California Privacy Notice

Effective Date: October 26, 2021

This California Privacy Notice ("Notice") is a supplement to Hard Assets Alliance LLC ("HAA" "us" "we" "our") other privacy policies or notices. In the event of a conflict between any other HAA policy, statement, or notice and this Notice, this Notice will prevail as to California residents and their rights under California law.

THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

In accordance with the CCPA's requirements, this Notice describes our Collection, use, and disclosure of California Consumers' "Personal Information" ("PI") during the preceding twelve months, as well as the rights California Consumers have under the CCPA. Terms defined in the CCPA that are capitalized in this Notice have the same meanings as in the CCPA unless otherwise stated.

Consistent with the CCPA, job applicants, current and former employees and contractors, and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered Consumers for purposes of this Notice or the rights described herein.

Collection and Use of Personal Information

We Collect and share PI about California Consumers as described in the table below.

We Collect PI directly from the Consumer (e.g., when you complete an order, create an account, or request information from us), indirectly from the Consumer (e.g., through user activity on our website), from other individuals (e.g., when friends or family place a gift order or book a trip or class), and through customer service call recordings.

We Collect PI for the following business purposes:

• Providing our services, including maintaining and servicing your accounts, verifying your information, billing and processing payments, marketing, analytics services, and similar functions and services;
• Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
• Troubleshooting our services to identify and repair issues;
• Internal research and development;
• Quality and safety assurance, and improving, upgrading, and enhancing our products and services; and
• Processing and managing interactions and transactions for our products and services.

In addition, we may Collect, use, and disclose your PI as required or permitted by applicable law, when requested or compelled by law enforcement or legal process, for required tax reporting, or in connection with contractual obligations. We do not treat deidentified data or aggregate consumer information as PI, and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information.

Subject to the CCPA’s restrictions and obligations, our service providers and business partners also may use your PI for some or all of the above-listed business purposes (including to facilitate interest-based advertising and other advertising and marketing).

CCPA PRIVACY RIGHTS

Under the CCPA, California Consumers have certain rights which they may exercise independently or through an Authorized Agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify that the requestor is the Consumer about whom we Collected PI.

Some PI we maintain about Consumers (e.g., clickstream data) is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer's PI. Accordingly, we will not include such information in response to Consumer requests. If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to us for another purpose.

Your California Consumer privacy rights are described below. To make a request, you may email us at privacy@hardassetsalliance.com or call us at (877) 727-7387 or (646) 530-8445. In making a request, you will need to verify that you are the authorized user of the subject email address/account and that you are a current resident of the State of California. Please follow the instructions on our website and promptly respond to any follow-up inquires so that we may confirm your identity. If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards. An Authorized Agent may submit a request on behalf of a Consumer if the Consumer has provided the Authorized Agent with power of attorney in accordance with California law; alternatively, we will (1) require the Authorized Agent to present verifiable written authorization from the Consumer that the Authorized Agent has the Consumer’s permission to submit the request; and (2) independently verify the Consumer’s own identity with us.

We may Collect, use, and disclose your PI as required or permitted by applicable law. Please note we are not obligated to comply with Consumer requests to the extent that doing so would infringe on our, or any other person's or party's rights, or conflict with applicable law.

Disclosure Rights

You have the right to request that we disclose your PI that we have Collected and are maintaining for the 12-month period prior to your request date. Consumer requests of this nature may be made no more than two times in a 12-month period.

• The categories of PI we have Collected about you.
• The categories of sources from which we Collected your PI.
• The business or commercial purposes for Collecting or Selling your PI.
• The categories of third parties with whom we have shared your PI.
• The specific pieces of PI we have Collected about you.
• A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
• A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we will also list the categories of third parties to which we Sold PI, by categories of PI Sold for each Third Party.

You have the right to make or obtain a portable copy, no more than twice in a 12-month period, of your PI that we have Collected in the period that is 12 months prior to the request date and are maintaining.  Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

"Do Not Sell" Rights

We do not sell California Consumer PI, including PI of minors under the age of 16, as “sell” is defined under the CCPA.

Additionally, we work with service providers and partner with advertising companies that use cookies and other tracking technologies to Collect information about your visits to our website and third-party sites, and then use that information to deliver advertisements relevant to your interests. There is not yet a consensus as to whether third party cookies and tracking technologies associated with our websites and mobile apps constitute a “sale” of your Personal Information as defined by the CCPA.

For more information on how we use cookies and other tracking technologies, please review our Privacy Policy. You may opt out of interest-based advertising using ad industry opt out tools by visiting youradchoices.com/control and optout.networkadvertising.org. To effectively manage cookies via these tools, you must set cookie preferences on all browsers and all devices that you use. If you clear the cookies on your device, you may need to set your cookie preferences with these tools again. We are not responsible for the completeness, accuracy, or effectiveness of any third-party programs, tools, or frameworks, or the information they provide.

Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have Collected directly from you and are maintaining.  Our retention rights include, without limitation, to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.

Non-Discrimination Rights

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

CALIFORNIA MINORS

Although our online service(s) are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the online service, can request removal by contacting us privacy@hardassetsalliance.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

CONTACT US

For more information regarding your California privacy rights, you may email us at privacy@hardassetsalliance.com or write us at:

Hard Assets Alliance
ATTN: Privacy/Legal & Compliance
485 Lexington Avenue
Suite 304
New York, NY 10017