This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of RA Outdoors, LLC, doing business as Aspira, and its affiliated companies and subsidiaries (collectively, “Aspira”, “us”, “we”, or “our”) and applies solely to visitors to and users of our websites (“Sites”), our blogs, our mobile applications (“Applications”), and our online products and services (collectively, “Services”) who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

A. Identifiers

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. Commercial information.

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

F. Internet or other similar network activity.

Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

G. Geolocation data.

Examples: Physical location or movements.

I. Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

K. Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Additionally, we have not collected the following categories of personal information from consumers within the last twelve (12) months:

E. Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

H. Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including 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:

The information we collect directly from consumers includes:

• Account information for our Sites
• Log in Information for our Sites
• Log in and location information for our Applications
• Information in connection with contests, surveys and questionnaires
• Information in connection with the purchase of licenses, reservations, and permits or payment of fines
• User profiles, comments and posts
• Job site references

The information we collect from third parties includes:

• Basic information, such as your name, profile picture, gender, networks, Facebook user ID, list of friends and any other information that you have made public on Facebook, if you log into Facebook through our Sites or Applications.
• Information provided to us by organizations and entities that use our Services to provide a service to consumers (our “Clients”) (including agents of our Clients) about individuals who have reserved a campsite or purchased a hunting or fishing license or who the Client wants us to contact or otherwise provide Services to on behalf of the Client.

We may use cookies, web beacons, tags, scripts, and other automated devices to collect information, including personally identifiable information, about you when you visit our Sites and receive emails from us. Specifically, we may collect the following information about your use of our Sites via these technologies: your browser type and operating system; web pages you view; links you click; your Internet Protocol (“IP”) address; your approximate geographic location; your interaction with the Sites; length of time you are logged in to our Sites; and websites visited before or after our Sites. In some of our email messages, we use a “click-through URL” linked to content on a Site. When Consumers click one of these URLs, they pass through a separate web server before arriving at the destination page on one of our Sites. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our Consumer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. We also collect non-personal data (including, without limitation, of the type set forth above) from third parties. The information we collect from third parties may be combined with the information we collect. This information also may be associated with your username and combined with other information, including personally identifiable information that we collect about you. For more detailed information on our use of cookies and other tracking technologies, please see our Cookie Policy.

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

• To provide our Services to you, to communicate with you about your use of our Services and for other customer service purposes;
• To provide information that you have requested to receive from us in response to your opt-in requests;
• To provide our Services at the request of our Clients;
• To administer activities on behalf of our Clients;
• To improve our Sites and Services by providing personalized experiences, location customization, personalized help, and instructions;
• For marketing and advertising purposes; for example, we may use your information to display targeted advertisements to you on our Sites and to assist us in advertising our Services on third party websites;
• To send you email, follow-up questions about your activity, news and newsletters, promotions, and/or invitations to visit the Site;
• To better understand how users access and use our Sites and Services, both on an aggregated and individualized basis, and for other research purposes;
• As necessary or appropriate to protect the rights, property or safety of us, 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
• 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.

Additionally, we may use information that we collect about you in order to allow third-party vendors, including Google, to show you ads on sites across the Internet (e.g. remarketing).

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

Notwithstanding the foregoing, in certain contexts, we collect personal information on behalf of our Clients subject to contractual requirements that prohibit us from selling the personal information and limiting our ability to retain, use, or disclose the personal information in ways that are more narrow than those set out in this privacy notice (e.g., the information be only used as necessary to provide Services to the Client as specified in the contract). In those limited circumstances, when we are acting as a service provider on behalf of one of our Clients, your information is subject to those contractual requirements and not to this privacy notice, subject to enforcement by the applicable Client. If your personal information is collected on behalf of a third party, it will be evident at the time that you provide such personal information. This privacy notice does not cover our Clients’ use of your personal information outside of our Services. You should contact that party directly to determine if your personal information is subject to such limitations on uses and to ascertain how the third party will make use of your 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 prohibits the recipient from selling the personal information and requires the recipient not to retain, use, or disclose it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category I:         Professional or employment-related information.

Category K:        Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• 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, including our Clients.

We do not sell your personal information.  In the preceding twelve (12) months, we have not sold any personal information.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those 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 we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • 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.

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 consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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. Debug products to identify and repair errors that impair existing intended 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 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.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at  888-836-8762.
• emailing us at privacy@aspiraconnect.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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information 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.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), 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.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request.  If we determine that your request is excessive, repetitive, or manifestly unfounded, we will tell you why we made that decision and we may, in such instances, refuse to comply the request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonable relate to your personal information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

We may change this privacy notice from time to time, so be sure to check back periodically. If we make any changes to this privacy notice that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to notify you in advance of such change, by highlighting the change on the Sites or by sending an email to you at the email address that you have registered with us. Your continued use of the Services after any changes or revisions to this privacy notice will indicate your agreement with the terms of the revised privacy notice.

If you have any questions or comments about this 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 do not hesitate to contact us at:

Aspira
Attn: Privacy Office
717 N. Harwood Street
Suite 2400
Dallas, TX 75201
Email: privacy@aspiraconnect.com