable and allows you to transmit the Personal Information from one entity to another entity.
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Non-Discrimination
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We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
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• Deny you goods or services;
• Charge you different prices or rates, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or,
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  

Changes to Our Privacy Notice
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We reserve the right to amend this Privacy Notice at our sole discretion from time to time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our Services.
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Contact Information
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If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:
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Phone: (213) 468-6700

Email: perks@picadeli.com
Postal Address: Picadeli US Inc, PO Box 69, Pacific Palisades, CA, 90272, United States

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